Effective Date: March 5, 2026

EXCELLO PRIVACY POLICY

This Privacy Policy explains how Excello, Inc. ("Excello," "we," "us," or "our") collects, uses, discloses, and processes information in connection with your access to and use of the Excello platform, website, applications, and services (collectively, the "Service").

This Privacy Policy should be read together with the Excello Terms of Service. Capitalized terms not defined here have the meanings given in the Terms of Service.

Geographic Restriction

The Service is intended solely for users located outside the European Union (EU), the European Economic Area (EEA), the United Kingdom (UK), and Switzerland. The Service is not offered to, directed at, or intended for use by residents or citizens of those jurisdictions. Excello does not knowingly collect or process personal data that is subject to the EU General Data Protection Regulation (GDPR), the UK General Data Protection Regulation (UK GDPR), or the Swiss Federal Act on Data Protection (FADP).

If you access or use the Service from a restricted jurisdiction in violation of the Terms of Service, you do so at your own risk. Excello assumes no obligation to provide data subject rights, data processing disclosures, or other protections required under GDPR, UK GDPR, or similar frameworks, and will not be liable for any failure to do so.

1. Information We Collect

1.1 Information You Provide

We collect information you voluntarily provide, including:

  • Account information (name, email address, login credentials)
  • Subscription and billing information (processed by third-party payment providers)
  • User-generated content, including prompts, responses, goals, notes, and other inputs ("Customer Content")
  • Communications with Excello

You are responsible for ensuring that the information you submit does not violate applicable laws or third-party rights.

1.2 Information Collected Automatically

When you use the Service, we may automatically collect:

  • IP address and approximate location
  • Device identifiers, operating system, and browser type
  • Usage data, logs, timestamps, feature interactions, and diagnostic data
  • Cookies and similar technologies

This information is used to operate, secure, monitor, and improve the Service.

1.3 Payment Information

Excello does not store full payment card numbers or sensitive payment credentials. Payments are processed by third-party providers (such as Stripe), which process your information under their own privacy policies. Excello receives limited billing metadata necessary to administer subscriptions.

2. How We Use Information

We use collected information to:

  • Provide, operate, maintain, and secure the Service
  • Authenticate users and manage accounts
  • Process subscriptions and payments
  • Generate outputs based on Customer Content
  • Monitor performance, detect abuse, and troubleshoot issues
  • Improve and develop features, models, and functionality
  • Comply with legal and regulatory obligations

Excello does not use personal information to provide professional advice or to guarantee outcomes.

3. Artificial Intelligence and Automated Processing

The Service uses artificial intelligence and automated systems to process Customer Content and generate outputs.

You acknowledge that:

  • Inputs may be processed automatically
  • Outputs are generated algorithmically and are not reviewed or verified prior to delivery
  • Outputs may be inaccurate, incomplete, misleading, speculative, or biased
  • Outputs may appear authoritative while being incorrect

You are solely responsible for reviewing and validating outputs before use.

You should not submit sensitive personal data unless you understand and accept the associated risks.

Customer Content is used to provide and operate the Service for you. Excello does not use Customer Content in identifiable form to train or improve general-purpose models. Excello may use Aggregated and/or De-Identified Data, as described below, to develop, improve, and refine models, insights, and features.

4. Aggregated and De-Identified Data

Consistent with the Terms of Service:

Excello may create Aggregated and/or De-Identified Data derived from Customer Content and use of the Service.

Aggregated and/or De-Identified Data is processed using reasonable technical and organizational measures so that it does not identify you, your organization, or any individual, and is not reasonably capable of being used, alone or in combination with other data, to identify any individual.

Aggregated and/or De-Identified Data does not contain Customer Content in an identifiable, attributable, or recoverable form.

Excello may use Aggregated 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 predictive models
  • Analyze patterns in decisions and aggregated outcome trends

Excello will not attempt to re-identify any individual from Aggregated and/or De-Identified Data and will not knowingly use such data to identify any individual.

Aggregated and/or De-Identified Data is not personal information and is not subject to individual access, deletion, correction, or portability requests under applicable data-protection laws.

5. How We Share Information

We do not sell personal information.

We may share information in the following circumstances:

5.1 Service Providers

With vendors that provide services such as hosting, analytics, security, customer support, and payment processing, subject to contractual confidentiality obligations.

5.2 Legal and Compliance

Where required by law, regulation, legal process, or to protect the rights, safety, or property of Excello, users, or others.

5.3 Business Transactions

In connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to appropriate confidentiality protections.

6. Data Retention

We retain personal information for as long as reasonably necessary to:

  • Provide and maintain the Service
  • Comply with legal obligations
  • Resolve disputes
  • Enforce agreements

Aggregated and/or De-Identified Data may be retained indefinitely.

7. Data Security

We implement reasonable administrative, technical, and organizational safeguards designed to protect information.

However, no system can be guaranteed to be completely secure.

8. International Data Transfers

Your information may be transferred to and processed in the United States. By using the Service, you consent to the transfer and processing of your information in the United States, which may not provide the same level of data protection as your home jurisdiction.

9. California Privacy Rights (CCPA / CPRA)

If you are a California resident, you may have the right to:

  • Know the categories and specific pieces of personal information collected
  • Request correction or deletion of personal information
  • Opt out of the sale or sharing of personal information (note: Excello does not sell personal information)
  • Not be discriminated against for exercising privacy rights

Requests may be submitted using the contact information below and will be verified as required by law.

De-identified and aggregated data is excluded from these rights under applicable law.

10. Children's Privacy

The Service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the Service or by email. Continued use of the Service after the effective date constitutes acceptance of the revised Privacy Policy.

12. Contact Information

Excello, Inc.
hello@excello.ai