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VEXLO

VEXLO LLC PRIVACY POLICY

Effective Date: October 2th 2026

Last Updated: October 2th 2026

Vexlo LLC, a Wyoming limited liability company (“Vexlo,” “we,” “us,” or “our”), operates an invitation-only membership community (the “Community”), together with the website located at vexlo.group, related digital properties, applications, in-person events, correspondence, and other services we provide (collectively, the “Services”). This Privacy Policy describes how Vexlo collects, uses, discloses, and safeguards personal information in connection with the Services, and describes the choices and rights available to individuals under applicable United States federal and state law.

Please read this Privacy Policy carefully. By visiting our website, submitting an inquiry, participating in our founding member or vetting process, requesting Vexlo The Art of Living, or becoming a member of Vexlo, you acknowledge that you have read and understood this Privacy Policy.

I. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information Vexlo collects and processes in connection with:

• Visitors to vexlo.group and any other website or application Vexlo operates;

• Individuals who submit an inquiry, request Vexlo The Art of Living, or otherwise contact Vexlo through the Services;

• Prospective members whom Vexlo identifies, researches, or is introduced to through referrals, warm introductions, or independent research, prior to any direct relationship between Vexlo and that individual (“Prospective Members”);

• Current members of the Community (“Members”) and their designated family or guest participants; and

• Sponsors, partners, vendors, and other individuals who interact with Vexlo in connection with the Services.

This Privacy Policy does not apply to information Vexlo maintains about its Manager, employees, or independent contractors solely in that capacity, which is addressed in Vexlo’s internal personnel policies, nor does it apply to third-party websites or services that Vexlo does not control, even where those third-party services are linked from or integrated with the Services.

II. DEFINITIONS

For purposes of this Privacy Policy, the following terms have the meanings set out below. Other capitalized terms used but not defined here have the meaning given to them elsewhere in this Privacy Policy.

• “Personal Information” means information that identifies, relates to, describes, or is reasonably capable of being associated with, a particular individual.

• “Sensitive Personal Information” means categories of Personal Information that receive heightened protection under applicable state law, including financial account information and precise geolocation.

• “Member” means an individual admitted to the Community as a paying subscriber under a Membership Agreement.

• “Prospective Member” means an individual whom Vexlo has identified, researched, or been introduced to as a potential candidate for membership, whether or not that individual has had direct contact with Vexlo.

• “Service Provider” means a third party that processes Personal Information on Vexlo’s behalf and under Vexlo’s instructions in order to perform services for Vexlo.

• “Sell” and “Share” have the meanings given to those terms under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, “CCPA”), and generally refer to disclosing Personal Information to a third party for monetary or other valuable consideration, or for cross-context behavioral advertising.

• “Services” means the Vexlo website, applications, events, communications, and membership offerings described in this Privacy Policy.

III. PERSONAL INFORMATION WE COLLECT

Vexlo collects Personal Information from and about individuals through several channels, described below. Because membership in Vexlo is invitation-only and Prospective Members are frequently identified before any direct relationship exists, some of the categories below describe information Vexlo may collect about an individual before that individual has contacted Vexlo directly.

3.1. Information You Provide Directly

• Registration and Inquiry Information: name, email address, mailing address, telephone number, and any information submitted through the “Make an Inquiry” form, the Vexlo The Art of Living signup, or other contact channels on the Services.

• Application and Vetting Information: date of birth or age confirmation, photograph, professional and business background, source and general nature of wealth, estimated net worth or wealth tier, business and career history, referral source or warm introduction details, professional references, and any information you or your representatives provide during founding member conversations, interviews, or the broader vetting process.

• Membership and Account Information: membership tier, Membership Agreement terms, member identification, membership fee payment and billing information, and renewal and status information.

• Event and Experience Information: RSVP and attendance information for Signature Events; travel preferences, itinerary details, and companion information for Exploration and Adventure experiences; documented interests, hobbies, and preferences used for Passion and Mastery curation and relationship management; philanthropic interests and giving preferences for Generosity and Impact programming; and your general interest in Vitality and Longevity programming. Vexlo does not collect health information, as described in Section IV.

• Legacy and Family Program Information: information about designated next-generation family participants who engage with Ambition and Legacy programming, provided by the Member or, where the participant is under the age of eighteen, by a parent or legal guardian.

• Communications: the content of messages, calls, and meeting notes exchanged between you and the Vexlo team, whether through email, the website, telephone, or in person.

• Payment Information: billing details necessary to process the membership fee or any additional-cost programming you elect to purchase, processed through our payment processors and financial institutions.

3.2. Information We Collect Automatically

When you visit vexlo.group, we and our service providers may automatically collect certain technical information through cookies and similar technologies, including your IP address, browser and device type, operating system, referring and exit pages, pages viewed, links clicked, and the date, time, and duration of your visit. Section VII (Cookies, Analytics, and Similar Technologies) describes this in more detail.

3.3. Information We Collect From Other Sources

• Referrals and Warm Introductions: when an existing Member or another individual refers or introduces a Prospective Member to Vexlo, we collect the name, relationship, and contact information of the person referred, along with any context the referring individual provides.

• Public and Professionally Available Sources: because Prospective Members are identified through direct research rather than open enrollment, Vexlo and its service providers may collect Personal Information about Prospective Members from publicly available sources such as news coverage, public filings, professional profiles, and social media, and through professional research, data-enrichment, and outreach-verification tools, before that individual has any direct relationship with Vexlo.

• Sponsors, Partners, and Service Providers: information about a Member’s engagement with a sponsor-provided experience, wellness provider, travel partner, or event partner, to the extent that partner shares it back with Vexlo for account administration, excluding any health information.

• Background, Reputational, and Sanctions Screening: given the profile of our membership, Vexlo may obtain information from background-check, sanctions-list (including U.S. Treasury OFAC and comparable lists), and reputational-screening providers regarding current or Prospective Members.

IV. SENSITIVE PERSONAL INFORMATION

Some of the information described in Section III may constitute Sensitive Personal Information under applicable state law, most notably financial account and net-worth information collected for vetting. Vexlo collects Sensitive Personal Information only where reasonably necessary for the purposes described in this Privacy Policy, uses it solely for those purposes, and does not use or disclose Sensitive Personal Information for purposes that require an opt-in or opt-out right under applicable state law beyond what is described here. Vexlo does not collect health or medical information. Vitality and Longevity programming is delivered by independent wellness partners, who collect any health information they need directly from the Member under their own privacy practices; that information is not shared with Vexlo. Participation in Vitality and Longevity programming is always voluntary. Please do not send health information to Vexlo.

V. HOW WE USE PERSONAL INFORMATION

Vexlo uses the Personal Information described above for the following purposes:

5.1.
To evaluate, vet, and, where appropriate, admit Prospective Members, including assessing eligibility against Vexlo’s membership criteria and conducting reputational, background, and sanctions screening.

5.2. To create, administer, and maintain a Member’s account and relationship with Vexlo, including processing membership fee payments and renewals.

5.3. To design, curate, and deliver Services, including Signature Events and programming across the five pillars of Ambition and Legacy, Generosity and Impact, Exploration and Adventure, Vitality and Longevity, and Passion and Mastery, tailored to a Member’s documented interests and preferences.

5.4. To communicate with you, including responding to inquiries, sending Vexlo The Art of Living to those who request it, providing event and program invitations, and sharing Service-related updates.

5.5. To conduct research and outreach regarding Prospective Members consistent with Vexlo’s invitation-only model.

5.6. To maintain, secure, and improve our internal systems, including our customer relationship management platform, and to detect, prevent, and respond to fraud, unauthorized access, or misuse of the Services.

5.7. To develop aggregated, de-identified, or statistical information that does not identify any individual, which Vexlo may use for internal analysis and business planning.

5.8. To comply with applicable law, respond to legal process, and enforce our agreements, including the Membership Agreement.

5.9. To support internal recordkeeping, tax, and accounting obligations.

5.10. To support a corporate transaction involving Vexlo, including any future reorganization, merger, acquisition, financing, or sale of assets.

5.11. For any other purpose disclosed to you at the time Personal Information is collected, or with your consent.

VI. USE OF ARTIFICIAL INTELLIGENCE

Vexlo may use artificial intelligence and machine learning tools, including third-party AI assistants, to support internal operations. Typical uses include helping research Prospective Members from publicly available sources, drafting and personalizing member and prospect communications, organizing and summarizing information within our customer relationship management system, and supporting event and program curation. Vexlo’s team reviews the output of these tools before it is relied upon in any decision affecting a Member or Prospective Member, and Vexlo does not use artificial intelligence tools to make final membership admission decisions without qualified human review.

VII. COOKIES, ANALYTICS, AND SIMILAR TECHNOLOGIES

Our website uses cookies and similar technologies to recognize your browser or device, understand how visitors use the Services, and improve the website’s functionality. These technologies may collect information such as your browser and operating system type, IP address, the time you spend on the site, the number of visits, and the pages you view. A notice about our use of cookies is displayed when you first visit the website. Vexlo does not use advertising cookies or tracking pixels.

We may use analytics services, such as Google Analytics, provided by Google LLC, to help us understand website usage. Analytics providers may set their own cookies and process the resulting information on servers located in the United States and elsewhere, generally on the basis of Vexlo’s legitimate business interest in understanding and improving the Services. You can learn how Google uses this information at policies.google.com/technologies/partner-sites, and opt out by installing the Google Analytics opt-out browser add-on at tools.google.com/dlpage/gaoptout. Most browsers allow you to control or block cookies through their settings; please note that blocking certain cookies may affect the functionality of the Services. Where a webpage embeds third-party video (for example, from YouTube), visiting that page may connect you to the third-party provider’s servers, and that provider’s own privacy practices will govern any information it collects.

Vexlo currently does not respond to “Do Not Track” browser signals, except where required to treat such a signal as an opt-out preference signal under applicable state law, as described in Section XII.

VIII. HOW WE SHARE PERSONAL INFORMATION

Vexlo does not sell Members’ or Prospective Members’ Personal Information for money. Vexlo never publicly discloses the identity of its Members. We may disclose Personal Information in the following circumstances:

• Service Providers: with vendors that support our operations under contractual confidentiality and data-protection obligations, including customer relationship management, productivity and collaboration, professional research and data-verification, and email delivery providers, payment processors, and professional advisors such as legal and accounting firms.

• Event and Experience Partners: with the specific partner facilitating a Signature Event or other experience under one of the five pillars that a Member has chosen to participate in, limited to what is necessary to deliver that experience.

• Sponsors: sponsors that support Signature Events are never granted access to the member room and do not receive a Member roster; any information shared with a sponsor is limited to what a Member affirmatively agrees to share in connection with a sponsor-provided experience.

• Affiliates: with entities affiliated with Vexlo, including Marion Street Capital, where necessary to administer your membership or as separately authorized by you.

• Legal and Safety Reasons: where we believe disclosure is necessary to comply with applicable law, respond to legal process, protect the rights, property, or safety of Vexlo, our Members, or others, or investigate suspected fraud or violations of our agreements.

• Corporate Transactions: in connection with a merger, acquisition, financing, reorganization, or sale of assets, where the recipient agrees to handle Personal Information consistently with this Privacy Policy.

• With Your Consent: for any other purpose disclosed to you and to which you agree.

Vexlo does not currently engage in cross-context behavioral advertising that would constitute a “Share” of Personal Information under the CCPA. If this changes, we will update this Privacy Policy and provide the opt-out mechanisms described in Section XII.

IX. DATA RETENTION

Vexlo retains Personal Information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including for the duration of a membership relationship, for the period necessary to satisfy tax, accounting, and other legal recordkeeping obligations, and for as long as necessary to resolve disputes or enforce our agreements. Information about Prospective Members who do not become Members is retained in accordance with Vexlo’s internal data governance practices and is deleted upon a verified request, except where retention is required by law or necessary to establish, exercise, or defend legal claims.

X. DATA SECURITY

Vexlo maintains administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, disclosure, alteration, or destruction, appropriate to the sensitivity of the information involved. These measures include restricting access to Personal Information to personnel and service providers who need it to perform their functions, and contractually requiring service providers to maintain appropriate security measures. No method of transmission or storage is completely secure, and Vexlo cannot guarantee absolute security. If we become aware of a security incident affecting your Personal Information, we will notify you and take other steps in accordance with applicable law.

XI. YOUR PRIVACY RIGHTS UNDER STATE LAW

Depending on where you live, you may have certain rights regarding your Personal Information under applicable state privacy law. Vexlo honors these rights for all individuals to whom they apply, and, as a matter of practice, extends comparable choices to other individuals who submit a request even where not strictly required by the law of their state of residence.

11.1. California (CCPA/CPRA)

If you are a California resident, you have the right to: (a) know and access the categories and specific pieces of Personal Information we have collected about you, the categories of sources, the purposes for collection, and the categories of third parties with whom we have disclosed it; (b) request deletion of your Personal Information, subject to certain exceptions; (c) request correction of inaccurate Personal Information; (d) opt out of the sale or sharing of your Personal Information (as noted in Section VIII, Vexlo does not currently sell or share Personal Information as those terms are defined by the CCPA); (e) limit the use and disclosure of Sensitive Personal Information to what is necessary to perform the Services you have requested; and (f) not be discriminated against for exercising any of these rights.

11.2. Other State Privacy Laws

If you are a resident of Colorado, Connecticut, Virginia, Utah, or another state that has enacted a comprehensive consumer privacy law, you may have similar rights, which generally include the right to confirm whether we process your Personal Information, access it, correct inaccuracies, delete it, obtain a portable copy of it, and opt out of its use for targeted advertising, the sale of Personal Information, or certain forms of automated profiling. Some of these states also provide a right to appeal a denied request, as described in Section 11.4.

11.3. How to Exercise Your Rights

You may submit a request to exercise any of the rights described in this Section 11 by contacting us using the information in Section XIX. To protect your Personal Information, we will take reasonable steps to verify your identity before fulfilling a request, which may include asking you to confirm information we already have on file. You may designate an authorized agent to submit a request on your behalf, subject to our ability to verify the agent’s authority to act for you. We will respond to verifiable requests within the time periods required by applicable law, generally within forty-five (45) days, with the possibility of a reasonable extension where permitted by law and communicated to you.

11.4. Appeals

If we decline to act on your request, and your state of residence provides a right to appeal, you may appeal that decision by contacting us using the information in Section XIX and referencing your original request. We will respond to your appeal within the time period required by applicable law.

XII. DO NOT SELL OR SHARE MY PERSONAL INFORMATION

Vexlo does not sell Personal Information for monetary consideration and does not currently engage in activity that constitutes “sharing” for cross-context behavioral advertising under the CCPA. Should Vexlo’s practices change in the future, we will provide a mechanism, such as a “Do Not Sell or Share My Personal Information” link, and will honor recognized opt-out preference signals to the extent required by applicable law.

XII-A. EMAIL COMMUNICATIONS

Vexlo sends Vexlo The Art of Living and other marketing emails only to individuals who have requested them. Every marketing email includes an unsubscribe link, and Vexlo honors unsubscribe requests promptly and in any event within ten (10) business days. You may also unsubscribe by writing to the email address in Section XIX with “Unsubscribe” in the subject line. Members will continue to receive service-related communications about their membership, which are not marketing emails.

XIII. CHILDREN’S PRIVACY

The Services are not directed to individuals under the age of eighteen (18), and membership in Vexlo is limited to adults. We do not knowingly collect Personal Information from children under the age of thirteen (13) in a manner inconsistent with the Children’s Online Privacy Protection Act. Ambition and Legacy programming may involve limited information about a Member’s next-generation family participants; where such a participant is under the age of eighteen, Vexlo collects and processes information about that participant only with the prior consent of a parent or legal guardian, and only to the extent necessary to administer that programming. If we learn that we have collected Personal Information from a child in a manner inconsistent with applicable law, we will take steps to delete that information.

XIV. NO INVESTMENT, LEGAL, OR TAX ADVICE

Vexlo is not an investment adviser, broker-dealer, law firm, accounting firm, or provider of professional advisory services. Any information, introductions, discussions, events, or experiences made available through the Membership are intended solely to foster meaningful connections, learning, and community among Members. Members are solely responsible for evaluating any information, opportunities, relationships, or decisions arising from their participation in Vexlo and should consult their own professional advisers regarding legal, tax, financial, or other matters. Participation in Vexlo does not create any advisory, fiduciary, agency, or professional-client relationship between Vexlo and any Member.

XV. INTERNATIONAL DATA TRANSFERS

Vexlo’s team, Members, and service providers are located in the United States and other countries. As a result, Personal Information may be transferred to, stored in, and processed in countries other than the country in which it was originally collected, including the United States, which may have data protection laws that differ from those of your home country. Where required by applicable law, Vexlo takes reasonable steps to ensure that such transfers are subject to appropriate safeguards. The Services are not currently directed to individuals located in the European Economic Area or the United Kingdom.

XVI. THIRD-PARTY LINKS AND CONTENT

The Services may contain links to, or embed content from, third-party websites and platforms that Vexlo does not own or control, including social media platforms and, where applicable, embedded video content. This Privacy Policy does not apply to those third-party sites or services, and we encourage you to review the privacy policy of any third-party site or service before providing your Personal Information to it.

XVII. CHANGES TO THIS PRIVACY POLICY

Vexlo may update this Privacy Policy from time to time to reflect changes in our practices, our Services, or applicable law. If we make material changes, we will post the revised Privacy Policy on our website with an updated “Last Updated” date and notify Members by email at least thirty (30) days before the changes take effect. Your continued use of the Services after a revised Privacy Policy takes effect constitutes your acceptance of the changes.

XVIII. GOVERNING LAW

This Privacy Policy is governed by the laws of the State of Wyoming, without regard to conflict-of-laws principles, except to the extent that other state or federal privacy laws described in this Privacy Policy apply to you and cannot be superseded by this choice of law.

XIX. CONTACT US

If you have questions about this Privacy Policy, wish to exercise any of the rights described above, or want to submit a privacy-related request, you may contact us at:

Vexlo LLC
1000 Brickell Ave Ste 715, Miami, FL 33131 US

Email: angel@vexlo.group