1. Our Approach to Privacy

1.1. We at Xelera (“Xelera”,“We”, and/or “Us”) are committed to protecting the privacy of visitors to Our website and/or the users of our Services (as this term is defined in the Client’s T&Cs)(“You” and the “Users”, respectively).
1.2.This privacy policy (the “Privacy Policy”) sets forth the nature of the information We collect, and how We collect, store, process, transfer, share and use such information, as well as how We communicate with the Users and how You can withdraw Your consent for collection of personal information, delete and change such information.

1.3. Xelera is managing an international network of business professionals that provide Users with access to knowledge, contacts and skills required to help the Users develop their businesses and/or projects (the “Service”).
1.4.This Privacy Policy applies to visits on Our website and to any use of the Service. 1.5. Xelera is the Data Controller (as this term is defined in the EU GDPR) of the personal information We hold about You.

2.The Type of Information We Collect on You

2.1. We collect personal information voluntarily provided by You and/or automatically

collected indirectly through visiting Our website.

2.2.The types of personal information We are collecting includes (1) voluntary

information mandatory for registering to Our website (details on the type of such

information, its uses by Us and the recipients of such information are provided in

appendix 1); (2) voluntary information provided by You through the project onboarding form (details on the type of such information, its uses by Us and the

recipients of such information are provided in appendix 2); and (3) automatic information collected indirectly through visiting Our website (details on the type of such information, its uses by Us and the recipients of such information are provided in appendix 3).

2.3. We may combine the personal information We collect about You and the information We collect automatically in order to provide you with better personalized Service.
2.4. We may anonymise and aggregate any of the personal information We collect (so that it does not directly identify You). We may use anonymised information for purposes that include providing the services, testing our IT systems, research,

data analysis, improving our Service and developing new products and features. We may also share such anonymised information with others.
2.5. We will store the information We collect about You for no longer than necessary for the purposes set forth in appendices 1, 2 and 3 and in accordance with Our legal obligations and legitimate business interest.

2.6. We will use Your personal information in order to contact You, facilitate Your connection with relevant members of Our Network, provide You with relevant documents, and receive Our Service fees.
2.7.The lawful basis for processing Your personal information is to deliver Our Service which is of contractual nature.

3. How We Collect the Information

We collect Your personal information in the following ways:

3.1. When You fill in any of the forms on the Get In Touch page on Our website.

3.2. When You send Us an email with an inquiry to Our contact address.

3.3. By using cookies of certain kinds, as further described in section __ herein.

4. Recipients of Personal Information

4.1. In addition to the recipients listed in Annex 1, Annex 2 and Annex 3, We may

also share Your personal information with the following (as required in

accordance with the uses set forth in Annex 1, Annex 2 and Annex 3).

4.1.1. Members of the Network: We may share Your personal information with

members of Our Network (as this term is defined on Our Users’T&Cs) for

the provision of the Service and for any other purpose relating thereto.

4.1.2. Service Providers and Advisors: We may share Your personal

information with third party vendors and other service providers, that

perform services for Us or on Our behalf, which may include providing

mailing, email or chat services, fraud prevention, web hosting, web

programing, data storing, system networking or providing analytic

services.

4.1.3. Purchasers and third parties in connection with a business

transaction:Your personal information may be disclosed to third parties

in connection with a business transaction such as a meger, sale of assets

or shares, reorganisation, financing, change of control or acquisition, of all

or a portion of Our business.

4.1.4. Law enforcement, regulators and other parties for legal reasons: We

may share Your personal information with third parties as required by law

or if We reasonably believe that such action is necessary to (i) comply

with the law and reasonable requests of law enforcement; (ii) detect and

investigate illegal activities and breaches of agreements, including Our

terms of use; and/or (iii) exercise or protect the rights, property or

personal safety of Xelera, the Users or others.

5. Information Storage, Usage and Transfer

5.1. Our company is hosted on the Wix.com platform. Wix.com provides Us with the

online platform that allows Us to sell the Service to You.Your data may be stored

through Wix.com’s data storage, databases and the general Wix.com

applications.They store Your data on secure servers behind a firewall.

5.2. We may also store Your personal information on commercial cloud drivers such

as Google Docs, Dropbox and the likes. We always use vetted and reliable

service providers and will use Our best efforts to keep Your information safe, and

in anyway, would use the same level of security We use to keep Our personal

and confidential information safe.

5.3. All direct payment gateways offered by Wix.com and used by Our company

adhere to the standards set by PCI-DSS as managed by the PCI Security

Standards Council, which is a joint effort of brands like Visa, MasterCard,

American Express and Discover. PCI-DSS requirements help ensure the secure

handling of credit card information by Xelera and its service providers.

5.4.The personal information We collect may be transferred to and stored in

countries outside of Your jurisdiction, where We and our third party service

providers have operations. If You are located in the European Union (“EU”),Your

personal information may be processed outside of the EU including in the United

States; these international transfers of Your personal information will be made

pursuant to appropriate safeguards, such as standard data protection clauses

adopted by the European Commission. If You wish to enquire further about these

safeguards used, please contact Us at contact@joinxelera.com.

6. How We Communicate with Our Users and Site Visitors

6.1. We will, from time to time, communicate with You through Email correspondence,

text messages, video calls, and phone calls).

6.2. We will mainly contact You as part of Our service and in order to provide such

Service. Please note that sharing Your personal information (and contact details

specifically) is crucial for providing the Service.Therefore, a request to refrain

from using Your contact details by Us or by members of Our Network during a

Project (as this term is defined in the Users’T&Cs) will be considered as a

request to terminate the Project and will be subject to all relevant terms and

conditions.

6.3. We may contact You to notify You regarding Your Xelera account, to

troubleshoot problems with Your account, to resolve a dispute, to collect fees or

monies owed, to poll Your opinions through surveys or questionnaires, to send

updates about Our company, or as otherwise necessary to contact You to

enforce Our terms of use, applicable national laws, and any agreement We may

have with You. For these purposes We may contact You via email, telephone,

text messages, and postal mail.

6.4. From time to time We may contact You with information about Our Service by

email.

6.5. We will only send You marketing messages if You have given us Your consent to

do so. We will ask You if You would like to receive these messages when We

first collect your contact details.You can change Your preferences at a later date

by clicking on the unsubscribe link at the bottom of Our marketing messages.

6.6.You can ask Us at any time not to receive marketing anymore by sending an

email to Us at contact@joinxelera.com.

7.YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

7.1. In accordance with applicable privacy law, you have the following rights in

respect of your personal information that we hold:

7.1.1. Right of access.You have the right to obtain:

7.1.1.1. confirmation of whether, and where, We are processing Your

personal information;

7.1.1.2. information about the categories of personal information We are

processing, the purposes for which We process your personal

information and information as to how We determine applicable

retention periods;

7.1.1.3. information about the categories of recipients with whom We may

share Your personal information; and

7.1.1.4. a copy of the personal information We collect and store about

You.

7.1.2. Right of portability.You have the right, in certain circumstances, to

receive a copy of the personal information You have provided to us in a

structured, commonly used, machine-readable format that supports reuse, or to request the transfer of Your personal data to another person.

7.1.3. Right to rectification.You have the right to obtain rectification of any inaccurate or incomplete personal information We hold about You without undue delay.
7.1.4. Right to erasure.You have the right, in some circumstances, to require us to erase Your personal information without undue delay if the continued processing of that personal information is not justified.

7.1.5. Right to restriction.You have the right, in some circumstances, to require Us to limit the purposes for which we process Your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by You.

7.2. If you wish to exercise one of these rights, please contact us at:

contact@joinxelera.com.

7.3.You also have the right to lodge a complaint to your national data protection

authority. Further information about how to contact your local data protection

authority is available at http://ec.europa.eu/justice/dataprotection/bodies/authorities/ index_en.htm.

8. Cookies Usage and Other Tools

8.1. Our website is hosted in Wix.com platform (“Wix”). Wix uses cookies to provide better experience to You while visiting Our website, to identify Users registered to Our website, monitor and analyze the performance, operation and effectiveness of Wix platform, and to ensure the Wix platform is secure and safe for use.

8.2.You can find all the Cookies Wix places on its sites on

https://support.wix.com/en/article/cookies-and-your-wix-site.

8.3.The following links explain how to access cookie settings in various browsers:

8.3.1. Cookie settings in Firefox

8.3.2. Cookie settings in Internet Explorer

8.3.3. Cookie settings in Google Chrome

8.3.4. Cookie settings in Safari (OS X)

8.3.5. Cookie settings in Safari (iOS)

8.3.6. Cookie settings in Android

8.4. To opt out of being tracked by Google Analytics across all websites, visit this link:

http://tools.google.com/dlpage/gaoptout.

9. If you don’t want us to process your data anymore, please contact us at

contact@joinxelera.com.

10.We reserve the right to modify this Privacy Policy at any time subject to Our sole discretion. Please review this Privacy Policy frequently as changes and clarifications will take effect immediately upon their posting on Our website. In the event that We will make material changes to this Privacy Policy, We will notify You here that it has been updated.