Privacy Policy

At Elevate Digital Solutions Ltd , d/b/a Elevate Digital (“us”, “we”, “our” or the “Company”) we value your privacy and the importance of safeguarding your data. This Privacy Policy (the “Policy”) describes our privacy practices for the activities set out below. As per your rights, we inform you how we collect, store, access, and otherwise process information relating to individuals. In this Policy, personal data (“Personal Data”) refers to any information that on its own, or in combination with other available information, can identify an individual.

We are committed to protecting your privacy in accordance with the highest level of privacy regulation. As such, we follow the obligations under the below regulations:

• Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and the applicable provincial legislations
• Quebec Law 25
• the EU’s General Data Protection Regulation (GDPR)
• Brazil’s Data Protection Legislation (LGPD)
• California’s Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA) and California Online Privacy Protection Act (CalOPPA)
• Colorado Privacy Act (CPA)
• Utah Consumer Privacy Act (UCPA)
• Connecticut Data Privacy Act (CTDPA)
• Virginia Consumer Data Protection Act (VCDPA)
• Texas Data Privacy and Security Act (TDPSA)
• Oregon Consumer Privacy Act (OCPA)
• Montana Consumer Data Privacy Act
• Delaware Personal Data Privacy Act
• Nebraska Data Privacy Law
• New Hampshire Data Privacy Act
• New Jersey Data Privacy Act
• Minnesota Consumer Data Privacy Act
• Maryland Online Consumer Protection Act
• Kentucky Consumer Data Protection Act (KCDPA)
• Tennessee Information Protection Act (TIPA)
• The Rhode Island Data Transparency and Privacy Protection Act (RIDTPPA)
• Indiana Consumer Data Protection Act (INCDPA)
• Iowa Consumer Data Protection Act (ICDPA)
• South Africa’s Protection of Personal Information Act (POPIA)

Scope

This policy applies to the Elevate Digital Solutions Ltd websites, domains, applications, services, and products.

This Policy does not apply to third-party applications, websites, products, services or platforms that may be accessed through (non-Elevate Digital Solutions Ltd) links that we may provide to you. These sites are owned and operated independently from us, and they have their own separate privacy and data collection practices. Any Personal Data that you provide to these websites will be governed by the third-party’s own privacy policy. We cannot accept liability for the actions or policies of these independent sites, and we are not responsible for the content or privacy practices of such sites.

Processing Activities

This Policy applies when you interact with us by doing any of the following:

• Make use of our application and services as an authorized user
• Visit any of our websites that link to this Privacy Statement
• Receive any communication from us including newsletters, emails, calls, or texts / SMS

What Personal Data We Collect

When you make a purchase, or attempt to make a purchase, we collect the following types of Personal Data:

This includes:

• Account Information such as your name, email address, and password
• Payment Information such as your billing address, phone number, credit card, debit card or other payment method

When you use our products and/or features, we collect the following types of Personal Data:

• Account Information such as your name, email address, and password
• Payment Information such as your billing address, phone number, credit card, debit card or other payment method

How We Collect Your Personal Data

We collect Personal Data from the following sources:

From You. You may give us your Account Information, Payment Information, Financial Information, Demographic Data, Purchase Information, Content, Feedback, Product Information, by filling in forms, using our products or services, entering information online or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide, for example, when you:

• Create an account or purchase products on our website;
• Use our products or services;
• Create content through our products or services;
• Express interest in our products or services;
• Downloading software and/or our mobile application;
• Subscribe to our newsletter;
• Complete a voluntary market research survey;
• Contact us with an inquiry or to report a problem (by phone, email, social media, or messaging service);
• When you log in to our website via social media;

Automated technologies or interactions: As you interact with our website, we may automatically collect the following types of data (all as described above): Device Data about your equipment, Usage Data about your browsing actions and patterns, and Contact Data where tasks carried out via our website remain uncompleted, such as incomplete orders or abandoned baskets. We collect this data by using cookies, server logs and other similar technologies. Please see our Cookie section (below) for further details.

Third parties: We may receive Personal Data about you from various third parties, including:

• Account Information and Payment Information from another individual when they purchase a gift for you on our website;
• Device and Usage Data from third parties, including analytics providers such as Google;
• Account Information and Payment Data from social media platforms when you log in to our website using such social media platforms;
• Content from communication services, including email providers and social networks, when you give us permission to access your data on such third-party services or networks;
• Account Information and Payment Data from third parties, including organizations (such as law enforcement agencies), associations and groups, who share data for the purposes of fraud prevention and detection and credit risk reduction; and
• Account Information, Payment Data, and Financial Data from providers of technical, payment and delivery services.

If you provide us, or our service providers, with any Personal Data relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Policy. If you believe that your Personal Data has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Data, please contact us by using the information set out in the “Contact us” section below.

Device and Usage Data

When you visit a Elevate Digital Solutions Ltd website, we automatically collect and store information about your visit using browser cookies (files which are sent by us to your computer), or similar technology. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help Feature on most browsers will provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of our Service and we recommend that you leave them turned on.

We also process information when you use our services and products. This information may include:

• IP Address
• Individual Products you view
• Web terms or searches that led you to the site

Data we collect from third parties

We may receive your Personal Data from third parties such as companies subscribing to Elevate Digital Solutions Ltd services, partners and other sources. This Personal Data is not collected by us but by a third party and is subject to the relevant third party’s own separate privacy and data collection policies. We do not have any control or input on how your Personal Data is handled by third parties. As always, you have the right to review and rectify this information. If you have any questions you should first contact the relevant third party for further information about your Personal Data. Where that third party is unresponsive to your rights, you may contact the Data Protection Officer at Elevate Digital Solutions Ltd (contact details below).

Our websites and services may contain links to other websites, applications and services maintained by third parties. The information practices of such other services, or of social media networks that host our branded social media pages, are governed by third parties’ privacy statements, which you should review to better understand those third parties’ privacy practices.

Purpose and Legal Basis for the Processing of Personal Data

We collect and use your Personal Data with your consent to provide, maintain, and develop our products and services and understand how to improve them.

These purposes include:

• To deliver your product or service
• To fulfill orders including electronic and non-electronic shipment
• Providing, Developing, and Improving our Products and Services
• Deliver, maintain, debug and improve our products and services.
• Enable you to access Elevate Digital Solutions Ltd services and set up accounts.
• Provide you with technical and customer support
• Organize and Deliver Advertising and Marketing
• Send you newsletters and other marketing communications about current and future products, programs and services, events, competitions, surveys and promotions held by us or hosted on our behalf; and
• Organize events or register attendees and schedule meetings for events.
• For research and development
• To communicate with you about the Products and Services

Where we process your Personal Data to provide a product or service, we do so because it is necessary to perform contractual obligations. All of the above processing is necessary in our legitimate interests to provide products and services and to maintain our relationship with you and to protect our business for example against fraud. Consent will be required to initiate services with you. New consent will be required if any changes are made to the type of data collected. Within our contract, if you fail to provide consent, some services may not be available to you.

Third Party Tools

We use these third party tools to store your information:

• Hubspot

International Data Transfer and Storage

Where possible, we store and process data on servers within the general geographical region where you reside (note: this may not be within the country in which you reside). Your Personal Data may also be transferred to, and maintained on, servers residing outside of your state, province, country or other governmental jurisdiction where the data laws may differ from those in your jurisdiction. We will take appropriate steps to ensure that your Personal Data is treated securely and in accordance with this Policy as well as applicable data protection law.In regions that are not considered adequate, we will enter into EU standard contractual clauses (or equivalent measures) with parties outside the EEA and ensure adequate controls are in place for the security of your data. More information about these clauses can be found here: https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32021D0914

Sharing and Disclosure

We will share your Personal Data with third parties only in the ways set out in this Policy or set out at the point when the Personal Data is collected.

We also use Google Analytics to help us understand how our customers use the site. You can read more about how Google uses your Personal Data here: https://www.google.com/intl/en/policies/privacy/

You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout?hl=en

We may also use your Personal Data to provide you with targeted marketing via advertisements or communications (such as newsletters).

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/

Legal Requirement

We may use or disclose your Personal Data in order to comply with a legal obligation, in connection with a request from a public or government authority, or in connection with court or tribunal proceedings, to prevent loss of life or injury, or to protect our rights or property. Where possible and practical to do so, we will tell you in advance of such disclosure.

Service Providers and Other Third Parties

We may use a third party service provider, independent contractors, agencies, or consultants to deliver and help us improve our products and services. We may share your Personal Data with marketing agencies, database service providers, backup and disaster recovery service providers, email service providers and others but only to maintain and improve our products and services. For further information on the recipients of your Personal Data, please contact us by using the information in the “Contacting us” section below.