Please see our Privacy Snapshot below for an overview of our Privacy Practices.
When you interact with us through the Services, we may collect from you certain personal information and other information that relates to or can identify you (“Personal Data”), as further described below:
Personal data that you provide through the services: We collect Personal Data from you when you voluntarily provide such information, such as when you register for access to the Services (for example email address, first name, and last name), use certain Services, contact us with inquiries, or respond to one of our surveys. This information may also include payment and transaction information when you make purchases through the Services. All payments are processed through third party payment providers, and we do not have access to full payment card information.
Personal data that we obtain through third party sources, such as social media platforms and other Third Party Services (as explained in the Integrating Third Party Services within the Services section below). We may combine this Personal Data with information we receive directly from you.
Device, usage information, and transactional data: We collect information about how you use our Services and the computers or other devices, such as mobile phones or tablets, you use to access our Services. Some examples include:
In order to collect such information, we may also use technologies such as web beacons, local storage technologies, and “cookies.” A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Services may set a cookie on your browser or device that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Services. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Services features.
to opt out of targeted advertising. If you would like to find out more information, please visit the Network
Advertising Initiative’s online resources at www.networkadvertising.org and follow the opt-out instructions
Non-identifiable or aggregated data: When you interact with Elevate through the Services, we receive and store certain non-identifiable or aggregated data. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Elevate may store such information itself or such information may be included in databases owned and maintained by Elevate affiliates, agents or service providers. The Services may use such information in Elevate’s legitimate business interests and pool it with other information to track, for example, the total number of visitors to our Services, the number of visitors to each page of our Site or game of our apps, the domain names of our visitors’ Internet service providers, and how our users use and interact with the Elevate Services.
Elevate and its Related Companies may use your Personal Data to communicate with you regarding the Services or to tell you about services we believe will be of interest to you. Except where consent is required, we undertake such communications on the basis of our legitimate business interests. Where we seek your consent, you may withdraw your consent at any time.
Elevate may use your Personal Data for compliance and protection reasons. We may use your information to comply with legal obligations, and to defend us against legal claims or disputes, including to: protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims); audit our internal processes for compliance with legal and contractual requirements and internal policies; enforce the terms and conditions that govern our Services; prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and comply with applicable laws, lawful requests, and legal process.
In an ongoing effort to better understand and serve the users of the Services, Elevate, in its legitimate business interests, often conducts research on its customer demographics, interests and behavior based on the personal data and other information provided to us. This research may be compiled and analyzed on an aggregate basis. Elevate may share this non-identifiable and aggregate data with its affiliates, agents and business partners. Elevate may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes.
Elevate is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:
Business transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
Service providers and related third parties: Elevate, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments.
Advertising partners: for the interest-based advertising purposes described above.
Legal requirements: Elevate may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Elevate, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
Delete your account: You may request that we delete your account, and any information associated with your account, but please note that we may be required (by law or otherwise) to retain certain 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 your information, it will be deleted from the active database but may remain in our archives.
Opt-out of marketing communications. Any marketing communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below. Note however that as a user of the Service you cannot opt-out of some administrative communications that are reasonably necessary to the Service, such as billing or service notifications.
Personal data requests. Subject to certain exemptions, and depending on your location and the nature of your interactions with our Services, you may request the following in relation to your Personal Data:
To exercise the above rights:
Prior to responding to your requests, we may verify your identity by matching any requested identifying information you provide against the information we have about you. Depending on your jurisdiction, you may designate an authorized agent to make a request on your behalf. We will require the authorized agent to have a written authorization confirming that authority.
We will never discriminate against you for exercising any of these rights, but you may lose access to certain functionality or the ability to interact with services due to changes in the Personal Data we have access to after complying with your privacy requests.
Right to complain. If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns (in the UK, the Information Commissioner’s Office (ICO), who can be contacted at https://ico.org.uk/concerns, and in other EU countries the data protection authority of the country in which you are located; in the US, this may be your state’s attorney general or data protection authority).
Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint or appeal by contacting us as provided in the How to Contact Us section below. Depending on your jurisdiction, if your appeal is denied, you may submit a complaint to your data protection authority as described in the Right to Complain section above.
One of the special features of the Service is that it allows you to enable various online third party services, such as social media and networking services (“Third Party Services”) to be directly integrated into your Elevate experience. To take advantage of this feature, we will ask you to provide us your username and password for the relevant Third Party Services. By enabling such Third Party Services, you are allowing us to pass your log-in information to these service providers for this purpose. When you add a Third Party Service account to the Service, we will collect your login information and other relevant information necessary to enable the Service to access that Third Party Service and your data contained within that Third Party Service. However, please remember that the manner in which Third Party Services use, store and disclose your information is governed solely by the policies of such third parties, and Elevate shall have no liability or responsibility for the privacy practices or other actions of any Third Party Service that may be enabled within the Service.
Elevate takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet, email or other electronic transmission is ever fully secure or error free, so you should take special care in deciding what information you send to us in this way.
Our Service is not directed to children who are under the age of 13. Elevate does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to Elevate through the Service please contact us and we will endeavor to delete all such Personal Data from our databases.
We are headquartered in the US. We may transfer your Personal Data to our affiliates and service providers in the US and other jurisdictions. Please note that data protection laws of the US and other jurisdictions may not be as comprehensive as those laws or regulations in your country or may otherwise differ from the laws in your country.
When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for Personal Data, and we will comply with applicable data protection laws. For example, where our Service targets individuals in the European Economic Area, Switzerland or the United Kingdom, we may rely on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of Personal Data. For more information about how we transfer Personal Data internationally, please contact us as set out in the How to Contact Us section below.
When we no longer have a need to keep your information, we will either delete it from our systems or anonymize it so that it no longer identifies you.
Elevate Labs, LLC. is the entity responsible for the processing of Personal Data and is the data controller in respect of such processing.
You may contact us as follows: emailing [email protected] or Elevate: Attention LEGAL; 1390 Market St, Suite 200, San Francisco, CA 94102.
Alternatively, if you are in the UK you can contact us by email at [email protected] or in writing to: VeraSafe United Kingdom Ltd. 37 Albert Embankment, London, SE1 7TL United Kingdom.
Alternatively, if you are in the EU you can contact us by email at [email protected] or in writing to: VeraSafe Ireland Ltd. Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork, T23 AT2P Ireland.