Privacy Notice

1. About This Notice

Exelcius, Inc. ("Exelcius," "we," "us," or "our") is committed to protecting personal information entrusted to us. This Privacy Notice explains, at a high level, how we collect, use, disclose, retain, and protect personal information in connection with our business activities and services.

This public notice is intended for customers, prospective customers, business contacts, partners, vendors, and other individuals whose personal information Exelcius may process. Additional contractual or role-specific privacy terms may apply in particular circumstances.

2. Personal Information We May Process

Depending on your relationship with Exelcius, we may process personal information that is reasonably necessary to conduct our business or provide services, including:

• Contact and identification information, such as name, business email address, phone number, and company or organization.
• Professional and business information, such as job title, role, and business relationship details.
• Communications and service-related information that you provide when contacting us, requesting information, or working with us.
• Personal information provided to Exelcius by a customer or other authorized party where that information is necessary to perform agreed services.
• Other personal information that is provided to us for a legitimate business purpose or that we are required to process by law or contract.

3. How We Use Personal Information

Exelcius uses personal information only for legitimate business purposes and in accordance with applicable legal and contractual requirements. These purposes may include:

• Providing, supporting, and administering our services and business relationships.
• Communicating with customers, prospective customers, partners, and other business contacts.
• Managing access to systems, services, and information where appropriate.
• Protecting the confidentiality, integrity, and availability of Exelcius and customer information.
• Detecting, investigating, responding to, and documenting security or privacy incidents.
• Meeting legal, regulatory, contractual, audit, and compliance obligations.
• Managing internal business operations and improving our processes and controls.

4. Consent and Other Legal Requirements

Where consent is required by applicable law or contract, Exelcius will seek appropriate consent before collecting, using, or disclosing personal information for the relevant purpose. Where processing is permitted on another lawful or contractual basis, Exelcius may rely on that basis instead.

If you withdraw consent where consent is the applicable basis for processing, Exelcius will review the request and take appropriate action consistent with applicable law and contractual obligations.

5. How We Share Personal Information

Exelcius may share personal information only where reasonably necessary for a legitimate business purpose, to provide agreed services, to meet legal or contractual obligations, or to protect our rights, operations, customers, or users.

We may use third-party service providers to support our business and technology environment. Where such providers process personal information on our behalf, Exelcius expects appropriate contractual, security, and privacy protections to apply.

We may also disclose information where we reasonably believe disclosure is required by law, necessary to investigate fraud or security issues, necessary to enforce our agreements, or necessary to protect Exelcius, our customers, or other individuals.

6. Data Retention

Exelcius retains personal information only for as long as reasonably necessary for the purpose for which it was collected, to provide services, to meet contractual requirements, or to satisfy applicable legal, regulatory, audit, or recordkeeping obligations.

Where appropriate and subject to applicable requirements, personal information may be returned, deleted, destroyed, or otherwise securely disposed of when it is no longer required.

7. Data Transfers

Personal information may be processed or transferred through systems and service providers used to support Exelcius operations. Exelcius takes reasonable steps to ensure that appropriate protections are applied to personal information transferred to third parties or across jurisdictions, consistent with applicable law and contractual requirements.

8. Information Security

Exelcius maintains administrative, technical, and organizational safeguards designed to protect personal and confidential information against unauthorized access, use, disclosure, alteration, loss, or destruction. Safeguards are applied based on the sensitivity of the information, applicable risks, and relevant legal and contractual requirements.

No method of electronic transmission or storage can be guaranteed to be completely secure. Exelcius therefore reviews and improves its security and privacy practices as appropriate to its business and risk environment.

9. Security and Privacy Incidents

Exelcius maintains processes for identifying, assessing, responding to, and documenting security and privacy incidents. Where an incident affects personal information and notification is required by applicable law or contract, Exelcius will make or support the appropriate notifications based on the circumstances.

10. Your Privacy Rights

Depending on where you are located and the laws that apply, you may have rights relating to your personal information, such as requesting access, correction, deletion, restriction, or other appropriate action.

Requests will be reviewed in light of the applicable law, our contractual obligations, the nature of our relationship with you, and any information we may need to verify the request. In some cases, Exelcius may process personal information on behalf of a customer, in which case the relevant customer may be responsible for handling the request.

11. Changes to This Privacy Notice

Exelcius may update this Privacy Notice from time to time to reflect changes in our practices, services, legal requirements, or privacy program. The effective date at the top of this notice indicates when the current version became effective.

12. Contact Us

Questions, concerns, or requests regarding this Privacy Notice or Exelcius privacy practices may be directed to Exelcius through the contact information provided on our website. Please identify your request as a privacy matter so it can be routed to the appropriate person. At Exelcius, privacy oversight is assigned to the Chief Technology Officer (CTO).