Xclude Privacy Policy

At Xclude Inc (“Xclude”, “we,” “our,” or “us”), we prioritize your privacy and are committed to safeguarding any personal data shared with us through our Service. This privacy policy (“Privacy Policy”, “Policy”) outlines how we collect, use, disclose, and safeguard your information when you use our product and services.

For the purpose of this Policy,

“Personal Data” (“personal information”) means information about an identifiable individual but does not include aggregated information that cannot be associated with a specific individual

“Services” refers to our website which can be viewed or accessed at www.xclude.ai (“Website”), our product (“Xclude’s AI Worker” or “Xclude’s AI content moderators”) or any other services that we may supply to you which are further described in our Terms of Service.

This Privacy Policy applies to all customers of our Services worldwide, including residents of the European Economic Area (EEA) and California (under GDPR and CCPA, respectively).

This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage. Similarly, this Privacy Policy may not apply to the Personal Data that we process as a data processor or service provider on behalf of our customers in the course of providing our Services. We are not responsible for the privacy practices of our customers or other third parties, which may differ from those described in this Privacy Policy.

By accepting our Privacy Policy, you expressly consent to our collection, storage, processing, use and disclosure of your Personal Data as described in this Policy.

1. Who we are

Xclude offers a full-lifecycle deep learning artificial intelligence platform for computer vision, natural language processing and more. Our AI content moderator helps organizations to review user-generated content (“UGC”) and excludes any content featuring competitor products or mentions.

2. Personal Data we collect

When you provide Xclude with your Personal Data, you consent to us providing your data to any third parties that are necessary to offer, support and improve the Services. Xclude also collects Personal Data from you when you place an order including your name, physical address, email address. Xclude only uses this data for the purpose of fulfilling orders or communicating with you and Xclude’s partners regarding the Services.

2.1. When you visit our Website

You are free to explore our Website without providing any Personal Data about yourself. Xclude collects your Personal Data when you register and open an account with Xclude to help us operate and support the Services and to contact you in connection with your use of the Service.

2.2. When you use our Product

We use a third-party service provider, Amplitude, to track customer behavior within Xclude’s AI content moderator to improve the product and personalize communications. Data tracked includes:

• Message conversations with Xclude’s AI content moderator
• Events like button clicks, navigation, and time spent on specific sections

No personally identifiable information (PII) is pushed to Amplitude. Amplitude’s tracking focuses on interactions and usage patterns to enhance the user experience and ensure the product meets customer needs.

2.3. Information you provide

This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Data can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.

2.4. Payment information

We do not collect payment information directly. Payment information, such as credit card numbers and billing details, is collected and processed by our third-party PCI-compliant service provider, Stripe. Xclude does not store credit card details.

2.5. Account data

Username and password that you may set to establish an online account on the Services.

2.6. User-generated content data

Content submitted for analysis through Xclude’s AI content moderator, which may include:

• Images, videos, and text that could contain personal data such as identifiable individuals
• Metadata (e.g. timestamps, geolocation data, captions, hashtags) associated with the submitted content

Before analysis, identifiable elements (such as human faces) are automatically detected and masked to minimize privacy risks. Customers submitting UGC must ensure they have appropriate legal basis (e.g. consent) for providing such data to Xclude.

‍2.7. Communications data

Your interactions with us, including when you contact us through the Services, via email, chats, social media, or otherwise.

‍2.8. ‍Third-party sources

We may obtain personal information about you from other sources, such as government agencies, public records, social media platforms, and joint marketing partners.

‍2.9. Automatic data collection

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Services, our communications and other online services. The information collected automatically may be combined or associated with information collected from other sources. The information collected automatically may include:

• Device and online activity data

  This refers to information about your computer or mobile devices, and your visits to our Website and use of the Services such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. We use this information for the above purposes and to monitor and analyze use of the Services, for the Services’ technical administration, to increase our Services’ functionality and user-friendliness and to verify users have the authorization needed for the Services to process their requests.

• ‍Cookies

  Some of our automatic data collection is facilitated by cookies and similar technologies. You can manage or disable cookies and similar tracking technologies through your browser settings. However, please note that disabling cookies may impact your experience and limit certain functionalities of our Website or Services.

3. Use of Personal Data we collect

We may use your personal information for the following purposes or as otherwise described at the time of collection:

3.1. Service delivery and operations

We may use your Personal Data to provide, operate and improve the Services and our business; establish and maintain your user account on the Services; enable security features of the Services, such as by sending you security codes via email; communicate with you about the Services including by sending Service-related announcements, updates, security alerts, support and administrative messages; understand your needs and interests, and personalize your experience with the Services and our communications; and provide support for the Services, and respond to your requests, questions and feedback.

3.2. ‍Service improvement and analytics

We may use your Personal Data to analyze your usage of the Services, improve the Services, improve the rest of our business, help us understand user activity on the Services, as well as user interactions with our AI content moderator and emails, and to develop new products and services.

3.3. Marketing

We may collect and use your personal information for sending you marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications.

3.4. Internet based advertising

Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Services, our communications and other online services over time, and use that information to serve online ads that they think will interest you.

3.5. Compliance and protection

We may use your personal information to: comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities; protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); audit our internal processes for compliance with legal and contractual requirements or our internal policies; enforce the terms and conditions that govern the Services; and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

3.6. International transfer of Information

If you are located outside the United States, the information that we collect from you may be transferred to and stored and processed at a destination in the United States. By submitting information, you agree to this transfer, storing or processing. We will take all steps necessary to ensure that your information is treated securely and in accordance with this Privacy Policy. All our employees and contractors related to working with personal data as part of their duties are signed agreements that cover Xclude and their responsibility regarding the transfer of data to remote working locations other than the United States. This Privacy Policy shall apply even if we transfer Personal Data to other countries.

3.7. Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

3.8. To unsubscribe from our communications

You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, or by sending us an email at privacy@xclude.ai. Customers cannot opt-out of receiving transactional emails or notifications related to their account with us or the Xclude Services.

4. User-generated content data

4.1. Use of user-generated content data

We process publicly available UGC, submitted to Xclude’s AI content moderator via API or CSV upload by customer for the following purposes:

• Analysis and moderation

  Xclude uses AI algorithms to review UGC (images, videos, posts), identify competitor products and mentions within the content and filters them out.

• ‍AI model training

  When applicable, anonymized and aggregated UGC may be used to enhance the accuracy and efficiency of Xclude’s AI algorithms. This use is limited to non-identifiable data to ensure privacy compliance and safeguard individual rights.

4.2. Handling Personal Data in UGC

UGC submitted to Xclude’s AI content moderator may include Personal Data, such as identifiable faces, names, or other information embedded in the content. We take privacy and compliance with applicable data protection laws seriously. Here’s how we handle Personal Data in UGC:

• Anonymization and masking

  Xclude detects and automatically masks human faces in images and video frames before processing or storing the data. This ensures that identifiable information about individuals is anonymized as much as possible. Any personal data embedded in UGC is anonymized wherever feasible to reduce privacy risks and ensure compliance with privacy regulations.

• Storage and security

  UGC is temporarily downloaded and stored in private AWS S3 buckets, which are configured with encryption both at rest and in transit. After processing, including analysis and filtering by our AI models, all raw UGC is permanently deleted from our servers. Xclude does not retain raw UGC for long-term storage unless explicitly agreed upon with the customer.

• Role & obligations as our customer

  Xclude operates as a data processor for UGC submitted by customers. Customers act as data controllers and are responsible for ensuring compliance with applicable data privacy laws (e.g., GDPR, CCPA). Customers must obtain the necessary consents or establish a legal basis for collecting personal data within the UGC they submit.

5. Revision of the Privacy Policy

Xclude reserves the right to revise, modify or update this Policy at any time. Your continued use of the Services after any such revisions, modifications or updates constitutes your acceptance of any such change. If we make any material changes we will notify you by posting the revised Privacy Policy on our Website or conspicuously in the Services.

6. Contact us

Email:  privacy@xclude.ai

Mail:  390 NE 191st St, STE 8610, Miami, FL 33179, United States