Excelohunt's Privacy Policy

Last Updated: 28 Feb 2025

Introduction:

This Privacy Policy (“Policy”) describes how Excelohunt (hereinafter “Excelohunt,” “Company,” “we,” “us,” or “our”) collects, uses, retains, and protects personal data in the course of providing its email marketing services (“Services”) to clients. Excelohunt is an email marketing service provider that executes email campaigns and related services on behalf of its clients (each a “Client”). In providing these Services, Excelohunt acts as a data processor (under the EU General Data Protection Regulation “GDPR”) or service provider (under the California Consumer Privacy Act “CCPA”), processing personal data solely on behalf of and under the instructions of the Client (the data controller/business). Excelohunt is committed to handling all personal data in compliance with applicable data protection laws, including GDPR and CCPA, to the extent those laws apply.

Excelohunt may utilize third-party email platforms or tools (for example, Klaviyo, Mailchimp, or similar services) as part of delivering the Services. However, Excelohunt does not promote, endorse, or affiliate itself with any specific third-party email marketing tools. Any use of such platforms is purely functional for executing campaigns, and Clients are responsible for reviewing and agreeing to the separate terms and privacy policies of those third-party services before use. By engaging Excelohunt for email marketing Services, the Client acknowledges and agrees to the data practices outlined in this Policy. Excelohunt may also enter into separate data processing agreements with Clients as required by law or upon request to further ensure GDPR-compliant and CCPA-compliant data handling.

Data Collection & Ownership:

Excelohunt operates under strict data ownership principles to respect the rights of Clients and their data. We clarify the ownership and usage rights of data as follows:

Client-Provided Data: Any personal data or contact information supplied by the Client for use in email campaigns (such as email lists of subscribers/customers, recipient names, or other identifying information) remains the sole property of the Client. Excelohunt does not permanently store client-provided data on our systems beyond the duration necessary to execute the agreed campaigns. Such data is used exclusively for executing email campaigns and related tasks as instructed by the Client. Excelohunt will not access or use Client-provided personal data for any purpose other than fulfilling the Client’s email marketing campaign instructions, and will never sell, rent, or disclose Client-provided personal data to third parties for independent use.

Excelohunt-Provided Data and Materials: Excelohunt retains ownership of any data, content, or materials that Excelohunt provides or creates as part of the Services, unless otherwise agreed in a written contract. This includes (for example) email contact lists provided by Excelohunt as part of a service package, pre-designed email templates, copywriting content, graphics, or other campaign-related assets created by our team. The Client is granted a license or right to use these Excelohunt-provided assets solely for the purposes of the email campaigns and services for which they were provided. Ownership of such assets remains with Excelohunt by default, and any transfer of ownership or exclusive rights would need to be explicitly agreed to in a separate contract.

Confidentiality of Client Information: Excelohunt understands that Clients may entrust us with sensitive business information, strategies, trade secrets, or other confidential data in the course of our engagement. All such client secrets and confidential information remain the property of the Client and will be kept strictly confidential by Excelohunt. We will not disclose or divulge any sensitive Client business information to any third party without the Client’s authorization, except as required by law or legal process. Excelohunt personnel are bound by confidentiality obligations to protect Client information, and we implement internal controls to prevent any unauthorized access or disclosure.

Data Storage & Retention:

Excelohunt’s policy is not to permanently store personal data from Client campaigns on our own systems. Any Client data that we handle is retained only for as long as necessary to perform the Services. Our data storage and retention practices are as follows:

Temporary Storage for Processing: In certain cases, Excelohunt may need to temporarily store or cache Client data to accomplish specific tasks (for example, uploading a contact list into an email platform, performing email validation and list cleaning, or generating campaign reports). Any such temporarily stored data is retained for a short duration (typically no more than seven (7) to fifteen (15) days), solely to complete the relevant task. After this period, and once the data has served its purpose, it is securely and permanently deleted from our active systems. We do not build or maintain separate databases of Client-provided personal information.

Unintentional or Residual Data: In the rare event that any Client data remains on our systems beyond the intended retention period (for instance, due to backup retention, caching, or an oversight), Excelohunt’s policy is to identify and remove such data as soon as possible. We conduct periodic reviews to ensure no client personal data is retained longer than necessary. Any residual data that is no longer needed for campaign purposes will be purged in a secure manner.

Client Data Deletion Requests: Clients may, at any time, request deletion of their data that may be held by Excelohunt. Upon receiving a legitimate deletion request, Excelohunt will make good-faith efforts to promptly erase the requested Client data from our systems, to the extent we control it. However, Excelohunt reserves the right to make the final determination regarding data deletion. In certain instances, we may decline or delay deletion of data if, for example, retention is required for legal compliance, to assert or defend legal claims, for auditing purposes, or other legitimate business reasons consistent with applicable law. Excelohunt will inform the Client of the justification if any data must be retained contrary to a deletion request. Aside from such exceptional cases, our goal is to honor deletion requests and ensure that Client data is not held longer than necessary.

Data Security:

Excelohunt is committed to protecting the security and integrity of all personal data processed on behalf of Clients. Although we do not permanently store Client personal data, we implement appropriate technical and organizational security measures to safeguard any data while it is being processed or temporarily stored by us. These security measures include, but are not limited to:

Access Controls: Restricting access to Client data strictly to authorized Excelohunt personnel who need it for performing the Services. We limit and monitor internal access on a need-to-know basis, and all staff are subject to confidentiality and data protection obligations.

Data Transmission & Storage Security: Using secure methods to transfer data (such as encrypted channels) when uploading or sending email lists or campaign content to third-party email platforms. For any data temporarily stored on our systems, we employ up-to-date security practices (firewalls, encryption at rest where applicable, secure passwords, etc.) to prevent unauthorized access or breaches.

Timely Deletion: Promptly deleting and removing personal data from our systems once it is no longer required for the Service, which minimizes the window of any security risk. By not maintaining long-term databases of personal data, Excelohunt reduces the risk of data exposure.

Despite our efforts, no method of data transmission or storage can be guaranteed 100% secure. Therefore, while Excelohunt strives to use commercially reasonable means to protect personal data, we cannot warrant absolute security. In the unlikely event of a data breach or security incident affecting Client personal data, Excelohunt will notify the affected Client without undue delay and provide relevant details in accordance with our legal obligations and any applicable data breach notification laws. We will also take prompt action to contain, mitigate, and remedy the breach to protect the interests of our Clients and the individuals whose data is involved.

Tracking & Analytics:

As part of the email marketing Services, Excelohunt may implement tracking and analytics tools to measure campaign performance. This includes collecting data on email open rates, link click-through rates, bounce rates, unsubscribe actions, and other engagement metrics related to the emails sent on the Client’s behalf. All such tracking and analytics activities are conducted in a privacy-conscious manner and serve the following purposes:

Campaign Performance Analysis: The information gathered (e.g., how many recipients opened an email, which links were clicked, etc.) is used exclusively to analyze and optimize the performance of the Client’s email campaigns. Excelohunt uses these metrics to generate reports for the Client, refine email content or targeting strategies as needed, and improve overall effectiveness of the Service for that Client. This data allows both Excelohunt and the Client to gauge engagement levels and make data-driven decisions for future campaigns.

No Third-Party Disclosure or Sale: Tracking and analytics data is treated as confidential and is never shared with or sold to any third parties. Excelohunt does not monetize this data in any way. The campaign performance data remains under Excelohunt’s control and is accessible to the Client for their own use, but it is not disclosed outside of our organization (except to the Client) and not used for any other purpose beyond servicing that Client. Any aggregated statistics (for example, average open rates across all campaigns) that Excelohunt may derive will contain no identifying information and will not be attributable to any individual or specific Client without permission.

Please note that some of these metrics may involve the use of tracking pixels or unique links within emails, which function by notifying our system when an email is opened or a link is clicked. By using Excelohunt’s Services, the Client consents to the use of such lawful tracking mechanisms for the purpose of obtaining performance data. All tracking is done in compliance with applicable laws and industry standards, and recipients of emails have the ability to opt out of further emails by using the provided unsubscribe mechanisms in every campaign, which Excelohunt will honor and reflect in the analytics (e.g., recording an unsubscribe action).

Third-Party Services:

In delivering email campaigns, Excelohunt may rely on third-party service providers and platforms for certain functionalities (for example, to send bulk emails, manage subscriber lists, or validate email addresses). These may include well-known email marketing platforms such as Klaviyo, Mailchimp, SendGrid, or others, as well as specialized tools for analytics or email validation. It is important to understand the following in regard to third-party services:

Use of Third-Party Platforms: Excelohunt uses third-party email delivery platforms and related services solely as tools to provide the Services to the Client. Any Client data uploaded to or processed by these platforms is only to facilitate the sending and management of the Client’s email campaigns. Excelohunt does not endorse or promote any specific third-party tool; the choice of platform is typically based on the Client’s needs or preferences, or on the technical requirements of the campaign. References to any third-party service (e.g., naming an email platform we use) are for informational purposes only and do not constitute an endorsement by Excelohunt of that service or its provider.

Separate Terms and Policies: Each third-party service that may be utilized (such as an email marketing platform) operates under its own privacy policy and terms of use. Clients may be required to have their own account with these services or to agree to those terms for their data to be processed on that platform. Clients are responsible for reviewing and complying with any relevant user agreements or privacy policies of third-party platforms used in connection with Excelohunt’s Services. Excelohunt will make reasonable efforts to choose reputable providers with strong privacy and security practices, but we do not control the independent data practices of these third parties. For example, if an email campaign is executed through Mailchimp on the Client’s behalf, the data will be stored on Mailchimp’s systems during the campaign, and the Client should ensure they understand Mailchimp’s privacy commitments as well.

Data Sharing with Third Parties: Excelohunt will only share Client data with third-party services to the extent necessary to perform the requested Services. This is typically limited to uploading the email list and campaign content to an email delivery platform to send out the emails, or using an email verification service to check for invalid addresses. We do not provide Client data to any third-party except for service delivery purposes, and under no circumstances will Excelohunt allow a third-party provider to use Client data for their own marketing or purposes outside of executing our Client’s campaigns. All third-party service providers used by Excelohunt are bound by contractual obligations or terms of service that restrict their use of the data strictly to providing the requested service to us (and by extension, to the Client).

In summary, while Excelohunt integrates certain third-party tools into our workflow, those tools act under our direction and for our Client’s benefit. Clients should ensure they are comfortable with the third-party services involved and understand their independent policies, as Excelohunt cannot assume liability for the actions of third-party processors beyond our control. We will, however, promptly address any concerns and work with Clients to mitigate issues arising from a third-party service used for campaign execution.

Client Responsibilities:

Using Excelohunt’s Services comes with specific responsibilities for the Client to ensure that all email marketing activities are legally compliant and ethically conducted. By using our Services, the

Client agrees and acknowledges the following responsibilities:

a. Legal Compliance and Lawful Use of Data: The Client is solely responsible for ensuring compliance with all applicable laws and regulations in relation to the personal data and email campaigns they engage Excelohunt to process. This includes, without limitation, data protection and privacy laws such as the GDPR (for individuals in the European Economic Area), the CCPA (for California residents), and any other relevant international, federal, or state laws (for example, CAN-SPAM Act in the United States, CASL in Canada, PECR in the UK, etc. as applicable). The Client must ensure that all personal data provided to Excelohunt (e.g., email addresses in the mailing list) has been collected and is being shared with Excelohunt lawfully. It is the Client’s duty to have a proper legal basis for processing and sending emails to each individual on their list (for example, obtaining the individual’s consent to receive marketing emails, or relying on another permissible basis under GDPR such as legitimate interests, if appropriate). Excelohunt does not independently verify the legality of the Client’s data collection; we operate under the assumption that the Client has obtained all necessary consents and rights for the use of the data in the intended campaigns.

b.Providing Notices and Handling Data Subject Requests: The Client is responsible for providing any required privacy notices or disclosures to the individuals whose personal data is used in email campaigns. For example, if required, the Client should have a privacy policy of its own that discloses that a service provider like Excelohunt may process personal data on the Client’s behalf for email marketing purposes. Additionally, if any email recipient (data subject) exercises their rights under data protection laws (such as requesting access to their data, deletion of their data, or opting out of further communications), it is the Client’s responsibility to address and honor such requests. Excelohunt will assist the Client as reasonably necessary (and as required by GDPR or other laws) in responding to such requests — for instance, by deleting or retrieving data that we process for the Client — but the primary obligation to the individual lies with the Client. Similarly, the Client must ensure that any unsubscribe or opt-out requests by recipients of the email campaigns are properly implemented. Excelohunt will include unsubscribe links in email campaigns and manage removals from the mailing list as instructed, but the Client must ensure ongoing compliance with those opt-outs (e.g., not re-adding an unsubscribed person to a list).

c.Content and Campaign Compliance: The Client is responsible for the content of the emails and the targeting of their campaigns. This means the Client must ensure that the content does not violate any laws (e.g., it should not contain false or misleading information, and it must include any legally required elements such as identification of the sender and an unsubscribe mechanism as required by law). The Client should also ensure that they are not instructing Excelohunt to send emails to any individuals who have not agreed to receive such communications or who are otherwise protected by do-not-contact rules. Excelohunt can provide guidance on best practices if requested, but we do not assume responsibility for vetting the legality or appropriateness of the Client’s email content or recipient list beyond following the Client’s explicit instructions.

Excelohunt’s Limited Role in Compliance: Excelohunt acts as an executor of the technical and creative aspects of email campaigns under the direction of the Client. Excelohunt does not assume responsibility for the Client’s legal obligations with respect to data protection or privacy law compliance, beyond our role as a data processor following the GDPR Article 28 and CCPA service provider requirements. We will follow the instructions given by the Client and implement reasonable measures to facilitate compliance (for example, by including required unsubscribe links, not sending to suppressed addresses, and protecting data as described), but ultimate compliance responsibility rests with the Client. The Client should seek independent legal advice if unsure about the legality of any aspect of their email marketing practices. By using our Services, the Client agrees to indemnify and hold Excelohunt harmless for any claims or penalties arising from the Client’s failure to comply with applicable laws in the use of our Services, to the extent permitted by law and by our service contract.

In summary, Excelohunt provides the tools and expertise to run email campaigns, while the Client must ensure that those campaigns meet all legal requirements. Excelohunt will cooperate with Clients and regulators as needed to support compliance efforts (for example, by providing information about our processing or signing Data Processing Agreements), but we do not independently monitor or enforce legal compliance beyond our described practices.

Policy Updates & Contact Information:

Excelohunt reserves the right to update or modify this Privacy Policy at any time. We may revise the contents of this Policy to reflect changes in our practices, to clarify our commitments, or to comply with updates in laws and regulations. If we make material changes to this Policy, we will provide an appropriate notice to Clients (for example, by emailing Clients or by posting a prominent notice on our website) prior to the change becoming effective. The “Last Updated” date at the top of this Policy will always indicate the timing of the latest revisions. Continued use of Excelohunt’s Services after any modifications to the Privacy Policy constitutes acceptance of the updated terms. We encourage Clients to review this Policy periodically to stay informed about how we are protecting and handling their information.

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of personal data by Excelohunt, please contact us at info@excelohunt.com. You may also reach out to us via the contact information provided on our website or through your account manager at Excelohunt. We will respond to inquiries as promptly as possible and work in good faith to address any issues or requests related to privacy and data protection. If a Client or any individual believes that Excelohunt is processing personal data in a manner not in compliance with this Policy or applicable law, we welcome you to contact us to resolve the issue. Additionally, individuals whose data we process on behalf of a Client should ideally direct any concerns or requests to the relevant Client (the data controller), but Excelohunt will also assist in forwarding or addressing such communications in line with our obligations.

Consent and Acknowledgment:

By engaging Excelohunt for email marketing Services or by providing us with personal data for processing, the Client acknowledges that they have read and understood this Privacy Policy and agree to its terms. This Policy forms part of any service agreement or terms of service with Excelohunt. In case of any conflict between this Policy and other agreements, the terms that provide greater data protection to the Client’s data shall prevail (unless explicitly agreed otherwise in writing). This Policy does not override any rights an individual may have under applicable law, and Excelohunt will always strive to meet the highest standards of data protection as required by law or contract.