Privacy Policy

This Privacy Policy explains how XL Ventures Inc, a Delaware corporation doing business as The Underlying Intent(“TUI,” “we,” “us,” or “our”), collects, uses, discloses, and protects personal information when you visit theunderlyingintent.com(the “Site”), request a roundtable invitation, participate in our podcast, subscribe to the Clarity Brief, submit a sponsorship or other inquiry, or otherwise interact with us (together, the “Services”).

We serve a global audience, including visitors in the United States, the European Economic Area (EEA), and the United Kingdom. This policy is written to meet the requirements of the EU and UK GDPR, the California Consumer Privacy Act as amended by the CPRA, and other U.S. state privacy laws that apply to you.

1. Information We Collect

Information you provide to us

We only collect what you choose to give us through our forms and communications. Depending on the form, this may include:

• Identity and contact details — name, email address, company or organization, job title, city, and LinkedIn profile.
• Program details — the information you share when you request a roundtable invitation, inquire about sponsorship, or nominate or express interest in being a podcast guest (for example, your topic, biography, pronunciation notes, topics to avoid, and any message you write to us).
• Podcast guest information — for confirmed guests, scheduling details and a recording consent confirmation.
• Newsletter preferences — the edition of the Clarity Brief you choose when you subscribe.

Information collected automatically

When you visit the Site, our hosting and email providers automatically process limited technical data such as your IP address, browser type, and the pages you request, together with any campaign parameters (for example, UTM tags) contained in the link you followed. We use this to operate and secure the Site.

Cookies and tracking. We do not currently use advertising, analytics, or cross-site tracking cookies. We do not build advertising profiles about you. If we introduce analytics or other non-essential cookies in the future, we will update this policy and, where required, request your consent first.

2. How We Use Your Information

We use personal information to:

• respond to your inquiries and follow up with you directly;
• administer our programs — executive roundtables, the podcast, sponsorships, and related events;
• send the Clarity Brief and program updates where you have asked to receive them;
• operate, maintain, secure, and improve the Site and Services;
• comply with legal obligations and enforce our terms, including preventing fraud and abuse.

3. Legal Bases (EEA / UK)

If you are in the EEA or UK, we rely on the following legal bases under the GDPR:

• Consent — for sending the Clarity Brief and other marketing emails. You may withdraw consent at any time.
• Legitimate interests — to respond to your inquiries, run our programs, and keep the Site secure, in a way that is not overridden by your rights.
• Performance of a contract — to arrange your participation once you register for a program or agree to appear as a guest.
• Legal obligation — where we must process data to comply with the law.

4. How We Share Information

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We disclose personal information only in these circumstances:

• Service providers. We use vetted providers who process data on our behalf under contract: Resend (email delivery), Sanity (content management and storage of program submissions), and Vercel (website hosting). We may also engage other providers to operate specific programs (for example, scheduling or recording tools for podcast guests), each bound by confidentiality and data-protection obligations.
• Legal and safety. Where required to comply with law, respond to lawful requests, or protect the rights, property, or safety of TUI, our users, or others.
• Business transfers. In connection with a merger, acquisition, or sale of assets, subject to this policy.

5. Data Retention

We keep personal information only as long as needed for the purposes described here. In general, we retain inquiry and program data for as long as our relationship is active and for a reasonable period afterward (typically up to 24 months of inactivity), then delete or anonymize it. We honor deletion requests sooner where required by law. Newsletter data is kept until you unsubscribe.

6. How We Protect Information

We use administrative and technical safeguards appropriate to the sensitivity of the data, including encrypted transport and access controls with our providers. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

7. International Data Transfers

We are based in the United States, and our providers may process data in the U.S. If you are in the EEA or UK, transfers of your information to the U.S. are protected by appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (and the UK Addendum) or another lawful transfer mechanism.

8. Your Privacy Rights

Depending on where you live, you may have some or all of the following rights: to access the personal information we hold about you; to request correction or deletion; to port your data; to opt out of any sale or sharing of personal information or targeted advertising (note: we do not do these); and to withdraw consent to marketing at any time.

To exercise any right, email us at contact@theunderlyingintent.com. We will verify your request and respond within the timeframe required by applicable law. You will not receive discriminatory treatment for exercising your rights. If we decline a request, you may ask us to reconsider. We also honor browser-based Global Privacy Control (GPC) opt-out signals where they apply.

EEA / UK residents may also object to or restrict certain processing and have the right to lodge a complaint with your local supervisory authority.

9. California Privacy Notice

In the past 12 months we have collected the categories of personal information described in Section 1 — identifiers, contact and professional information, and limited internet activity — directly from you and automatically through your use of the Site. We use it for the business purposes in Section 2 and disclose it only to the service providers in Section 4.

We have not sold or “shared” (as defined by the CCPA/CPRA) personal information, and we do not process sensitive personal information for purposes that require a right to limit. California residents have the rights to know, delete, correct, and opt out described in Section 8, and may use an authorized agent to submit requests.

10. Children’s Privacy

The Services are intended for business professionals and are not directed to children under 16. 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.

11. Third-Party Links

The Site links to third-party sites and platforms (such as LinkedIn). We are not responsible for their privacy practices, and we encourage you to review their policies.

12. Changes to This Policy

We may update this policy from time to time. When we do, we will revise the “Effective” date above and, for material changes, provide a more prominent notice. Your continued use of the Services after an update means you accept the revised policy.

13. Contact Us

For any privacy question or request, contact:

XL Ventures Inc (dba The Underlying Intent)
11 Apex Dr #300, Marlborough, MA 01752, USA
contact@theunderlyingintent.com