Effective Date: March 12, 2026
EXCELLO PRIVACY POLICY
This PrivacyPolicy explains how Excello, Inc. (“Excello,” “we,” “us,” or “our”) collects,uses, discloses, and processes information in connection with your access toand use of the Excello platform, website, applications, and services(collectively, the “Service”).
This PrivacyPolicy should be read together with the Excello Terms of Service. Capitalizedterms not defined here have the meanings given in the Terms of Service.
1. Information We Collect
1.1 Information You Provide
We collectinformation you voluntarily provide, including:
• Account information (name, email address, login credentials)
• Subscription and billing information (processed by third-party paymentproviders)
• User-generated content, including prompts, responses, goals, notes, andother inputs (“Customer Content”)
• Communications with Excello
You areresponsible for ensuring that the information you submit does not violateapplicable laws or third-party rights.
1.2 Information Collected Automatically
When you use theService, we may automatically collect:
• IPaddress and approximate location
• Deviceidentifiers, operating system, and browser type
• Usagedata, logs, timestamps, feature interactions, and diagnostic data
• Cookies and similar technologies
This informationis used to operate, secure, monitor, and improve the Service.
1.3 Payment Information
Excello does notstore full payment card numbers or sensitive payment credentials. Payments areprocessed by third-party providers (such as Stripe), which process yourinformation under their own privacy policies. Excello receives limited billingmetadata necessary to administer subscriptions.
2. How We Use Information
We use collectedinformation to:
• Provide, operate, maintain, and secure the Service
• Authenticate users and manage accounts
• Process subscriptions and payments
• Generate outputs based on Customer Content
• Retainand reference prior session content, goals, objectives, key results, andcoaching context to provide continuity and personalized interactions acrosssessions
• Monitor performance, detect abuse, and troubleshoot issues
• Improve and develop features, models, and functionality
• Complywith legal and regulatory obligations
Excello does notuse personal information to provide professional advice or to guaranteeoutcomes.
3. Artificial Intelligence and Automated Processing
The Service usesartificial intelligence and automated systems to process Customer Content andgenerate outputs.
As a core featureof the Service, the platform retains and references your prior inputs, goals,objectives, key results, session history, and coaching context across sessionsto provide continuity and personalized coaching. This information is stored as partof your Customer Content and is used solely to operate the Service for you. Youmay request deletion of this information as described in the Data Retention,California Privacy Rights, and European and United Kingdom Privacy Rightssections of this Privacy Policy.
You acknowledgethat:
• Inputsmay be processed automatically
• TheService retains information from prior sessions, including goals, objectives,key results, and coaching context, and uses this information to personalizesubsequent interactions
• Outputs are generated algorithmically and are not reviewed or verifiedprior to delivery
• Outputs may be inaccurate, incomplete, misleading, speculative, orbiased
• Outputs may appear authoritative while being incorrect
You are solelyresponsible for reviewing and validating outputs before use.
You should notsubmit sensitive personal data unless you understand and accept the associatedrisks.
Customer Contentis used to provide and operate the Service for you. Excello does not useCustomer Content in identifiable form to train or improve general-purposemodels. Excello may use Aggregated and/or De-Identified Data, as describedbelow, to develop, improve, and refine models, insights, and features.
4. Aggregated and De-Identified Data
Consistent withthe Terms of Service:
Excello maycreate Aggregated and/or De-Identified Data derived from Customer Content anduse of the Service.
Aggregated and/orDe-Identified Data is processed using reasonable technical and organizationalmeasures so that it does not identify you, your organization, or anyindividual, and is not reasonably capable of being used, alone or incombination with other data, to identify any individual.
Aggregated and/orDe-Identified Data does not contain Customer Content in an identifiable,attributable, or recoverable form.
Excello may useAggregated and/or De-Identified Data for legitimate business purposes,including to:
• Operate, maintain, secure, and improve the Service
• Develop and enhance products, features, and models
• Generate statistical analyses, benchmarks, insights, and predictivemodels
• Analyze patterns in decisions and aggregated outcome trends
Excello will notattempt to re-identify any individual from Aggregated and/or De-Identified Dataand will not knowingly use such data to identify any individual.
Aggregated and/orDe-Identified Data is not personal information and is not subject to individualaccess, deletion, correction, or portability requests under applicabledata-protection laws.
5. How We Share Information
We do not sellpersonal information.
We may shareinformation in the following circumstances:
5.1 Service Providers
With vendors thatprovide services such as hosting, analytics, security, customer support, andpayment processing, subject to contractual confidentiality obligations.
5.2 Legal and Compliance
Where required bylaw, regulation, legal process, or to protect the rights, safety, or propertyof Excello, users, or others.
5.3 Business Transactions
In connectionwith a merger, acquisition, financing, reorganization, or sale of assets,subject to appropriate confidentiality protections.
6. Data Retention
We retainpersonal information for as long as reasonably necessary to:
• Provide and maintain the Service
• Complywith legal obligations
• Resolve disputes
• Enforce agreements
Aggregated and/orDe-Identified Data may be retained indefinitely.
7. Data Security
We implementreasonable administrative, technical, and organizational safeguards designed toprotect information.
However, nosystem can be guaranteed to be completely secure.
8. International Data Transfers
Your informationmay be transferred to and processed in the United States or other jurisdictionswhere our service providers operate. Where required by applicable law, we relyon appropriate transfer mechanisms, such as Standard Contractual Clauses approvedby the European Commission, to safeguard your information when it istransferred outside your home jurisdiction.
9. California Privacy Rights (CCPA / CPRA)
If you are aCalifornia resident, you may have the right to:
• Knowthe categories and specific pieces of personal information collected
• Request correction or deletion of personal information
• Optout of the sale or sharing of personal information (note: Excello does not sellpersonal information)
• Not bediscriminated against for exercising privacy rights
Requests may besubmitted using the contact information below and will be verified as requiredby law.
De-identified andaggregated data is excluded from these rights under applicable law.
10. European and United Kingdom Privacy Rights
If you arelocated in the European Union, the European Economic Area, or the UnitedKingdom, you may have additional rights under the General Data ProtectionRegulation (GDPR) or the UK General Data Protection Regulation (UK GDPR),including the right to:
• Access the personal data we hold about you
• Request correction or deletion of yourpersonal data
• Restrict or object to certain processing ofyour personal data
• Request portability of your personal data
• Withdraw consent at any time, whereprocessing is based on consent
• Lodge a complaint with your local supervisoryauthority
Our legal basesfor processing your personal data include: performance of our contract with you(to provide the Service), our legitimate interests (to operate, improve, andsecure the Service), and your consent (where applicable). Requests may besubmitted using the contact information below.
11. Children’s Privacy
The Service isnot intended for individuals under 18 years of age. We do not knowingly collectpersonal information from children.
12. Changes to This Privacy Policy
We may updatethis Privacy Policy from time to time. Material changes will be communicatedthrough the Service or by email. Continued use of the Service after theeffective date constitutes acceptance of the revised Privacy Policy.
13. Contact Information
Excello, Inc.
hello@excello.ai
