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    Privacy Notice


    Last Updated: December 1, 2025

    Scope
    Your privacy is important to Acelab, Inc. (“Acelab”, “our”, “us” or “we”) as is your trust in our Services. This Privacy Notice (“Notice”) describes how Acelab handles personal information in connection with our website and proprietary software platform (collectively, the “Services”), and when you otherwise interact with us such as by visiting the Acelab website, or accessing and using the internet-based services offered by Acelab on our website acelabusa.com. This Notice is incorporated into, and considered a part of, the Acelab Terms of Use.


    PERSONAL DATA WE COLLECT
    The personal data that we may collect includes, but is not limited to, the following categories listed below. We may receive this information when it is provided directly to us by you (including through interaction with our Services), our business partners, and in some cases, certain trusted service providers we work with. We may also obtain information from other sources such as publicly available sources.
    We may combine information that we receive from the various sources described above for the purposes identified in this Notice. Depending upon your use of our Services, we may collect some or all of the following information:
    ●    Account Information: We collect information you provide to create an account for our Services, such as your first and last name, email address, telephone number, professional title, company name, or other biographical information.
    ●    Business Information: such as your company’s name, website, and a short business description.
    ●    Account and Authentication Information: such as usernames and passwords to set up your account and photos if you choose to upload a profile picture.
    ●    Contact and Communication Information: If you contact us, including in connection with customer support requests, requests for product demonstrations or purchase inquiries, or otherwise, we collect the information you provide to enable us to contact you (such as name, job title, email address, physical address, phone number, or other similar contact information). We also collect records of emails, chats (for example, when you use our Rep Connect chat feature to connect with Manufacturers or Architects), and other communications with us. When you contact us, you may interact with our chatbot.
    ●    Usage and Performance Information: When you use our Services (including visiting our websites), we automatically collect information related to your use of such Services and their performance, including analytics, logs, session information regarding how you interact with the Services (which may include information such as the resources that you access, pages viewed, how much time you spent on a page, and how you reached our website), browser type, operating system, and other similar usage activity.
    ●    Device Information: We also collect other types of information automatically when you use our Services (including visiting our websites) regarding the device you use to access such Services, such as operating system and version, IP address, browser and device characteristics, referring URLs, and a record of your interactions with our Service.
    ●    Crashes and Error Reports: If you encounter a crash or error while using our Service, we may generate a crash report that includes technical, usage and, if you are logged in, your account information so that we can diagnose and potentially prevent the problem in the future.
    ●    Other Information You Provide to Us: We collect any information you may submit or otherwise provide to Acelab, such as feedback regarding our Services (whether in written, oral, or electronic form), your responses to forms on our websites, your responses to surveys that we have sent to you, or other information you provide when you interact with us.
    ●    Other Information Provided to Us by Third Parties: In addition to the above, we may also collect other information about you from other third parties, as well as from publicly available sources. We may periodically obtain both personal and non-personal information about you from third parties that are authorized to share the information. These parties may install tracking scripts and cookies when you integrate them with the Service. This Notice only covers the use of cookies by Acelab. Cookies placed by third party services are governed by the third party terms and privacy policies.
    ●    Aggregate And Deidentified Information: We may also collect, use and share aggregate or deidentified information that does not identify you as permitted by applicable laws. For example, we may collect, analyze and share statistical information about the use of our website including data on traffic, usage patterns, user numbers, sales and other information in order to measure and improve our Services.
    ●    Do-Not-Track: Your browser or device may include “Do-Not-Track” settings or functionality. Currently, our systems do not recognize browser “Do-Not-Track” requests. The information collection and disclosure practices, and the choices that we provide to users, will continue to operate as described in this Notice, whether or not a Do-Not-Track signal is received.


    You can choose not to provide us with any or all of the information we specify or request, but then you may not be able to register with us or to take advantage of some or all of our features.


    USE OF YOUR PERSONAL DATA
    We use the personal data we collect primarily to develop, operate, deliver, and improve our Services. We also may use the personal data we collect for the following purposes:
    ●    Service Delivery: To provide, maintain and improve our Services (for example, to connect Manufacturers and their products to Architects, construction companies, and real estate developers).
    ●    Personalization: To personalize our Services, such as customizing your experience or making recommendations for features or functionality you may wish to use.
    ●    Training and Education: To provide training (for example, AIA continuing education).
    ●    Communication: To send you technical notices, updates, security alerts, and other administrative messages, and respond to your requests, comments, or questions, and to provide customer service and communicate with you about the Service.
    ●    Support and Development: To monitor and analyze trends, performance, usage and other activities in connection with and otherwise support, maintain and improve our Services and to develop new products and services. This includes creating de-identified and aggregate information, troubleshooting, and quality assurance purposes.
    ●    Marketing: To market and promote our Services, which may include sending you emails or direct mail with information about products and services offered by Acelab. For marketing surveys, research and analytics.
    ●    Billing: To process transactions, fulfill orders and send related information, including confirmations, receipts, and invoices, and otherwise to administer and operate our business, including sending of relevant information (your name, company name, job title, address, phone number, and email address) to our third party payment processors.
    ●    Security and Legal Compliance: To detect, investigate and prevent fraudulent transactions, abuse, and other illegal activities, to verify your identity otherwise to help secure our Services, to comply with legal, regulatory or contractual requirements, and to protect the rights and property of Acelab, our users, and others.
    ●    Other Purposes with Your Consent: For any other purpose that we communicate to you and to which you consent, or to carry out any other purpose described to you at the time the information was collected.
    ●    Other Purposes without Your Consent We may disclose your personal information to third parties for purposes other than those for which the information was originally collected. 


    DISCLOSURE OF YOUR PERSONAL DATA
    We do not disclose or share your personal data outside of Acelab, except as follows:
    ●    With Service Providers: We may engage third-party service providers to help deliver Services on our behalf (or enhance specific features within our offerings), or to perform certain tasks, at our direction, including with our trusted services providers who work on our behalf. We may share your personal data with such service providers to perform such services and tasks on our behalf.
    ●    With Business Partners: We may share your personal data with our business partners in connection with offering you co-branded services or other joint offerings.
    ●    With Related Entities: We may share some or all of your personal data within Acelab and our future parents, affiliates, subsidiaries, joint ventures, or other companies under common control and ownership.
    ●    Business Transfers: We may share your personal data in connection with, or during negotiations of, any merger, sale of assets, financing or acquisition of all or a portion of our business, or in connection with the sale, transfer or financing of a significant part of Acelab business or its assets.
    ●    Protection and Enforcement Purposes: We may disclose any information about you as we deem necessary in our sole discretion to: (i) enforce this Privacy Notice or the Terms, (ii) respond to claims of a violation of the rights of third parties, (iii) protect our rights, property, or safety and the rights, property and safety of the Services, our users or others, (iv) prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable, or (v) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to a law enforcement request.
    ●    As Required by Law: We may disclose any information about you to government or law enforcement officials or private parties that we, in our sole discretion, believe necessary or appropriate to comply with a legal requirement or process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures, such as in conjunction with a subpoena, government inquiry, litigation, dispute resolution or similar legal process.

    ●    Otherwise with Your Consent: We may otherwise disclose any information about you with your consent or at your direction, including if you intentionally interact with third-parties on our site.
    ●    De-identified information: We may also share aggregated or de-identified information, which cannot reasonably be used to identify you, with others.

    YOUR CHOICES
    Account Information
    At any time, you may access and change your personal information we may store by contacting us via email at support@acelabusa.com. To further protect privacy, these requests may be subject to identity verification. You may also request deletion of your account information by email at support@acelabusa.com, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete account information, it will be deleted from the active database, but may remain in our archives. You are responsible for maintaining the confidentiality of your Services access information and password and for restricting access to your device, and you agree to accept responsibility for all activities that occur under your password.


    Cookies and Other Tracking Technologies
    These are alphanumeric identifiers that help us to distinguish between unique browsers and devices in order to avoid showing you the same information twice, keep you logged into Acelab, prevent duplicate actions, prevent duplicate coupon redemptions and improve your experience. We use cookies and other similar technologies on our websites for a number of purposes, including enhancing website navigation, analyzing website usage, improving our users' experience, enhancing the security of our Services, and assisting in our marketing efforts. The information we collect from cookies may include your IP address, browser and device characteristics, referring URLs, and a record of your interactions with our Service. We may analyze this information and use it in accordance with this Notice. For example, Google Analytics is one of the analytics providers we use. You can find out how Google Analytics uses data and how to opt out of Google Analytics.  


    You can manage cookies through your browser settings. Most browsers and devices will tell you how to remove cookies from your device, how to prevent your browser or device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Depending on the jurisdiction in which you reside, you may have additional choices regarding how we use cookies and other tracking technologies. For more information about such choices, please refer to the Location-Specific Notices section below.

    Promotional Emails
    You may opt-out of receiving promotional emails from us by following the instructions in such marketing emails or by contacting us at support@acelabusa.com. If you opt-out, we may still send you non-promotional emails, such as those about your account, your purchases, or transactional communications related to the Services. Please note that we will honor your marketing opt-out preferences, but we may continue to send transactional communications related to the Services.

    YOUR RIGHTS
    Subject to certain limitations and exceptions allowed by law, Acelab honors the exercise of the following rights for individuals regardless of their location:
    ●    Access: You have the right to request access to the personal data we process about you along with information about how we process your personal data and the categories of personal data we process.
    ●    Correction: You have the right to request that we correct inaccurate or incomplete personal data we process about you.
    ●    Deletion: You have the right to request that we delete personal data about you.


    Depending on where you reside, you may have other rights available to you in addition to those described above. For more information, please review the Location-Specific Notices section below. Individuals who wish to submit a privacy related request can either do so on their own, or through a third party, such as an authorized agent. Prior to taking action on any privacy-related request, Acelab takes steps to limit fraudulent activity that are designed to verify the identity of the person making the request. Failure to provide us with the information requested may result in our denial of the request. We respond to all legitimate requests within legally mandated timeframes or, to the extent the above rights are not legally mandated where you reside, we will use reasonable efforts to respond within 45 days. To exercise any of the rights above or the additional rights described in the Location-Specific Notices section below, please contact us using any of the methods described in the Contact Information section below.


    OTHER IMPORTANT DETAILS
    Changes To This Privacy Notice
    If we make changes to this Notice, these changes will be posted on our website in a timely manner. We're constantly trying to improve our Services, so we may need to change this Notice from time to time. We reserve the right to modify this Notice at any time. We will alert you to material changes by, for example, placing a notice on our website or by sending you an email (if you have registered your email address with us) when we are required to do so by applicable law. You can determine when this Notice was last revised by referring to the "Last Updated" legend at the top of this page. Any changes to this Notice will become effective upon our posting of the revised Notice on our website. You are responsible for periodically reviewing this Notice.


    Security Of Your Data
    We use a variety of technical, organizational, and administrative measures designed to protect the personal data that we collect about you against unauthorized access, use and disclosure. We use reasonable physical, technical, and administrative safeguards to protect personal information within our organization. We want you to feel confident using the Services, however no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account with us has been compromised), please immediately contact us at support@acelabusa.com. You are responsible for maintaining the confidentiality of your Services access information and password and for restricting access to your device, and you agree to accept responsibility for all activities that occur under your password.


    Data Retention
    We store the personal data we collect about you for as long as is necessary for the purpose for which such information was collected or for other legitimate business purposes, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. We retain your personal information as long as we have an ongoing legitimate business need to do so for example to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws. The criteria we use to determine storage periods include the applicable contractual provisions that are in force, legal statutory limitation periods, applicable regulatory requirements and industry standards. When we have no ongoing legitimate business need to process your personal information, we will either delete, deidentify or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible as permitted by law.


    Location of Processing
    We are headquartered in the United States and collect, use, and otherwise process personal data we collect or otherwise receive about you primarily in the United States. By using our Service, you authorize us to transfer, store, use and process your personal data in the United States and any other country where we operate. In some of the countries to which we transfer personal data, the privacy and data protection laws may vary from those of your home country. Certain of our employees and service providers reside or operate in other jurisdictions and your personal data may be stored in or accessed from multiple countries. Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Notice and as permitted by applicable data protection laws. 


    Advertising and Analytics Services Provided by Others
    We engage others to provide analytics services via our Services, and to serve advertisements on our behalf on other websites and online services. These entities use cookies, web beacons, device identifiers and other technologies to collect information about your use of our Services and other websites and online services, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. For example, we use Google Analytics. See Google's  privacy policy for more information about how Google collects and uses data about you when you use our Services.


    Third Party Services and Links to Other Websites
    Our website may contain links to other websites, many of which have their own privacy notices. Be sure to review the privacy notice on any site you are visiting or providing information to. This Notice  does not apply to the practices of those third-party plug-ins, exchanges, networks or websites that Acelab has a relationship with or other companies or individuals that Acelab does not own, employ, manage or control.


    A Note About Children
    We do not permit anyone under the age of 18 to register for our Services, nor do we knowingly collect or solicit personal data from anyone under the age of 18. We restrict use of the Service to individuals age 18 and above. If you are under 18, please do not attempt to register for the Services or send any personal data about yourself to us. If we learn that we have collected personal data from a child under the age of 18, we will make commercially reasonable efforts to delete such information from our database. If you believe that a child under 18 may have provided us with personal data, please contact us at support@acelabusa.com.

    LOCATION-SPECIFIC NOTICES
    The following sections provide additional notices and describe additional rights that may apply to you based upon where you reside:


    European Economic Area, Switzerland & United Kingdom
    This section provides additional disclosures for and details about rights afforded to individuals residing in any of the countries of the European Economic Area ("EEA"), Switzerland, or the United Kingdom:


    Acelab's Role: Acelab acts as a controller of the personal data we collect and use in providing Services to our customers.


    Legal Bases for Processing Personal Data: We may process your personal data on the following legal bases:
    ●    Contract: We use information about you to fulfill our contractual obligations to you or to an organization (such as your employer), such as to provide our Services, provide customer service, or fulfill other transactions like processing payments.
    ●    Legitimate Interest: We also use information about you when we have a legitimate interest in doing so, such as to help secure and improve our products and services, to develop new products and services, to detect and prevent fraud, to market and promote our Services, to analyze usage patterns, or to operate our business.
    ●    Legal Obligation: We may be required to use information about you to comply with our legal obligations, such as to communicate legally required notices or to respond to legal process.
    ●    Consent: We may ask for consent to use information about you for specific purposes. If we do, know that you can withdraw your consent at any time. Even if we are not relying on consent to use information about you, we may still provide you with choices or ask your permission before conducting a specific processing activity.


    International Transfers: As described in the "Location of Processing" section above, we may transfer personal data from the EEA, Switzerland, or the United Kingdom to the United States and other countries. When we transfer personal data to countries that have not been deemed to provide an adequate level of protection by the European Commission, we rely on appropriate safeguards such as standard contractual clauses approved by the European Commission or other legally compliant mechanisms. You may request a copy of the safeguards we use for international transfers by contacting us at the email address provided in the Contact Information section below.


    Additional Rights: In addition to the access, correction, and deletion rights described above in the Your Rights section, you have the following rights, subject to certain limitations and exceptions allowed by law:
    ●    Restriction: You have the right to request that we restrict processing of your personal data, such as by limiting to storing but not further processing.
    ●    Data Portability: For personal data you provided to us, you have the right to request that we provide that data in a structured, commonly used and machine-readable format, and you have the right to transmit that data to another controller.
    ●    Objections: You have the right to object to our processing, such as if you object to our processing based on legitimate interests or our direct marketing.
    ●    Revocation of Consent: When our processing is based on your consent, you have the right to revoke that consent.
    ●    Cookies: You may use your browser settings to manage cookies and similar tracking technologies, as described in the "Your Choices" section above.
    ●    You may opt-out of certain uses of your personal information, such as sharing with third parties for marketing or analytics purposes, by contacting us at 


    Complaints: You may also have further rights to lodge complaints with your local data protection authority if you have concerns about the manner in which we handle your personal data. If you reside in the EEA, please see this directory for contact details. If you reside in the UK, you can contact the Information Commissioner's Office. For Swiss residents, please refer to the Office of the Federal Data Protection and Information Commissioner. 


    United States
    This section provides additional disclosures for and details about rights afforded to residents of certain US states, including, without limitation, California consumers under the California Consumer Privacy Act or "CCPA", as well as the California Privacy Rights Act or "CPRA", Colorado consumers under the Colorado Privacy Act or "CPA", Connecticut consumers under the Connecticut Data Privacy Act or "CTDPA", and Virginia consumers under the Virginia Consumer Data Protection Act or "VCDPA".

    Categories of Personal Information We Collect: The personal information we have collected in the last 12 months fall into the following categories established by the CPRA and other US state privacy laws:
    ●    identifiers (such as name, contact information and device identifiers);
    ●    personal information as described in subdivision (e) of Section 1798.80 of the California Civil Code (such as a credit card number or other payment information);
    ●    commercial information (such as Services purchased);
    ●    internet or other network activity information (such as data about how and when you use our Services);
    ●    information used to prevent and detect fraud or other unauthorized activity, including informing customers if such activity were to affect them;
    ●    demographic information (such as in response to a survey we send you);
    ●    audio, electronic, visual, thermal or similar information (such as when you communicate with us by phone or otherwise);
    ●    professional or employment-related information (such as from business contacts);
    ●    inference data (such as information about your preferences); and
    ●    other information that does not fall into any category of data described under the CCPA (such as content you upload or submit that may contain personal information).


    Categories of Sources From Which We Collect Personal Information: The above information has been collected from the following sources:
    ●    information you provide directly to us;
    ●    information we collect automatically as you use certain of our products and Services; and
    ●    information we receive from other parties.


    For more details about the personal information we collect, please see the Personal Data We Collect section above.

    Purposes for Collection: We collect personal information for the business and commercial purposes described in the Use of Your Personal Data section above.

    Sales or Sharing; Targeted Advertising and Categories of Third Parties Who May Receive Your Personal Information: We do not sell your personal information but we may disclose this information with the categories of third parties described in the Disclosure of Your Personal Data section above.


    De-identified Data: Acelab may use de-identified data in some instances. Acelab either maintains such data without attempting to re-identify it or treats such data as personal data subject to applicable law.
    Non-Discrimination: Acelab will not discriminate against any consumer for exercising their rights.
    Profiling: Acelab does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.
    Additional Rights: In addition to the access, correction, and deletion rights described above in the Your Rights section, you may have the following additional rights depending on the state in which you reside and subject to certain limitations and exceptions allowed by law:
    ●    Access in a Portable Format: When exercising your right to access your personal information, you further have the right to receive such personal information in a portable format.
    ●    Opt-Out of Sales/Sharing or Targeted Advertising: The right to opt-out of the sale or sharing of personal information or the use of your personal information for targeted advertising, depending on the state in which you reside. Please refer to the Sales or Sharing; Targeted Advertising section above for information regarding how to opt-out of such sales or sharing of personal information.
    ●    Appeal: The right to appeal any refusal by Acelab to take action on a request to exercise the rights afforded to you under applicable state law. You may exercise your right to appeal by submitting your request to appeal to Acelab via email at support@acelabusa.com. We will inform you in writing of any action taken or not taken in response to your appeal, along with a written explanation of the reasons for our decisions. If your appeal is denied, you may be entitled to contact the Attorney General in your state to submit a complaint.


    CONTACT INFORMATION
    We welcome your comments or questions regarding this Notice. Feel free to email comments or questions to us or contact us to exercise any of your rights as described herein:


    Email: support@acelabusa.com

    Mailing Address: Acelab, Inc., 12 E 49th St., 18th Floor, New York, NY 10017
    If you believe that any of your rights related to the collection or use of your personal data have been infringed upon, we encourage you to contact us using the provided contact information. We are committed to promptly investigating and working to resolve reasonable complaints and disputes.


    For individuals located in the EEA or the United Kingdom: You also have the option to directly contact our EEA and UK representative. If you want to contact our representative, please email support@acelabusa.com for representative contact information.