Information we collect
When you interact with us through the Services, we may collect from you certain personal data and other information that can identify you (“Personal Data”), as further described below:
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:
- IP address
- Unique device identifiers and device attributes, like operating system and browser type
- Usage data, such as: web log data, referring and exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used our Services, the frequency of your use of our Services, error logs, and other similar information
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 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.
Also, in an ongoing effort to better understand and serve the users of the Services, Elevate 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, but this type of non-identifiable and aggregate information does not identify you personally. 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.
Our Use of Your personal data
Elevate and its Related Companies may use this information to communicate with you regarding the Services or to tell you about services we believe will be of interest to you. If we do so, 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.
Our Disclosure of Your Personal Data and Other Information
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.
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
California User Rights
Where provided for by law and subject to any applicable exceptions, California residents may have the right:
- To know the categories of Personal Data that Elevate has collected about you, the business purpose for collecting your Personal Data, and the categories of sources from which the Personal Data was collected;
- To access the specific pieces of Personal Data that Elevate has collected about you;
- To know whether Elevate has disclosed your Personal Data for business purposes, the categories of Personal Data so disclosed, and the categories of third parties to whom we have disclosed your Personal Data;
- To have Elevate, under certain circumstances, delete your Personal Data;
- To instruct businesses that sell Personal Data to stop doing so – Elevate, however, does not sell Personal Data; and
- To be free from discrimination related to the exercise of these rights.
If you would like to exercise any or all of these rights, you may do so by contacting us as instructed below. After we receive your request, we may request additional information from you to verify your identity. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.
Scope: This section applies to individuals in the EU (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway, the United Kingdom, and, to the extent applicable, Switzerland).
Data Controller: Data protection laws in the EU differentiate between the “data controller” and “data processor” of Personal Data. Elevate is the data controller for the processing of your Personal Data relating to data collected directly from end users who visit our website or other data we collect independently from our business customers. You can find our contact information, and the contact information of our EU-based representative, in the “Contact Us” section below.
Data Processor: Elevate is the data processor for the processing of your Personal Data relating to when we are providing our service on behalf of our business customers. To exercise the rights described below in relation to when Elevate is the processor, please contact our customer that processed your Personal Data (the data controller) in order to exercise your rights.
Your Rights: Pursuant to the GDPR, you have the following rights in relation to your Personal Data, under certain circumstances and subject to any applicable exceptions:
- Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
- Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
- Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and that is processed by automated means. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
- Rights in relation to automated decision-making: You have the right to be free from decisions based solely on automated processing of your Personal Data (including profiling) which produce a significant legal effect on you, unless this is necessary in relation to a contract between you and us or you provide your explicit consent to this use.
- Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
- If we are relying on a legitimate interest to process your Personal Data -- unless we demonstrate compelling legitimate grounds for the processing or we need to process your data in order to establish, exercise, or defend legal claims;
- If we are processing your Personal Data for direct marketing. We may keep minimum information about you in a suppression list in order to ensure your choices are respected in the future and to comply with data protection laws (such processing is necessary for our and your legitimate interest in pursuing the purposes described above);
- Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your data before we received notice that you wished to withdraw consent.
- Right to lodge a complaint with the data protection authority: 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).
Please see the “Contact Us” section below for information on how to exercise your rights
Data Transfers. Elevate is based in the U.S. The U.S. may have data protection laws less stringent than or otherwise different from the laws in effect in the EU and UK. Transfers of your Personal Data to Elevate in the U.S. are necessary to perform the agreement we have entered into, or are about to enter into, with you.
Integrating Third Party Services within the Services
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.
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.
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.
Links to Other Websites
How to Contact Us
You may contact us as follows: emailing [email protected] or Elevate: Attention LEGAL; 1390 Market St, Suite 200, San Francisco, CA 94102