VEXLO LLC PRIVACY POLICY
Effective Date: October 2th 2026
Last Updated: October 2th 2026
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
• “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
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
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
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
X. DATA SECURITY
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
XII-A. EMAIL COMMUNICATIONS
XIII. CHILDREN’S PRIVACY
XIV. NO INVESTMENT, LEGAL, OR TAX ADVICE
XV. INTERNATIONAL DATA TRANSFERS
XVI. THIRD-PARTY LINKS AND CONTENT
XVII. CHANGES TO THIS PRIVACY POLICY
XVIII. GOVERNING LAW
XIX. CONTACT US
Vexlo LLC
1000 Brickell Ave Ste 715, Miami, FL 33131 US
Email: angel@vexlo.group