Xenovue LLC
Last Updated: May 19, 2026

1. Introduction

‍Xenovue LLC (“Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting personal information in accordance with applicable U.S. federal and state privacy laws, including the California Consumer Privacy Act (CCPA), and applicable international data protection principles.

For purposes of operational management and corporate restructuring, Company and its current or future parent entities, holding companies, subsidiaries, and affiliates may operate as a unified business group.

navaroAI is an educational platform, brand, project, or service created and operated by Xenovue LLC. References in this Privacy Policy to our website, services, platforms, products, newsletters, digital products, educational content, consulting services, or offerings include navaroAI unless otherwise stated.

This Privacy Policy explains how we collect, use, disclose, retain, and safeguard information when you:

• Visit our website
• Subscribe to newsletters or educational content
• Purchase digital products• Engage consulting, implementation, or advisory services related to the Xenovue AI Direction Operating System™
• Participate in certification programs
• Interact with services offered under our brands, platforms, projects, or services, including navaroAI
• Engage with us through third-party platformsBy using our website or services, you acknowledge this Privacy Policy.
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2. Information We Collect
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A. Information You Provide Directly

‍We may collect:

• Full name
• Email address
• Company or organization name
• Billing address
• Contact information
• Subscription preferences
• Information submitted through forms
• Engagement-related information for consulting services
• Organization size, role, industry, or operational context
• Information submitted through assessments, intake forms, worksheets, surveys, or educational tools
• Information you choose to provide in connection with AI adoption, governance, compliance awareness, workflow design, or operational planning
• Accessibility, support, or technical assistance requestsWe do not store full payment card numbers.

Payments are processed by third-party platforms including Substack, Gumroad, Stripe, or similar providers.

‍B. Automatically Collected Information

‍We may automatically collect:

• IP address
• Browser type and version
• Device type
• Operating system
• Pages visited
• Referring URLs
• Date/time stamps
• Interaction metrics

This information is collected via cookies and similar tracking technologies.

‍C. Information from Third-Party Platforms

‍If you transact, subscribe, register, click referral links, or otherwise interact with us through Substack, Gumroad, Stripe, email platforms, affiliate or referral platforms, analytics providers, or other third-party services, we may receive:

• Name
• Email address
• Purchase details
• Transaction status
• Referral source
• Subscription status
• Affiliate or referral attribution information
• Engagement information, such as opens, clicks, downloads, or form submissionsWe do not control how those platforms process your data and encourage review of their privacy policies.

‍3. Lawful Basis for Processing (GDPR Transparency)

‍If you are located in the European Economic Area (EEA), United Kingdom, or similar jurisdictions, we process personal data under one or more of the following lawful bases:

• Your consent
• Performance of a contract
• Compliance with legal obligations
• Legitimate business interests, such as analytics, fraud prevention, and operational improvementYou may withdraw consent where applicable.
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4. Use of AI-Assisted Tools

‍We may use artificial intelligence-assisted tools to support research, drafting, summarization, content development, workflow design, administrative tasks, internal operations, product development, customer support, and service delivery.

AI-assisted tools may be used in connection with website content, newsletters, educational materials, navaroAI resources, digital products, operational frameworks, templates, consulting preparation, and other Company materials or services.

We do not intentionally submit sensitive personal information to AI-assisted tools unless necessary to provide services, support operations, respond to a request, or where you have provided the information for that purpose. Where practical, we use reasonable efforts to limit the personal information included in AI-assisted workflows.

AI-assisted tools may be provided by third-party service providers. Information processed through those tools may be subject to their privacy, security, and data-processing terms.

You should not submit confidential, sensitive, regulated, or legally privileged information through website forms, educational tools, or other general communication channels unless we have entered into a separate written agreement governing that information.

‍5. How We Use Personal Information

‍We may use information to:

• Provide and deliver digital products
• Manage subscriptions• Process transactions
• Deliver consulting, implementation, and advisory services related to the Xenovue AI Direction Operating System™
• Administer certification programs
• Respond to inquiries
• Improve website functionality
• Conduct analytics
• Prevent fraud
• Comply with legal obligations
• Send marketing communications, with opt-out available
• Operate and improve navaroAI and other Company platforms
• Personalize educational content, resources, or communications
• Prepare, support, or improve AI-assisted workflows, educational tools, templates, and operational resources
• Respond to accessibility, support, or technical assistance requests
• Track referral, affiliate, or promotional attribution where applicableWe may use aggregated or de-identified information to improve our educational content, digital products, operational frameworks, website performance, and service offerings.

We do not sell personal information.

Except as described in this Privacy Policy and our Cookie Policy, we do not knowingly share personal information for cross-context behavioral advertising.

‍6. Cookies & Tracking Technologies

‍We use cookies and similar technologies for:

• Essential website functionality
• Analytics, such as Google Analytics
• Advertising measurement, such as Meta Pixel
• Performance optimization
• Affiliate, referral, or promotional attribution where applicableCookies may collect device identifiers and browsing activity.

You can manage cookie settings through your browser.

For more information about the cookies and tracking technologies we use, including how to manage your preferences, please review our Cookie Policy.

For California residents, you may opt out of tracking technologies used for advertising purposes by adjusting browser settings or using available opt-out tools.

‍7. Analytics & Advertising Disclosure

‍We engage third-party service providers to assist with analytics, marketing, payment processing, and communications.
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These providers operate under their own terms and privacy policies.

We configure these tools for our business purposes but do not control how third parties independently use data collected through their platforms.

You may review the privacy policies of these providers directly.

Some pages, newsletters, resources, or recommendations may contain affiliate links, referral links, sponsored links, or similar tracking technologies. If you click these links, third parties may collect information about your visit, referral source, purchase, subscription, or interaction according to their own privacy policies.

‍8. Data Sharing & Disclosure

‍We may share personal information with:

• Payment processors, including Substack, Gumroad, Stripe
• Email service providers
• Analytics providers
• Cloud storage providers
• Legal advisors
• Government authorities when legally required
• AI-assisted tool providers
• Affiliate, referral, or promotional tracking providers
• Customer support, form, survey, or workflow tool providersWithin our corporate structure, personal information may be processed by current or future parent entities, holding companies, subsidiaries, or affiliates for operational, administrative, or legal purposes consistent with this Privacy Policy.

We share personal information only as reasonably necessary for the purposes described in this Privacy Policy, to operate our business, provide services, comply with law, or protect our rights.We do not sell personal information.We do not share personal information for monetary consideration.

‍9. Data Retention
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We retain personal information only as long as reasonably necessary to:

• Fulfill contractual obligations
• Maintain business and tax records
• Resolve disputes
• Comply with legal requirements

Retention periods vary depending on the nature of the data.

‍10. Data Security

‍We implement reasonable administrative, technical, and organizational safeguards to protect personal information.

However, no method of transmission over the Internet or electronic storage is completely secure.

We cannot guarantee absolute security.

Where we use AI-assisted tools or third-party service providers, we use reasonable efforts to select tools and workflows appropriate for the sensitivity of the information involved.

Digital Products downloaded to your environment are controlled by you. These materials may constitute components of the Xenovue Proprietary System, including elements of the Xenovue AI Direction Operating System™. We do not access, monitor, or control data entered into downloaded materials after delivery.

‍11. Your Privacy Rights (United States & California)

‍Depending on your state of residence, you may have the right to:

• Request access to personal information we have collected about you
• Request correction of inaccurate personal information
• Request deletion of personal information, subject to legal exceptions
• Request information about categories of personal information collected
• Request information about categories of sources and third parties
• Opt out of certain uses of personal informationCalifornia Residents — Do Not Sell or Share Notice

We do not sell personal information for monetary consideration.

We may use analytics and advertising technologies, such as Google Analytics and Meta Pixel, to measure website performance and marketing effectiveness. Under certain interpretations of California law, use of these technologies may be considered “sharing” for cross-context behavioral advertising purposes.

California residents have the right to opt out of the sale or sharing of personal information.

You may exercise this right by:
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• Using our cookie consent banner to reject non-essential cookies
• Adjusting your browser settings
• Contacting us directly at: engage@xenovue.com

We may verify your identity before fulfilling requests.

‍12. International Data Transfers

‍If you access our website from outside the United States, your data may be transferred to and processed in the United States.

By using our website, you consent to this transfer.

‍13. Children’s Privacy

‍Our services are not directed to individuals under 18 years of age.

We do not knowingly collect personal information from children.

‍14. Third-Party Links, Tools, and Affiliate Links

‍Our website, newsletters, resources, digital products, or educational materials may contain links to third-party websites, tools, platforms, affiliate links, referral links, sponsored links, or embedded services.

We are not responsible for the privacy practices, security practices, content, terms, or data-processing activities of third parties.

If you click a third-party link or use a third-party tool, that third party may collect information directly from you or about your interaction according to its own privacy policy.

‍15. Corporate Restructuring

‍We may restructure, merge, form a holding company, create subsidiaries, or transfer assets.
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In connection with such restructuring, personal information may be transferred to a successor entity.

Any successor entity will process personal information in accordance with applicable law and its then-current privacy policy.

‍16. Changes to This Privacy Policy

‍We may update this Privacy Policy at any time.

Updates will be reflected by the “Last Updated” date.

Continued use of our website constitutes acceptance of changes.

‍17. Contact Information

‍For privacy-related inquiries, requests, or concerns: engage@xenovue.com

© 2026 Xenovue LLC. All rights reserved.
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