XCLSV

1. Introduction

This Privacy Policy (“Policy”) describes how Maiden Labs LLC, a Wyoming limited liability company (“Company,” “XCLSV,” “we,” “us,” “our”), collects, uses, stores, shares, and protects your personal information when you access or use the XCLSV premium concierge platform, including all related services, applications, websites (including xclsv.com), application programming interfaces, messaging integrations, voice services, and any other software or services offered by the Company (collectively, the “Service”).

BY REGISTERING FOR AN ACCOUNT, ACCESSING, OR USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO THE COLLECTION, USE, STORAGE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS POLICY. IF YOU DO NOT AGREE WITH THIS POLICY, YOU MUST NOT ACCESS OR USE THE SERVICE.

This Policy is incorporated by reference into our Terms of Service (available at xclsv.com/terms). We may update this Policy from time to time. We will provide you with notice of material changes at least fourteen (14) days prior to the effective date by sending a notification via SMS or WhatsApp. The “Last Updated” date at the top indicates when it was most recently revised.

2. Information We Collect

2.1 Information You Provide Directly

When you register for and use the Service, we collect information that you voluntarily provide, including: your mobile phone number, first name, username, and country of residence (Account Registration Information); the full content of all text messages (SMS and WhatsApp) you send to and receive from the Service, including any images, documents, files, links, or other media (Communications Content); recordings and transcriptions of voice calls placed through or by the Service (Voice Interactions); any documents, images, receipts, or files you upload or share with the Service (Documents and Files); billing details including payment method and transaction history, with full payment card details collected directly by Stripe, Inc. (Payment Information); any correspondence for customer support or feedback (Customer Support Communications); and any preferences, dietary restrictions, favorite locations, or personalization data you communicate (Preferences and Settings).

2.2 Information Collected Automatically

When you access the Service, we automatically collect: device type, operating system and version, browser type, screen resolution, and device identifiers (Device and Browser Information); IP address, access timestamps, pages visited, interaction patterns, session duration, and frequency of use (Log and Usage Data); approximate geographic location inferred from your IP address or phone number country code — we do not collect precise GPS data unless you explicitly share your location (Location Data); and essential cookies and similar technologies for session management, security, and basic functionality (Cookies).

2.3 Information from Third Parties

We may receive information from: Meta Platforms, Inc. (WhatsApp) and telecommunications carriers regarding message delivery and metadata; Stripe, Inc. regarding transaction confirmations and fraud detection; and third-party businesses that provide confirmation details when the Service interacts with them on your behalf.

2.4 Derived and Inferred Information

Through your use of the Service, we may derive or infer additional information, including accumulated knowledge from your conversation history (preferences, habits, interests, frequently visited locations, and recurring requests) used to provide personalized responses, and aggregated usage analytics including message volume, active hours, and common request types.

3. How We Use Your Information

3.1 Providing and Operating the Service

Processing and responding to your concierge requests; maintaining conversation history for contextual, personalized responses; facilitating bookings, reservations, and outbound calls; storing and retrieving documents; sending reminders and notifications; and delivering the core messaging and voice functionality.

3.2 Account Management

Creating and managing your account; verifying your identity and phone number; processing payments and managing billing; enforcing usage limits; and providing customer support.

3.3 Service Improvement and Development

Analyzing usage patterns to improve quality, accuracy, and reliability; developing new features; training and improving AI systems using anonymized and aggregated data; conducting internal research; and monitoring performance, stability, and security.

3.4 Communications

Sending service-related messages including booking confirmations, reminders, and account notifications; billing alerts and payment confirmations; security alerts; and information about new features and enhancements (subject to your opt-out preferences).

3.5 Safety, Security, and Compliance

Detecting, preventing, and addressing fraud, abuse, security incidents, and technical issues; enforcing our Terms of Service; protecting the rights, property, and safety of the Company, our users, and the public; complying with applicable laws, regulations, and legal processes; and responding to lawful requests from law enforcement.

3.6 Legal Basis for Processing

Where required by applicable law (including the EU GDPR), we process your information based on: (a) Performance of a Contract — processing necessary to provide the Service; (b) Consent — for marketing communications and sensitive data; (c) Legitimate Interests — improving the Service, preventing fraud, and ensuring security; and (d) Legal Obligation — compliance with applicable laws.

4. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

4.1 Service Providers and Processors

We engage trusted third-party companies to perform services on our behalf. These providers have access to your information only as necessary and are contractually obligated to maintain confidentiality. Key providers include: Anthropic, PBC (Claude AI models process your messages — inputs and outputs are not used to train Anthropic's models); Meta Platforms, Inc. (WhatsApp message delivery); Twilio, Inc. (SMS delivery); Vapi, Inc. (voice call processing); Stripe, Inc. (payment processing); Vercel, Inc. and Supabase, Inc. (cloud infrastructure).

4.2 Third-Party Services at Your Request

When you request the Service to interact with third parties on your behalf (e.g., making a restaurant reservation), we share relevant information with those third parties as necessary, which may include your name, phone number, party size, date, time, and other pertinent details. You authorize such sharing when you make the request.

4.3 Legal and Safety Disclosures

We may disclose your information if we believe in good faith that disclosure is necessary to: comply with applicable law, regulation, or legal process; enforce our Terms of Service; protect the rights, property, or safety of the Company, our users, or the public; detect, prevent, or address fraud, security, or technical issues; or respond to an emergency involving danger of death or serious physical injury.

4.4 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your personal information may be among the assets transferred. We will notify you of any change in ownership or control of your personal information.

4.5 Aggregated and De-Identified Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you with third parties for research, analytics, or other lawful purposes.

5. Data Retention

5.1 Retention Periods

Account Information: retained for the duration of your active subscription and for ninety (90) days following cancellation to allow reactivation. Conversation History: retained for the duration of your subscription; deleted ninety (90) days after termination. Voice Call Recordings: retained for a maximum of one hundred eighty (180) days for quality assurance and dispute resolution. Payment and Transaction Records: retained for seven (7) years as required by tax and financial regulations. Usage and Analytics Data: retained in anonymized or aggregated form indefinitely. Legal Hold Data: retained beyond standard periods if subject to litigation hold or legal proceeding.

5.2 Deletion

Upon expiration of the applicable retention period, your personal information will be securely deleted or anonymized using industry-standard methods. You may request earlier deletion as described in Section 7.

6. Data Security

6.1 Security Measures

We implement reasonable administrative, technical, and physical security measures, including: encryption in transit (TLS/SSL) and at rest (AES-256); role-based access controls, multi-factor authentication, and least-privilege principles; SOC 2 Type II certified cloud infrastructure with network segmentation, firewalls, and intrusion detection; regular security reviews, vulnerability assessments, and code audits; API authentication tokens and rate limiting; and an incident response plan with breach notification procedures as required by law.

6.2 Limitations

No method of electronic transmission or storage is 100% secure. We cannot guarantee the absolute security of your personal information. You transmit data to the Service at your own risk and are responsible for maintaining the security of your phone and account credentials.

7. Your Rights and Choices

7.1 Access and Portability

You have the right to request access to the personal information we hold about you. Upon a verifiable request, we will provide a copy in a structured, commonly used, machine-readable format within thirty (30) days.

7.2 Correction

You may request correction of any inaccurate or incomplete personal information. Update your first name and username through account settings, or contact support@xclsv.com for other corrections.

7.3 Deletion

You may request deletion of your personal information. We will process verifiable deletion requests within thirty (30) days, except where retention is necessary for completing a transaction, fraud prevention, legal compliance, or defending legal claims.

7.4 Opt-Out of Communications

Text “STOP” to opt out of concierge messages at any time (this suspends core functionality). Text “START” to re-subscribe. Contact support@xclsv.com to opt out of promotional communications while continuing to receive service messages.

7.5 Do Not Track

Our website does not respond to “Do Not Track” browser signals. However, we do not engage in cross-site tracking or targeted advertising.

7.6 How to Exercise Your Rights

Contact support@xclsv.com or text “HELP” to our service number. We may require identity verification via phone number confirmation. We will respond within thirty (30) days.

8. SMS and WhatsApp Communications

8.1 Consent

By providing your phone number and using the Service, you expressly consent to receive recurring automated text messages (SMS and MMS) and WhatsApp messages from XCLSV, in compliance with the Telephone Consumer Protection Act (“TCPA”), 47 U.S.C. § 227, and all applicable state and federal regulations.

8.2 Types of Messages

Messages include concierge responses, booking confirmations, scheduled reminders, account notifications (billing, security, subscription changes), service announcements, and verification codes.

8.3 Message Frequency

Message frequency varies and is not fixed. You may receive multiple messages per day during periods of active use, depending on your requests, active reminders, and pending bookings.

8.4 Costs

Standard message and data rates from your wireless carrier may apply. The Company is not responsible for any carrier charges. International messaging fees may apply if outside your carrier's coverage area.

8.5 Opting Out

Message “STOP” to +1 (646) 504-9218 on WhatsApp at any time. Message “START” to resume. Message “HELP” or email support@xclsv.com for assistance.

8.6 Supported Carriers

The Service is designed to work with all major U.S. wireless carriers. Compatibility with all carriers or regions is not guaranteed.

9. Cookies and Tracking Technologies

Our website uses essential cookies (strictly necessary for session management, authentication, and security) and functional cookies (to remember preferences and settings). We do not use third-party advertising cookies, retargeting pixels, or cross-site tracking. We may use privacy-focused analytics tools to collect anonymized website usage data for improvement purposes only. Most browsers allow you to manage cookies through their settings; disabling essential cookies may impair website functionality.

10. Children's Privacy

The Service is not intended for individuals under eighteen (18) years of age or the age of majority in their jurisdiction, whichever is greater. We do not knowingly collect personal information from minors. If we become aware that we have collected such information, we will promptly delete it. Contact support@xclsv.com if you believe a minor has provided us with personal information.

11. State-Specific Privacy Rights

11.1 California Residents (CCPA/CPRA)

California residents have the right to: know what personal information we collect and how it is used (Right to Know); request deletion of personal information (Right to Delete); request correction of inaccurate information (Right to Correct); opt out of the sale or sharing of personal information — we do not sell or share personal information for cross-context behavioral advertising (Right to Opt Out); and not be discriminated against for exercising privacy rights (Right to Non-Discrimination).

Categories of personal information collected in the preceding twelve (12) months include: Identifiers (phone number, username, IP address); personal information under Cal. Civ. Code § 1798.80(e) (name, phone number); commercial information (subscription and transaction records); internet or electronic network activity (website usage data, interaction logs); geolocation data (approximate location from IP address); audio/electronic/visual information (voice recordings, images shared via messaging); and inferences drawn from the above. To exercise CCPA/CPRA rights, contact support@xclsv.com. We will respond within forty-five (45) days.

11.2 Other State Residents

Residents of Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy laws may have additional rights including the right to access, correct, delete, and obtain a copy of personal data; opt out of processing for targeted advertising, profiling, or sale (we do not engage in these activities); and appeal a denial of a privacy rights request by contacting support@xclsv.com.

12. International Data Transfers

The Service is operated from the United States. If you access the Service from outside the United States, including the European Economic Area, United Kingdom, Switzerland, Canada, or other regions with data protection laws, your personal information will be transferred to, stored in, and processed in the United States, where data protection laws may differ from those in your jurisdiction. By using the Service, you consent to such transfer. Where required by law, we will implement appropriate safeguards including Standard Contractual Clauses or other legally recognized transfer mechanisms.

13. Third-Party Links and Services

The Service may contain links to or facilitate interactions with third-party websites, applications, or services not owned or controlled by the Company. This Policy does not apply to the privacy practices of such third parties. We encourage you to review their privacy policies. The Company is not responsible for the content, privacy practices, or data collection policies of any third-party services.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated at least fourteen (14) days prior to the effective date via SMS or WhatsApp. Your continued use of the Service after the effective date constitutes acceptance of the revised Policy.

15. Contact Information

Maiden Labs LLC, State of Wyoming. Email: support@xclsv.com. WhatsApp: +1 (646) 504-9218. For data protection inquiries in the European Economic Area, you may also contact the supervisory authority in your country of residence.

By using XCLSV, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your personal information as described in this Privacy Policy.