GDPR Privacy Policy

This Privacy Policy (the “Policy”) describes the personal data that xklusivelyelite.com/ XKLUSIVELYELITE LTD (“XKLUSIVELYELITE LTD”, “we”, “us” or “our”) collects from or about you when you use website xklusivelyelite.com and related services (the “Services”), how we use that information, and to whom we disclose it. For the purposes of the Policy, the term “personal data” will have the same meaning as in EU General Data Protection Regulation 2016/679 (“GDPR”) and California Consumer Privacy Act (CCPA).

This Policy should be read in conjunction with the Terms of Use, into which it is incorporated by reference.

We may modify this Policy from time to time. We will provide you with notice of any material changes to this Policy by publishing or communicate the changes through our Services or by other means so that you may review the changes before continuing to use our Services. Your continued use of the Services after we publish or communicate a notice about any changes to this Policy means that you are consenting to the changes.

In short, XKLUSIVELYELITE LTD stores and processes your personal data and your contacts’ personal data solely to perform the services you have signed up for. We do not sell your information or use it for profiling secondary business objectives. The policies below describe this in greater detail.

XKLUSIVELYELITE LTD is responsible for personal data under our control. We have established policies and procedures to effectively safeguard any confidential personal data that we collect and to deal with complaints and inquiries. We are committed to maintaining the accuracy, confidentiality, and security of your personal data, and we will ensure that you have access to information regarding the policies and procedures that we use to manage your personal data. XKLUSIVELYELITE LTD has designated a Privacy Officer/Data Protection Officer (“Privacy Officer”) who is accountable for our compliance with this Policy and for ensuring that information about our policies and practices relating to the management of personal data is easily accessible. All questions or concerns regarding this Policy and our compliance with it should be directed to the Privacy Officer in writing and sent by email or postal mail to: GDPR@xklusivelyelite.com

Every complaint or challenge regarding our compliance with this Policy will be investigated, and where a deficiency is found to exist, we will take appropriate measures to address it. This may include amending our policies and procedures as necessary. We will also cooperate with regulatory authorities to resolve any complaints that cannot be resolved between us and an individual user.

By using the Services, you signify your agreement to the terms and conditions of this Policy and to our collection, use and disclosure of your personal data as set out herein. You may change or withdraw your consent to the collection, use or disclosure of your personal data at any time by contacting the Privacy Officer in writing at the address listed above (see: Accountability and Openness/ Compliance). In some circumstances, a change or withdrawal of consent may affect your ability to use the Services.

We collect personal data only to the extent that it is necessary for the purposes set out below (see: Purpose – Why We Collect, Use and Disclose Information). Subject to any legal or accounting requirements, we will retain personal data only as long as necessary to fulfill the purposes for which it was collected. Personal data that is no longer required will be destroyed, erased or made anonymous, although copies of deleted information may continue to exist on backup media. Information that we may collect includes:

User Submitted Information

We collect certain personal data at the time users register to create an account or update their account details including a user’s name, e-mail address, and other contact information. We also collect personal data that users submit through their use of the Services, including when they submit contact and other information, they have collected from their email subscribers and when they create and send email campaigns.

Usage Data

We collect certain non-identifying information about the usage of the Services, including information about how users are using the Services and the characteristics of those users. This information is anonymized and is not used by us to identify you as an individual.

Account Deletion Requests

At any time, you can request to have your account data deleted by contacting us. Upon receiving the request, we will send you an email to confirm this request. After successful confirmation, your account will be marked for deletion in 30 days. During this 30-day period, you may request to have your account reactivated by contacting us. After 30 days your account is permanently deleted and cannot be reactivated.

Account Inactivity

To protect your privacy and your data, if your account is not active for a period of 1 year, it will automatically be permanently deleted. 30 days prior to this deletion, an email notification will be sent to the account email address with information about the deletion and instructions on how to keep the account active if desired.

Data Retention Policy

An account can be permanently deleted by either a deletion request or from account inactivity. We retain personal data only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes. These may include retention periods:

• needed to maintain adequate and accurate business and financial records
• for resolving, preserving, enforcing or defending our contractual/legal rights
• mandated by law, contract or similar obligations applicable to our business operations
• to protect recipients from spam or malicious emails

Technical and Device Information

We collect certain non-identifying information related to a user’s access to the Services, including the Internet Protocol (IP) address of the user’s computer, the date and time the user accessed the Services and the operating system that the user is using. We make no attempt to link this information with the identity of individuals visiting our website without express permission.

Cookies and Web Beacons

A “cookie” is a small piece of information stored on your computer by a web page. It is used to identify you to the web server. We use cookies to determine your access privileges on our websites, to complete and support a current activity, and to track website usage. A “web beacon” is an invisible electronic image that is used to track certain information. We use web beacons on our websites, in emails we send to you and in emails you send through the Services.

We will identify the purposes for which we collect personal data before or when we request the information. We will not collect personal data which is not necessary. The information that we collect is used and disclosed only for business purposes including:

• to enable you to access and use the Services
• to process, track and communicate with you about the usage of the Services
• to establish, maintain and manage business relations with you
• internal business purposes such as administering or improving the Services
• to perform internal market research and conduct polls and surveys
• to obtain feedback regarding the Services
• to provide users with information and promotional materials
• to protect us against error, fraud, theft or damage
• to comply with any legal, accounting and regulatory requirements

We may disclose your personal data in response to requests from government agencies, law enforcement authorities, and regulators, or to satisfy legal or regulatory requirements. We may also disclose your personal data when we buy a business or sell all or part of our business. If we transfer any personal data to a third-party subcontractor, we will provide the subcontractors only with the information needed to perform the subcontracted service, and will use appropriate contractual or other means to provide a comparable level of protection.

We maintain reasonable security safeguards to protect personal data from loss or theft, and from unauthorized access, disclosure, copying, use or modification. We use user IDs, passwords and encryption technology, and restrict access to those having a “need to know” who are bound by confidentiality obligations.

XKLUSIVELYELITE LTD has a responsibility to ensure that all personal data contained in our records is accurate, complete and up-to-date. You may make a request in writing for access to your personal data. All notices and requests should be in writing and sent to the Privacy Officer at GDPR@xklusivelyelite.com.

You acknowledge and agree that your personal data may be transmitted, transferred, processed, and/or stored outside of the UK, including in the United States and in the EU, and therefore may be available to governmental authorities under lawful orders and laws applicable in such jurisdictions.

The Services may contain optional links to third party Internet websites and services. This Policy applies only to the XKLUSIVELYELITE LTD Services, and we encourage you to review the privacy policies of any third parties when using their websites or services.

Minors (persons under the age of majority as defined in your jurisdiction) are not eligible to use the Services unsupervised, and we request that minors do not submit any personal data to us. XKLUSIVELYELITE LTD does not knowingly collect personal data from minors.

In the event of a security breach causing unauthorized intrusion of our Services that materially affects you or your contacts, XKLUSIVELYELITE LTD will notify you as soon as possible and later provide a report of the action we took in response to this intrusion.

XKLUSIVELYELITE LTD takes reasonable steps to ensure the data we collect is accurate, complete and up to date. You can contact us directly at GDPR@xklusivelyelite.com. Rights include:

• The right to be informed
• The right of access/rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object

GDPR@xklusivelyelite.com