Privacy Policy

Last update: March 12, 2021

Our policy

Welcome to Elevate Labs, LLC. (“Elevate”, “we”, “us” and/or “our”). This privacy policy (“Privacy Policy”) has been created to provide information about our company and our mobile game applications (together with the Site (as defined below), the “Services”) to our users (“you”, “your”). The Services are provided by Elevate, Inc. (“Elevate” or “we” or “us” or “our”) located at 1390 Market St, Suite 200, San Francisco CA 94102. This Privacy Policy sets forth Elevate’s policy with respect to personal data and other information that is collected from visitors to our website located at elevateapp.com (the “Site”) and users of the Services. Your access to and use of the Services is subject to the Terms of Service.

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:

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. Wherever Elevate collects Personal Data, we make an effort to provide a link to this Privacy Policy.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to us, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Elevate and the authorized third parties referred to herein located in the United States.

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.

In operating the Services, we may also use a technology called "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. In all cases in which we use cookies, we will not collect personal data except with your permission. 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.

Our Use of Your personal data

Elevate uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data a in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. Elevate and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data to help us customize the Services or the messages you receive, improve the content and functionality of the Services, to better understand our users and to improve the Services.

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.

Related Companies: We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy.

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.

EU Users

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.

Legal Bases for Processing: This Privacy Policy (the paragraph “How We Use Personal Data”) describes the legal bases we rely on for the processing of your Personal Data. Please contact us if you have any questions about the specific legal basis we are relying on to process your Personal Data.

As used in this Privacy Policy, “legitimate interests” means our interests in conducting our business and developing a business relationship with you. This Privacy Policy describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted by law.

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.

Security

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.

Your Choices

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.

Children's Privacy

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

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by Elevate (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that Elevate endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Changes to Elevate's Privacy Policy

The Services and our business may change from time to time. As a result, at times it may be necessary for Elevate to make changes to this Privacy Policy. Depending on the type of change, we may notify you of the change by posting on this page or by email. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

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

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