Last Updated: July 17, 2018
We at Elevatie (Elevatie Inc. and our affiliates) are committed to protecting your privacy.
In carrying out its mandates under the Privacy Act, the Personal Information Protection and Electronic Documents Act (PIPEDA), HIPAA (Health Insurance Portability and Accountability Act of 1996), General Data Protection Regulation (GDPR) (EU) 2016/679, Elevatie, Inc. collects personal information about individuals as defined by section 3 of the Privacy Act. As guardian of the privacy rights of individuals in Canada and around the world, Elevatie Inc. is committed to respecting the privacy rights of all individuals whose personal information has been collected by Elevatie Inc.
Elevatie Inc. is committed to adhere not only to the legislative requirements of the Privacy Act but in addition the above mention laws concerning the handling of personal information, but to the spirit of the Acts as well. Its objective is to balance the need to collect, retain, use, disclose and dispose of personal information about individuals with the right to privacy of those individuals, and to ensure that all individuals are aware of the circumstances under which their personal information will be collected, retained, used, disclosed, and disposed of by Elevatie Inc.
- Important Information
1.2. Contact Us
1.3. Applicable Information
- Use of the Elevatie Subscription Service Platform and our Customers
2.1. The Elevatie Subscription Service Platform
Our online Subscription Service allows any company that uses it (our customers and Elevatie itself) to create and share marketing, sales and customer service content. The Subscription Service can also be used to help organize sales and marketing data about a company’s sales or marketing (e.g., leads, customers, deals, etc.). The information added to the Subscription Service, either by site visitors providing their contact information or when a Subscription Service user adds the information, is stored and managed on our service providers’ servers. This information is then used to contact our Subscription Service users customers. Elevatie provides the Subscription Service to our customers for their feedback, getting reviews, and customer service needs, and we use it to meet Elevatie’s related needs.
2.2. Use by Elevatie
2.3. Use by Our Customers
Elevatie collects information under the direction of its customers, and has no direct relationship with the individuals whose Personal Information it processes. If you are a customer of one of our customers and would no longer like to be contacted by one of our customer that use our Subscription Service, please contact the customer that you interact with directly. We may transfer Personal Information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.
2.4. “Sensitive Information”
This refers to credit or debit card numbers, personal financial account information, Social Security numbers, passport numbers, driver’s license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other employment, financial or health information.
- Information We Collect
3.1. When You Visit our Websites
You are free to explore the Websites without providing any information about yourself. When you visit the Websites or register for the Subscription Service, we request that you provide Personal Information about yourself, and we collect Navigational Information.
3.2 When You Use our Mobile Application
We use mobile analytics software to allow us to better understand the functionality of our Mobile Apps on your mobile device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. In addition to information we collect on our Websites, when you use our Mobile Apps we may also collect your city location, device model and version, device identifier (or “UDID”), OS version, and your Elevatie Subscription Service credentials.
We send push notifications from time to time in order to update you about events or promotions. If you no longer wish to receive such communications, you may turn them off at the device level.
We may link information we store within the analytics software to Personal Information you submit within the Mobile App. We do this to improve services we offer you and improve our marketing, analytics and site functionality.
3.3. “Personal Information”
This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.
Personal Information also includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual. Navigational information refers to information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the “Navigation Information” section below. We collect and process payment information from you when you subscribe to the Subscription Service, including credit cards numbers and billing information, using third party PCI-compliant service providers. Except for this, we do not collect Sensitive Information from you.
3.4 Log Files
When you use our services our view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by Elevatie for the operation of the Subscription Service, to maintain quality of the Subscription Service, and to provide general statistics regarding use of the Elevatie Website. For these purposes, we do link this automatically-collected data to Personal Information such as name, email address, address, and phone number.
3.5. Information we collect from third parties
From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and publicly available sources such as social media websites.
3.6. Information About Children
Elevatie complies with the Child Online Privacy Protection Act (“COPPA”). Our Terms and Conditions govern our activities and your conduct in relation to COPPA. The Websites are not intended for or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. If you believe that we have collected information about a child under 13, please contact us at [email protected], so that we may delete the information.
- How We Use Information We Collect
4.2. We Never Sell Personal Information
We will never sell, rent, lease, or make available your Personal Information for use by any third party. However, we may internally use your Personal Information to improve the Websites, to improve your experience as you use the Websites, to customize and communicate informational or product offerings and promotions to you, and to make our Services more helpful or useful to other users. We may use the services of a third party to perform these functions. In addition, we may allow ad exchanges, web analytics vendors, social networking platforms and other third parties to collect certain data and other non-personally identifiable information when you visit our Site. These companies may use non-personally identifiable information (e.g., search and click stream information, browser type, time and date, the identity or type of advertisements clicked or scrolled over) during your visits to this and other web sites in order to provide advertisements about goods and services likely to be of interest to you. By way of example, these companies may use a cookie or web beacon to collect this information.
4.3. Use of Personal Information
We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party.
We use the information collected through our Subscription Service by our customers for the following purposes:
to provide the Subscription Service (which may include the detection, prevention and resolution of security and technical issues); to respond to customer support requests; and otherwise to fulfill the obligations under the Elevatie Customer Terms of Service.
Legal basis for processing Personal Information (EEA visitors only)
If you are a visitor/customer located in the European Economic Area (“EEA”), Elevatie Ireland Limited is the data controller of your personal information. Elevatie’s Data Protection Officer can be contacted at [email protected].
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
4.4. Use of Navigational Information
We use Navigational Information to operate and improve the Websites and the Subscription Service Platform. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about Elevatie.
4.5. Customer Testimonials and Comments
We may post customer testimonials and comments on our Websites, which may contain Personal Information. We obtain each customer’s consent via email prior to posting the customer’s name and testimonial.
4.6. Use of Credit Card Information
If you give us credit card information, we use it solely to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.
4.7. Service Providers
We may employ other companies and people to provide services to visitors to our Websites, our customers, and users of the Subscription Service Platform and may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.
4.8. Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.
4.9. Social Media Features
4.10. External Websites
4.11. Help Centre
We offer a publicly accessible help centre for our customers. Please keep in mind that if you directly disclose any information through our public help centre, this information may be collected and used by others. We will correct or delete any information you have posted on the Websites if you so request, as described in “Opting Out and Unsubscribing” below.
4.12. Retention of Personal Information
How long we keep information we collect about you depends on the type of information. As described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about the Subscription Service or our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymise it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request, as described in “To Unsubscribe from Our Communications'” below.
If you provide information to our customers as part of their use of the Subscription Service, our customers decide how long to retain the personal information they collect from you. If a customer terminates its use of the Subscription Service, then we will provide customer with access to all information stored for the customer by the Subscription Service, including any Personal Information provided by you, for export by the customer according to our agreement with our customer. After termination, we may, unless legally prohibited, delete all customer information, including your Personal Information, from the Subscription Service.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your Elevatie account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
4.13. International Transfers within Elevatie’s Entities
To facilitate our global operations, we transfer information to either Canada or the United States and allow access to that information from countries in which the Elevatie affiliated entities have operations for the purposes described in this policy.
4.14. International Transfers to Third Parties
4.15. Privacy Shield Notice
Elevatie participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework. The following affiliated entities adhere to the Privacy Shield principles: Elevatie Inc is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov.
Elevatie is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Elevatie complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Elevatie is subject to the regulatory enforcement powers of the Canadian Government. In certain situations, Elevatie may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
You may direct any inquiries or complaints related to our Privacy Shield compliance to [email protected]. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
4.16. Corporate Events
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Elevatie on the Websites and the Subscription Service Platform. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
4.17. Compelled Disclosure
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
4.18. Assignment of Rights to Information
In the event of the sale, acquisition, or merger of Elevatie, Inc. or of all or substantially all of its assets, and in the event of any other change of control of Elevatie, your Personal Information, Received Materials, and Uploaded Materials, in addition to all other information possessed by Elevatie may be transferred, sold, or shared in connection with such transaction. In that event, your Personal Information will still be subject to the same protections as provided herein.
4.19. Cooperation with Authorities Consent to Canadian Processing
Elevatie complies with all applicable laws and regulations. This may require cooperation with governmental authorities with respect to information we’ve receive from you. If we believe it is necessary, in our sole discretion, to disclose information about you to law enforcement officials or in connection with a court proceeding, you hereby consent to such disclosure. In addition, if we believe a disclosure of such information is necessary to protect our property and rights, to protect public safety, or to prevent potentially illegal or unethical conduct, we may disclose certain information, and you consent to such disclosure. If you reside outside of Canada, your local laws may afford a higher degree of protection to your Personal Information than provided under Canadian law. Your use of the Website constitutes your consent to have your Personal Information transferred to, collected by, and processed by our servers located and not inclusive to the continent of The United States & Canada.
- Navigational Information
We use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web server. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a Web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize pages on our Websites, or register for the Subscription Service, a cookie helps us to recall your specific information on subsequent visits. When you return to the same Website, the information you previously provided can be retrieved, so you can easily use the customized features.
As stated above you have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Elevatie Subscription Service Platform or Websites you visit. Elevatie keeps track of the Websites and pages you visit within Elevatie, in order to determine what portion of the Elevatie Website or Subscription Service Platform is the most popular or most used. This data is used to deliver customized content and promotions within the Elevatie Website and Subscription Service Platform to customers whose behavior indicates that they are interested in a particular subject area.
5.2. Clear Gifs (Web Beacons/Web Bugs)
We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage the Website and Subscription Service by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages or in emails and are about the size of the period at the end of this sentence. We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. We tie the information gathered by clear gifs in emails to our customers’ Personal Information. If you would like to opt-out of these emails, please see “Opting Out and Unsubscribing”.
5.3. Navigational Information Collected by Our Customers
Our customers can use the tools we provide, as well as tools provided by third parties, to collect Navigational Information when you visit their webpages on the Subscription Service. Elevatie does not control our customers’ use of these tools, nor do we control the information they collect or how they use it.
5.4. Single Sign-On
You can log in to our site using a Single Sign-on (SSO) service like your Google or Facebook account. This service will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Such services may give you the option to post information about your activities on this Web site to your profile page to share with others within your network.
5.6. Third Party Tracking Technologies
- Opting Out and Unsubscribing
6.1. Reviewing, Correcting and Removing Your Personal Information
Upon request Elevatie will provide you with information about whether we hold any of your Personal Information. If you provide us with your Personal Information, you have the following rights with respect to that information:
To review the user information that you have supplied to us
To request that we correct any errors, outdated information, or omissions in user information that you have supplied to us
To request that your user information not be used to contact you
To request that your user information be removed from any solicitation list that we use
To request that your user information be deleted from our records
To opt out of being solicited by Elevatie or third parties
To exercise any of these rights, please contact us by email at [email protected] or by mail to Elevatie Inc. PO BOX 87053 Douglas Square RPO Calgary, AB T2Z 3V7 Canada, Attn: Privacy.
We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
6.2. Anti-Spam Policy
Our Acceptable Use Policy, at at https://elevatie.com/acceptable-use, applies to us and to our customers and, among other things, prohibits use of the Subscription Service to send unsolicited commercial email in violation of applicable laws, and requires the inclusion in every email sent using the Subscription Service of an “opt-out” mechanism and other required information. We require all of our customers to agree to adhere to the Acceptable Use Policy at all times, and any violations of the Acceptable Use Policy by a customer can result in immediate suspension or termination of the Subscription Service.
6.3. To Unsubscribe From Our Communications
We adhere to the Canadian Anti-Spam legislation which can be found here and our clients are informed to ensure they have obtained consent orally or written from their customers. In addition, we adhere to the Compliance and Enforcement Information Bulletin CRTC 2012-548. Together we can stop spam and unlawful advertising. If you felt like you didn’t subscribe to any of our services and wish us to stop sending offers and promotions to you, you may unsubscribe at any time by clicking unsubscribe on our digital material or contacting [email protected]. Instructions for unsubscribing from promotional campaigns are usually included in the footer of any messages. Customers cannot opt out of receiving transactional emails related to their account with us or the Subscription Service.
6.4. To Unsubscribe from Our Customers’ Communications
Our customers are solely responsible for their own marketing emails, and other communications; we cannot unsubscribe you from their communications. You can unsubscribe from our customers’ marketing communications by clicking on the “unsubscribe” link located on the bottom of their emails, or by contacting them directly.
6.5. Deleting Your Information
If you have registered with us, you may delete the Personal Information in your account by contacting us at [email protected]. We will make commercially reasonable efforts to delete such information upon request. We may archive all or some of your Personal Information as we believe may be required by law or for legitimate business purposes.