• Business Name: XELL LLC
• EIN: 99-3719920
• Address: 14311 SW 90TH TER, Miami, FL 33186, USA
• Email: support@xell.shop
• Contact Phone: +57 320 985 4135

• Authorization: The prior, explicit, and informed consent granted by each Data Subject for the Processing of their Personal Data.

• Personal Data: Any information linked or that can be associated with one or more identifiable individuals.

• Sensitive Data: Data that affects the privacy of the Data Subject or whose misuse could result in discrimination, such as racial origin, religious beliefs, and biometric data.

• Data Subject: The individual whose Personal Data is being processed.

• Processing: Any operation performed on Personal Data, such as collection, storage, use, sharing, or deletion.

XELL commits to complying with the provisions outlined in the following U.S. laws and regulations:

• The Fair Credit Reporting Act (FCRA)
• The Gramm-Leach-Bliley Act (GLBA)
• Federal Trade Commission (FTC) Act

These guidelines are supplemented by any additional state or federal regulations that may apply.

XELL may collect Personal Data through various channels, including:

• Registrations on our applications and websites: Information provided by users during account creation or service sign-up.
• Social media, emails, and phone lines: Data shared through interactions on digital platforms or customer service communications.
• Physical or virtual forms: Information provided by individuals when contracting our services or purchasing our products.
• Visits to our offices: Data collected for access control and security purposes.

This ensures we gather the necessary information to deliver an efficient and personalized service experience.

We collect various types of Personal Data from:

• Customers: Name, identification, contact details, financial information, and transactions made through our platform.
• Suppliers and Partners: Name, identification, financial, and commercial information.
• Employees and Contractors: Identification details, contact information, academic background, and employment history.
• Visitors: Identification details and the purpose of the visit.

This information helps us maintain efficient operations and provide tailored services to our stakeholders.

XELL may collect and process Sensitive Data under the following circumstances:

• The individual has provided explicit consent.
• It is necessary to safeguard the vital interests of the individual, and they are physically or legally unable to provide consent.
• It is required for the recognition, exercise, or defense of a legal right in a judicial proceeding.
• The processing is related to a matter of public interest and complies with applicable regulations.

In all cases, the provision of Sensitive Data is voluntary, except when it is essential for the fulfillment of a contracted service.

The collected Personal Data will be used for the following purposes:

• Managing Contractual Relationships: Establishing and managing contractual relationships with our customers, suppliers, and employees.
• Provision of Services: Processing payments, managing product and service requests, and enhancing the quality of our services.
• Regulatory Compliance: Preventing money laundering, terrorism financing, and other illegal activities in compliance with applicable regulations.
• Customer Service and Promotion: Contacting individuals for information about products, services, promotions, and improving the overall experience.
• Legal Inquiries and Requirements: Responding to inquiries from authorities and fulfilling legal obligations.

For the development of its corporate purpose, XELL may Transfer or Transmit Personal Data to third parties, both nationally and internationally, under strict security measures to ensure the protection of the rights of the Data Subject. Transfers will be made only when necessary to fulfill the purposes described and in accordance with current regulations.

The holders of Personal Data have the right to:

• Know, update, and rectify their Personal Data.
• Revoke the Authorization and request the deletion of their Personal Data when they believe XELL does not comply with the principles, rights, and guarantees established by the applicable regulations.
• Request proof of the Authorization.
• Access their Personal Data that has been processed by XELL, free of charge.

XELL provides the following channels for holders to exercise their rights:

• Email: soporte@xell.com
• Phone: +57 305 1234567
• Offices: 14311 SW 90th Ter, Miami, FL 33186, USA

Holders may submit inquiries and complaints regarding the use of their Personal Data. Inquiries will be resolved within 10 business days, and complaints will be addressed within 15 business days. If additional time is required, the holder will be notified of the reasons for the delay.

XELL implements an Information Security Management System that includes administrative, technical, and technological measures to ensure the integrity, confidentiality, and availability of Personal Data. Some of these measures include:

• Data encryption both in transit and at rest.
• Multi-factor authentication (MFA) for access to critical systems.
• Periodic audits to assess the security of our platforms.
• Security training for our employees on best practices for data protection.

Any substantial modifications to this policy will be communicated to the holders through our official channels and on our website: www.xell.shop. The changes will take effect 15 days after their publication.

This Data Processing Policy is effective as of October 25, 2024.