JUST EXCELERATE LLC

PRIVACY POLICY
Last updated: July 6, 2022

1. Introduction

JustExcelerate LLC (“JustExcelerate”, “we”, “us”, “our”) respects the privacy of its Users (“User,” “your,” or “you”).

Your privacy is important to us.

This Privacy Policy (the “Privacy Policy”) explains how we collect, use, disclose, and safeguard your information when you use our website at www.excelerate.it, and any other sites owned and operated by JustExcelerate LLC, that redirect to www.excelerate.it and all its subdomains, portal sites (collectively, “Website” or “Service”), and any of its related information, resources, tools, products, and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing personal information (also referred to as personally identifiable information or “PII”) It also describes the choices available to you regarding our use of your Personal Information and how you can access and update it. The capitalized terms have the same meaning as ascribed in our Terms of Service, unless otherwise noted here.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY
ACCESSING OR USING OUR WEBSITE, YOU AGREE TO ACCEPT ALL THE TERMS CONTAINED IN THIS PRIVACY POLICY AND ACKNOWLEDGE AND AGREE WITH THE
PRACTICES DESCRIBED HEREIN. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE OUR WEBSITE.

If you are entering into this agreement on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this agreement, in which case the terms “User”, “you” or“your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this agreement, you must not accept this agreement and may not access and use the Website and Services.

JustExcelerate LLC offers a platform to connect accomplished business leaders with the founders of B2B startups. Portfolio startups also get experienced advice and sales coaching from some of the stalwarts from industry.

WE DO NOT SELL PERSONAL INFORMATION OR PII, AS DEFINED BELOW.

2. What Information do we collect?

Personal Information

You can access and use the Website and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered on the Website, you may be asked to provide certain Personal Information (for example, your name and e-mail address). The capitalized terms have the same meaning as ascribed in our Terms of Service, unless otherwise noted here.

We receive and store any information you knowingly provide to us when you create an account or fill any online forms on the Website. When required, this information may include the following:.8

  • Contact information (such as email address, phone number, etc.)

  • Account details (such as username, password, etc.)

  • Basic personal information (such as name, country of residence, etc.)

  • Proof of identity (such as a photocopy of a government ID)

  • e. Any other material you willingly submit to us (such as articles, images, feedback, etc.)

Some of the information we collect is directly from you via the Website and Services. However, we may also collect Personal Information about you from other sources such as public databases, social media platforms, third-party data providers, and our joint marketing partners. Personal Information we collect from other sources may include demographic information, such as age and gender, device information, such as IP addresses, location, such as city and state, and online behavioural data, such as information about your use of social media websites, page view information and search results and links.

You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features on the Website. Users who are uncertain about what information is mandatory are welcome to contact us. Users are able to change their personal
information via email by contacting us at [Privacy Email]

3. How do we collect information?

We collect personal information from you in the following ways:

a. At registration on our Website;
b. In email, text, and other electronic messages between User and our Website;
c. When User interacts with our advertising and applications on third-party website and services, if those applications or advertising include a link to this Privacy Policy;
d. From User’s responses to a survey;
e. From forms filled out by User;
f. From records or copies of correspondences (including email addresses) if User contacts us;
g. From search queries on our Website; and


We collect information from you automatically when you navigate through our Website in the following ways:
a. Usage details;
b. IP addresses;
c. Information obtained through browser cookies; and
d. Other tracking technologies.

Depending on your location, data transfers may involve transferring and storing your information in a country other than your own.


If you are a resident of the European Economic Area (“EEA”) or the United Kingdom (“UK”) and your data is transferred outside of either region, we ensure at least one of the following safeguards is implemented:

4. How do we use your information?

We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate businessinterests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations.

 

We indicate the specific processing grounds we rely on next to each purpose listed below. Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Website and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular User of the system.

 

We use the information that you provide to:

a. To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.

b. Request feedback. We may use your information to request feedback and to contact you about your use of our Website.

c. To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

d. To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).

e. To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with  our contract.

f. To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

g. To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.

h. To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

i. To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time.

j. Send User periodic emails, in accordance with the CAN-SPAM Act of 2003 as detailed in Section 12, via the email address provided by User to (i) send information, respond to inquiries, and/or other requests or questions; (ii) process orders and send information and updates pertaining to such orders; (iii) send additional information related to User’s product and/or service; and (iv) market to our mailing list or continue to send email to User after the original transaction has occurred.

5. Our cookie policy

Our Website and Services use “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.


We may use cookies to collect, store, and track information for security and personalisation, and for statistical purposes. Please note that you have the ability to accept or decline cookies. Most web browsers automatically accept cookies by default, but you can modify your browser settings to decline cookies if you prefer.

6. How do we protect information we collect ?

Managing Collected Data:

You will be able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Website and Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners, and for the purposes described below. If you would like to delete your Personal Information or permanently delete your account, you can do so on the settings page of your account on the Website or Services or simply by contacting us.

Information Security:

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.

Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

As the security of Personal Information depends in part on the security of the device you use to communicate with us and the security you use to protect your credentials, please take appropriate measures to protect this information.

In the event we become aware that the security of the Website and Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice

7. Discloser of Personation Information

Information Disclosure:

We may share your information with our affiliates, contracted companies, and service providers (collectively, “Service Providers”) we rely upon to assist in the operation of the Website and Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. We will not share any personally identifiable information with third parties and will not share any information with unaffiliated third parties.

Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorize them to use or disclose any of the provided information for their own marketing or other purposes.

We may also disclose any Personal Information we collect, use, or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Information Retention:

We will retain and use your Personal Information for the period necessary to enforce our agreements, resolve disputes, and unless a longer retention period is required or permitted by law up to a maximum of 72 months.

We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and

Information Transeferring:

Depending on your location, data transfers may involve transferring and storing your information in a country other than your own.

If you are a resident of the European Economic Area (“EEA”) or the United Kingdom (“UK”) and your data is transferred outside of either region, we ensure at least one of the following safeguards is implemented:

a. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and UK adequacy regulations. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries or adequacy decisions for the UK.

b. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe, including the UK. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

c. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

8. For our European Customers and Visitors

Data Protection Rights Under the GDPR:

If you are a resident of the European Economic Area (“EEA”) or the United Kingdom (“UK”), you have certain data protection rights and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. You also have the right to complain to your local data protection supervisory authority. You can find their contact details here:

https://ec.europa.eu/justice/data- protection/bodies/authorities/index_en.htm. We are headquartered in the United States. Most of the operations are located in the United States. Your Personal Information, which you give to us during use of our Website, may be accessed by or transferred to us in the United States. If you are visiting our Website, be aware that your Personal Information may be transferred to, stored, and processed in the United States. Our servers or our third-party hosting services partners are located in the United States. By using our site, you consent to any transfer of your Personal Information out of Europe, UK, or Switzerland for processing in the US or other countries.

If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:

a. You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information. To the extent that the legal basis for our processing of your Personal Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

b. You have the right to learn if your Personal Information is being processed by us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of your Personal Information undergoing processing.

 

c. You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You also have the right to request us to complete the Personal Information you believe is incomplete.

d. You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent. Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us, or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection. You must know that, however, should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn whether we are processing Personal Information for direct marketing purposes, you may refer to the relevant sections of this Policy.

e. You have the right, under certain circumstances, to restrict the processing of your Personal Information. These circumstances include: the accuracy of your Personal Information is contested by you and we must verify its accuracy; the processing is unlawful, but you oppose the erasure of your Personal Information and request the restriction of its use instead; we no longer need your Personal Information for the purposes of processing, but you require it to establish, exercise or defend your legal claims; you have objected to processing pending the verification of whether our legitimate grounds override your legitimate grounds. Where processing has been restricted, such Personal Information will be marked accordingly and, with the exception of storage, will be processed only with your consent or for the establishment, to exercise or defence of legal claims, for the protection of the rights of another natural, or legal person or for reasons of important public interest.

f. You have the right, under certain circumstances, to obtain the erasure of your Personal Information from us. These circumstances include: the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure such as where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, to exercise or defence of legal claims.

g. You have the right to receive your Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance from us, provided that such transmission does not adversely affect the rights and freedoms of others.
 

h. You have the right to complain to a data protection authority about our collection and use of your Personal Information. If you are not satisfied with the outcome of your complaint directly with us, you have the right to lodge a complaint with your local data protection authority. For more information, please contact your local data protection authority in the EEA or UK. This provision is applicable provided that your Personal Information is processed by automated means and that the processing is based on your consent, on a contract which you are part of, or on pre-contractual obligations thereof.

9. Your California Policy Rights

Consumers residing in California are afforded certain additional rights with respect to their Personal Information under the California Consumer Privacy Act (“CCPA”). If you are a California resident, this section applies to you.

In addition to the rights as explained in this Policy, California residents who provide Personal Information as defined in the statute to obtain Services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the categories and specific pieces of Personal Information we have collected and disclosed.

Furthermore, California residents have the right to request deletion of their Personal Information or opt-out of the sale of their Personal Information which may include selling, disclosing, or transferring Personal Information to another business or a third party for monetary or other valuable consideration. To do so, simply contact us. We will not discriminate against you if you exercise your rights under the CCPA.

Excelerate does not sell, trade, or otherwise transfer to outside third parties your “Personal Information” as the term is defined under the California Civil Code Section § 1798.82(h). Additionally, California Civil Code Section § 1798.83 permits Users of our Website or Platform that are California residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. To make a request for such disclosure, or identification and/or deletion of Personal Information in all our systems that we store on you, please send an email to [Privacy Email] or write us at JustExcelerate LLC., 1915, Broadway Burlingame, CA 94010, USA

Note that (i) if we delete your Personal Information as requested, we will no longer be able to provide our services to you and (ii) we may need to keep such Personal Information for a while during the shutting down and billing process. If you would like to discuss our Personal Information storage and processing process with us, please send us an email at [Privacy Email] or write us at JustExcelerate LLC, 1915, Broadway, Burlingame, CA 94010, USA.

10. Advertisements and Social Media

We may permit certain third-party companies to help us tailor advertising that we think may be of interest to Users and to collect and use other data about User activities on the Website. These companies may deliver ads that might place cookies and otherwise track User behaviour.

Our Website and Services may include social media features, such as the Facebook, Twitter, LinkedIn, Share These buttons, etc. (collectively, “Social Media Features”). These Social Media Features may collect your IP address, what page you are visiting on our Website and Services and may set a cookie to enable Social Media Features to function properly. Social Media Features are hosted either by their respective providers or directly on our Website and Services. Your interactions with these Social Media Features are governed by the privacy policy of their respective providers.

11. Can-Spam Act of 2003

We may offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third-party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.

The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will:

a. not use false or misleading subjects or email addresses;

b. identify the email message as an advertisement in some reasonable way;

c. include the physical address of JustExcelerate LLC, which is 1915 Broadway, Burlingame, CA 94010, USA.

d. monitor third-party email marketing services for compliance, if one is used;

e. honor opt-out/unsubscribe requests quickly; and

f. give an “opt-out” or “unsubscribe” option.

If you wish to opt out of email marketing, follow the instructions at the bottom of each email or contact us at [Privacy Email] and we will promptly remove you from all future marketing correspondences

Links to other Websites and resourses. :

 

The Website and Services may contain links to other resources that are not owned or controlled by us.
Please be aware that we are not responsible for the privacy practices of such other resources or third
parties. We encourage you to be aware when you leave the Website and Services and to read the
privacy statements of each and every resource that may collect Personal Information.

12. Privacy of Children

We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Website and Services. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Website and Services, please contact us to request that we delete that child’s Personal Information from our Services immediately.

We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through then Website and Services without their permission.

13. Modification of our Privacy Policy

We reserve the right to modify this Policy, or its terms related to the Website and Services at any time at our discretion. When we do, we will revise the updated date on this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.

An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.

14. List of Other Party Service Providers

Excelerate uses the following third-party service providers for the provision of services as detailed under the Terms of Service.

Accepting this Policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.

15. Contact Us:

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

-  Privacy Officer
-  Email:  info@excelerate.it

-  Address: 1915 Broadway, Burlingame, CA 94010, USA

PLEASE NOTE: IF YOU USE OUR WEBSITE, YOU HAVE AGREED TO AND ACCEPTED THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF SERVICE . IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, PLEASE DO NOT USE OUR WEBSITE.

We will attempt to resolve complaints and disputes and make every reasonable effort to honour your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by applicable data protection laws.

Exercise Your Rights:

Any requests to exercise your rights can be directed to:

 Email Address: 

info@excelerate.it

Postal Address:

1915 Broadway
Burlingame, CA 94010
USA

Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. If we receive your request from an authorized representative, we may request evidence that you have provided such an authorized representative with power of attorney or that the authorized representative otherwise has valid written authority to submit requests on your behalf.

You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.

WE DO NOT SELL, LICENSE, OR OTHERWISE TRANSFER YOUR PERSONAL INFORMATION OR PII TO THIRD PARTIES.