Elevate Higher, Inc.
Privacy Policy
Elevate Higher, Inc. (“Elevate” or the “Company”) is committed to protecting the privacy of individuals who visit our website, including but not limited to www.elevatehigher.io as well as individuals who register to use our Services as defined below or who register to attend Elevate events.
This Privacy Policy describes how and why Elevate collects, uses, and shares the personal information we receive or that you make available to us by using our website, services, events, and programs offered by Elevate (collectively, the “Services”). It also describes the choices available to you regarding Elevate’s use of your personal information, the steps you can take to access this information and, where applicable, to request that we correct or delete it. We can be contacted by using the details in the “How to contact us” section below.
Elevate may also provide further privacy notices based on applicable regions and with respect to other interactions with you (for example, specific services requests). Those terms are to be read in conjunction with this Privacy Policy.
Topics:
Personal information we collect
Elevate collects personal information in a variety of ways described in this Privacy Policy. The types of personal information that we collect will depend on how you interact with us, your location, and applicable law. In addition to any other privacy notices you might have received, Elevate has collected the following types of information:
Employees, Independent Contractors, Interns, Volunteers and Candidates
The following personal information may be collected regarding employees, independent contractors, interns, volunteers, and candidates for these positions:
Additional contact details and other identifiers: Elevate may collect residency and work permit status, Social Security Number (SSN), driver’s license number, government identification numbers and/or other similar identifiers.
Protected classifications and other demographic data: age, gender, race, ethnicity and/or similar demographic information. We will use this information to comply with anti- discrimination laws and government reporting obligations, to help ensure equal employment opportunities and/or to conduct internal research on company demographics.
Background information: professional qualifications, education, CV/resume, credit history and/or civil/criminal records data (utilized for background check and vetting purposes where permissible and in accordance with applicable law).
Location data: physical location (e.g. city, state, country).
Elevate Program Participants
When you become an Elevate Program Participant, we may ask you for additional personal information which may include:
Account credentials: username, password, and similar account authentication information.
Financial information: credit card, billing, bank account details, and other payment information.
How we collect personal information
Elevate collects personal information about you when you provide us with your personal information. Examples include when you register with our website, enter into a contract with us for Services, or when you voluntarily provide personal or business details via online or paper application forms and surveys.
How we use personal information
Elevate uses personal information to operate, manage, and improve our Services and website. Elevate may use the personal information we collect to:
Fulfill your requests
When you make requests of Elevate, we will use the information you provided to fulfill these requests. For example, if you share contact and business information to request more details about our Services, we will use that personal information to respond to your inquiry.
Provide Services
If you are an Elevate Program Participant, your personal information is used to administer your account and enable you to connect with fellow Elevate Program Participants.
Operate, maintain and improve our Website
Elevate will record your use of our website to operate and improve our website, thus helping us to better understand your needs and interests. Elevate uses certain tools to improve and personalize your experience (e.g. Google Analytics).
Communicate with you
Your personal information may also be used to send additional information about Elevate’s Services, updates, promotions, and events (“Communications”) unless you opt out from receiving such Communications. We will seek your advance permission to send Communications if legally required.
General business and legal obligations
Elevate also collects personal information described above to conduct audits, comply with our legal obligations, resolve disputes, and enforce our agreements.
The personal information you have provided to Elevate is used for the purposes described in this Privacy Policy or for purposes disclosed in a separate privacy notice.
How we share personal information
Elevate may share your personal information with affiliates for business purposes related to customer support, technical operation, and/or account management.
We may also make your personal information available to authorized third parties or service providers for Elevate business purposes, such as acting on our behalf to assist in providing Services, technical support, account management, and payment processing.
These authorized third parties are permitted to use your personal information solely for the purpose of providing their services to Elevate. We will not otherwise share your personal information with other individuals or companies except when you have otherwise authorized this information to be shared, in circumstances required by law, in the exercise of our legal rights, to investigate, prevent, or take action regarding actual or suspected illegal or malicious activities, or to address actual or suspected violations of Elevate’s Terms of Use.
Elevate does not sell personal information about you.
How long we keep personal information
Elevate retains your personal information for the duration of the time that is consistent with the original purpose of collection. For example, we may retain your personal information while your account to use our website or Services is active. We may also retain personal information for a period of time thereafter to:
allow for the recovery of accounts if requested by you,
analyze the data for Elevate’s business operations, and/or
conduct audits, address our ongoing legal rights/obligations, resolve disputes, and enforce our agreements.
Our legal basis for processing personal information
Elevate may rely on various legal means or legal bases for collecting and processing personal information, including:
your consent (where necessary),
a legitimate interest,
necessity to enter into and perform contracts, and
to comply with our legal obligations.
The legal bases Elevate is required to use in order to collect and use your personal information will depend on your interaction with us, applicable law and your location.
International transfer of information collected
Elevate has its global headquarters in the United States and Elevate’s primary storage of personal information collected is in the United States. Depending on where you are located and applicable law, Elevate will rely on certain legal bases to transfer your personal information into the United States such as: your consent (if required), to perform a contract with you, or to fulfill Elevate’s legitimate interest which does not outweigh your rights and freedoms.
We take precautions to keep your personal information secure. Where necessary to comply with applicable law, Elevate also enters into data processing agreements and model clauses with its authorized third parties and service providers.
How to access and control your personal information
Your rights to access and control your personal information may vary depending on your location and applicable law. If you are a European resident, see the “European residents” section below for specific details.
To learn how to exercise your rights under this Privacy Policy, see the “How to exercise your rights” section below. In general, since Elevate provides services around the world, we acknowledge the following core privacy rights:
Access to your personal information
You have the right to request disclosure of certain information to you about our collection and use of your personal information. Any limits or exceptions under applicable law will be explained in our response to your verified request.
Deletion request rights
You have the right to request deletion of your personal information that Elevate collected and retained. Upon receipt of your verifiable request, we may delete (and direct our service providers to delete) your personal information from our records to the extent required by law. There are certain exceptions where applicable law either allows or requires us to deny your deletion request. Such a denial will be explained in our response to your verifiable request.
European residents
You have the right to be informed about our processing of your personal information as well the right to restrict or object to certain processing. You may also request information about: the processing purposes, the category of personal data, the categories of recipients to whom your data has been disclosed, the source if not collected directly from us, or the planned storage period. You also have the right to correct (rectify), delete, limit, or oppose the processing of your personal information.
If you have unresolved concerns that we have not addressed satisfactorily related to how we are processing your personal information, please contact the EU Data Protection Authorities.
No discriminatory treatment
When you choose to exercise your privacy rights listed in this section, you will not receive any discriminatory treatment from Elevate. This is not only a legal requirement, but it is in line with Elevate’s operational principal of “respect for the individual.”
How to exercise your rights
To exercise the rights described above, please submit a verifiable request to us by either contacting us using the information in the “How to contact us” section below.
Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. Elevate must be able to verify such requests through the exercise of reasonable diligence. To be verifiable your request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request. We will use personal information provided in a request solely for the purpose of verifying the requestor's identity or authority to make the request.
Communication preferences
You may manage your receipt of Communications via email by opting out of Communications by emailing us at: privacy@elevatehigher.io.
Elevate may retain some of your personal information solely for the purposes of knowing your wish to not be contacted again in the future, or for other purposes that are legally permitted or required.
Changes to this Privacy Policy
Elevate may update this Privacy Policy at any time, for any reason, without notice to you other than posting the amended Privacy Policy to our website. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary e-mail address we have on file for you or by placing a prominent notice on our website.
Elevate endeavors to ensure that this Privacy Policy is fully compliant with all applicable laws, however, the laws throughout the world are constantly evolving and changing. To the extent any part of this Privacy Policy is not compliant with applicable law, the non-compliant part shall be deemed automatically amended to the extent necessary to permit this Privacy Policy to be compliant.
How to contact us
Elevate has appointed a Data Protection Officer (DPO) who is responsible for overseeing questions related to this Privacy Policy. If you have any questions, please contact the DPO by emailing us at: privacy@elevatehigher.io.