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Privacy Policy

[Effective date]

[DRAFT prepared 2026-10-13 for counsel review. Not yet approved.]

Who we are

This Privacy Policy explains how EXCO Commercial, LLC ("EXCO Commercial", "we", "us") handles information in connection with this website, excocommercial.com (the "Site"). EXCO Commercial is the controller of that information. We are an EXCO Sciences company.

Scope

This policy covers the Site and the inquiry form on it. It does not cover other EXCO websites, which have their own policies, or any information exchanged after a signed confidentiality agreement, which is governed by that agreement.

Information we collect

Information you provide

When you submit the Partner With Us form we collect what you enter: your name, company, title, business email address, country or region, the market or application area you select, how you would like your inquiry directed, an optional scale or scope answer, and an optional short description of what you want to accomplish.

Information collected automatically

When you submit the form we also record which page you came from, the link you used, the pathway you selected, any campaign codes in the address you arrived with, and the address of the site that referred you (without any search terms). The Site uses a privacy-focused analytics service that counts page views and a small set of events (such as which market section was viewed or whether the form was started) in aggregate. It sets no cookies and does not identify individual visitors. The Site stores two small values in your browser session (your first-arrival campaign codes and a review setting) that are discarded when you close the tab; they are not cookies and are not sent to any third party except as part of a form submission.

Information we do not want

Please do not send us confidential, proprietary or unpublished technical information through the Site. The form says so, and our Terms of Use explain that anything submitted through the Site is treated as non-confidential. Technical detail is exchanged only after a confidentiality agreement.

How we use it and our legal bases

We use the information you submit to read and respond to your inquiry, to route it to the right person, to understand where inquiries come from, and to keep records of our commercial conversations. Where data-protection law requires a legal basis, we rely on our legitimate interest in responding to business inquiries and running a commercial website, and on the steps needed before entering into a contract with you or your organization. Analytics data is processed on the basis of our legitimate interest in understanding how the Site is used; it is aggregated and cannot be traced to you.

Who we share it with

Form submissions are delivered to our shared mailbox and are also stored by our website hosting provider, which operates the form service. We share inquiries within the EXCO group of companies where that is needed to respond to you, for example when an inquiry concerns science questions, manufacturing or intellectual property that another EXCO company handles. We use service providers for hosting, email and analytics; they process information only on our instructions. We do not sell personal information and do not share it with third parties for their own marketing. We may disclose information where the law requires it or to protect our rights.

International transfers

We are based in the United States and process information there. If you contact us from outside the United States, your information will be transferred to and handled in the United States, where privacy laws may differ from those in your country. Where required, we rely on recognized transfer mechanisms such as standard contractual clauses.

Retention

We keep inquiry records for as long as needed to respond to you and to maintain a history of our commercial conversations, and for no longer than [retention period, draft: 24 months] after our last contact unless a longer period is required by law or a business relationship follows. Aggregated analytics data contains no personal information and is kept indefinitely.

Your rights

Depending on where you live, you may have the right to access the personal information we hold about you, to have it corrected or deleted, to restrict or object to how we use it, to receive a copy in a portable form, and to complain to a supervisory authority. To exercise these rights, contact us at the address below. We will verify your request and respond within the time the law allows.

Cookies and similar technologies

The Site does not use cookies. Our analytics service is designed to operate without cookies or persistent identifiers. The two session values described above are stored by your browser only for the current tab and are never used to track you across sites.

Security

We use reasonable administrative and technical safeguards appropriate to the sensitivity of business contact information, including encrypted connections to the Site and access controls on our mailbox and hosting accounts. No method of transmission or storage is completely secure, which is one reason we ask you not to send confidential information through the Site.

Children

The Site is a business-to-business site intended for professionals. It is not directed at children, and we do not knowingly collect personal information from anyone under 16. If you believe a child has provided us information, contact us and we will delete it.

US state privacy notice

If you are a resident of California or another US state with a consumer privacy law, you may have additional rights to know what personal information we collect, to request deletion, and to be free from discrimination for exercising those rights. We do not sell or share personal information as those terms are defined under such laws, and we have not done so in the preceding 12 months. To make a request, contact us at the address below.

Changes to this policy

We may update this policy as the Site, our tools or the law change. The effective date at the top shows the current version. Material changes will be noted on this page.

Contact

Privacy questions and requests: use the form on our Partner With Us page, or write to us at the postal address below. EXCO Commercial, LLC, a [State] limited liability company, [mailing address].

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