Xelerate, LLC Privacy Policy

Xelerate, LLC (“Xelerate” or “us” or “we”) is committed to protecting the privacy of users of its website (the “Website”). We will use reasonable efforts to see that all information, identifying and otherwise, submitted to us by users, remains private and is used only for the purposes set forth.

Furthermore, at Xelerate we believe our online users have a right to know what information we collect when you visit our Website. This Privacy Policy describes the types of information we gather about you, how we use such information, with whom we might share such information and the means by which we keep the information secure.

Please read this Privacy Policy carefully. By accessing or submitting information through this Website, you are deemed to have consented to the practices described in this Privacy Policy.

The Website may contain links to third party websites which, in some cases, may be incorporated into, and appear to be part of, the Website. However, once you have used these links to leave the Website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide while visiting such sites and such sites are not governed by this Privacy Policy. Therefore, you should exercise caution and look at the privacy statement applicable to the website in question. Xelerate disclaims any responsibility for the privacy policies and procedures of any third-party websites that you reach via a hyperlink contained on the Website.

Data Usage

In general, when you visit our Website, we do not collect personally identifiable information about you. When you register on our Website to obtain more information about Xelerate’ services, you will be asked to complete a registration and eligibility form. We collect the following types of information: your name, address, e-mail address, telephone number, facsimile number and certain eligibility representations.  We use your name, address, e-mail address, telephone number, facsimile number and eligibility information to contact you regarding your eligibility to access our password protected pages. Xelerate may also use personal data:

• to communicate and respond to inquiries from you,
• to provide meeting services,
• to open accounts or process transactions for such accounts (and to evaluate eligibility for accounts and participation in meetings),
• to contact you with information or promotional materials about Xelerate,
• for recruitment and talent management,
• to develop new products or services,
• to review usage of and enhance experience with its Website,
• to operate, evaluate, and improve its business, and
• to comply with and enforce applicable regulatory and legal requirements and industry standards.

To opt-out of any marketing emails from Xelerate, you should follow the unsubscribe or opt-out instructions in such emails, and Xelerate will use commercially reasonable efforts to promptly implement such requests. You may continue to receive non-marketing communications related to administrative or transactional matters regarding your existing relationship with Xelerate.

Data Sharing

Xelerate does not sell personal data to any third parties. Xelerate may share personal data as needed to fulfill the purposes described in the “Data Usage” section above, including:

• with nonaffiliated persons and entities that assist it in managing and operating its business or that perform other services for it, such as attorneys, tax advisors, administrators, accountants, auditors, custodians, and entities that assist Xelerate with the facilitation of meetings;
• to Xelerate’ affiliates, for marketing purposes unless you have opted out of such sharing, or for purposes of facilitating requests for information;
• as permitted or required by law, including to verify eligibility under OFAC, for governmental permits or licensing, or other regulatory and compliance requirements; or
• as requested or approved by the applicable user (including to its advisors, which can include, among others, accountants, investment advisors, and/or attorneys).

In the event of a merger, consolidation, sale, or transfer of all or substantially all of Xelerate’ assets or business, one of the assets which would generally be transferred is the personal data that has been collected. Xelerate will advise a successor or successors in interest of the terms of this Policy and the expectation that such successor(s) will comply with the terms hereof.

Xelerate requires third-party service providers to protect the confidentiality of data subjects’ information and to use the information only for the purposes for which Xelerate discloses the information to them.

Data Security

Xelerate does not share end-user information with third parties/affiliates for marketing/promotional purposes. Xelerate may share end-user opt-in data with subcontractors or outsourced service providers solely to fulfill the service rendered to the end-user.

Xelerate takes commercially reasonable physical, administrative, and technical precautions designed to protect personal data from loss, misuse, or unauthorized alteration. While Xelerate uses reasonable efforts to safeguard the confidentiality of personal data, it cannot guarantee that data will always remain secure due to transmission errors, outside events, third-party hacking or other causes.

Xelerate restricts access to any nonpublic personal data about you to those employees who need to know that information to provide services to the partnership and its investors.

Xelerate will typically maintain personal data so long as it can reasonably foresee such personal data may be required in connection with its relationship with you. Xelerate may retain personal data for a longer period as necessary to comply with any applicable legal or regulatory requirements and reasonable records retention policies or as otherwise necessary for a legitimate reason (such as to resolve disputes and enforce its agreements and contracts).

Use of Cookies

“Cookies” are small files used by websites to store information on your computer that provide technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our website. Cookies contain information that identifies you during a session and allows the software to function, to facilitate site navigation, and to personalize your experience. For the Services to work properly, your browser must be enabled to accept cookies. We may also use anonymous log file information to: (a) make the websites better, faster and more robust; (b) monitor statistics relating to the websites; and (c) police the websites and enforce the terms of use and any other guidelines for usage.

This information is also not for sale. We do not use cookies to pull data from your hard drive or view data in cookies created by other websites. Third parties may view, edit, or set their own cookies. The use of these technologies by third parties is subject to their own privacy policies and is not covered by this Privacy Policy, except as required by law.

As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser.

Data Access

You may access and correct personal data held by Xelerate, except where the burden of providing such access would be disproportionate to the risks to your privacy, or where the rights of other persons would be violated. You may also request erasure of your personal data in certain circumstances (and subject to any applicable legally required or permitted retention standards). To request access to, correction of, or erasure of personal data, you should contact Xelerate as set forth at the end of this Privacy Policy. In the case of a request to exercise one of the above listed rights, you may be required to submit a valid personal identification proof to Xelerate. Xelerate will deal with such requests in accordance with applicable law and process the request within the time provided by applicable law.

Children

Xelerate’ Website and services are not directed toward children under 13. If a parent or guardian becomes aware that his or her child has provided Xelerate with personal data, they should contact Xelerate as set forth at the end of this Privacy Policy and Xelerate will take reasonable steps to promptly remove such data from its systems (subject to any applicable, legally required or permitted, retention standards).

Cross-Border Transfers

Xelerate is based in the United States, and personal data collected by it and its affiliates worldwide (including within the EU and Switzerland) may be transferred to the United States for processing. By submitting personal data to Xelerate or its affiliates, you consent to the transmission of personal data to the United States. Xelerate is generally the “data controller” as that term is used under applicable data privacy laws. Xelerate may be liable in cases of onward transfers of personal data to third parties.

California Residents

California law entitles California residents to certain additional protections regarding personal data. For purposes of this section alone, “personal data” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. California residents have the right to request:

• information regarding their personal data Xelerate has collected (the categories of personal data collected, the source of such data, and how such data has been used);
• a description of whether Xelerate has disclosed their personal data to third parties, and if so what categories of data have been disclosed, and to what categories of third parties);
• a copy of their personal data collected by Xelerate in the past 12 months; and
• that their personal data be deleted.

To make such a request, California residents should contact Xelerate as set forth below. Xelerate may require verification of your identity before further processing the request. In certain instances, Xelerate may be required or permitted by law to decline some or all of such request.

Contact

Should you have any questions, comments or concerns about Xelerate’ privacy practices or wish to exercise any rights under this Privacy Policy, please contact info@xeleratellc.com.

Policy Updates

If we ever change the Privacy Policy, we will post that information on this Privacy Policy page. If there is ever any material change to how your information is used or to whom it is shared, we will notify you via the contact information we have in your personal profile. We invite you to come back from time to time to review the Privacy Policy.

This Privacy Policy was last updated on June 2, 2020.