1. Information Provided by You
We collect information you provide directly to us, such as when you request information, request a demonstration of our Services, create or modify your personal account, request Services, complete an Elevate Security form or application, contact customer support, make a purchase or otherwise communicate with us. This information may include, without limitation: name, company name, company address, title or position with your company, date of birth, e-mail address, phone number or other personal information you choose to provide.
2. Information Collected Through Your Use of Our Services
The following are situations in which you may provide Your Information to us:
- When you fill out forms or fields through our Services;
- When you register for an account with our Service;
- When you order services or products from, or through our Service;
- When you provide the names and other identifying information for company employees;
- When you sign up for any newsletters or other materials through our Services;
- When you provide information to us through a third-party application, service or Website;
- When you communicate with us or request information about us or our products or Services, whether via email or other means;
- When you participate in online surveys;
- When you participate in any of our marketing initiatives, including, contests, events, or promotions; and
- When you participate in forums, reviews or provide user generated content or other submissions.
We also automatically collect information via the Website or App through the use of various technologies, including, but not limited to cookies and pixel tags (explained below). Certain information like email content may be forward to your employer’s Security Department. We may collect:
- your IP address,
- browsing behavior
- device IDs
- email address
- email content
- email subject
- recipient’s email
- time and date of report
This information is used by us in order to enable us to better understand how our Services are being used by visitors and allows us to apply security safeguards and administer and customize the Services to improve your overall user experience.
3. Information Collected from Other Sources
We may also receive information from other sources and combine that with information we collect through our Services. For example if you choose to link, create, or log in to your Elevate Security account with a social media service such as LinkedIn, or if you engage with a separate App, Outlook add-inor Website that uses our API, or whose API we use, we may receive information about you or your connections from that Site or App. This includes, without limitation, profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network.
4. Information Third Parties Provide
We may collect information about you from sources other than you, such as from social media websites, blogs, other users and our business partners.
5. Log Files, Cookies and Anonymous Identifiers
- Technologies such as cookies (a small file placed on your device), pixel tags, web beacons, touch heatmaps, scripts and similar technologies that create and maintain unique identifiers are used by us and our partners, affiliates, advertisers, analytics teams, or service providers. These technologies are used in analyzing trends, administering the Site, tracking user’s movements around the Site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
6. Device Information
When you use our Services through your computer, mobile phone or other device, we may collect information regarding and related to your device, such as device type, operating system version, the request type, the content of your request and basic usage information about your use of our Services, such as date and time. In addition, we may collect information regarding application-level events and associate that with your account to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.
7. Location Information
When you use the Services, we may collect your precise location data. We may also derive your approximate location from your IP address.
8. Children’s Privacy
Our Services are intended for users who are at least the age of majority in their state of residence. Furthermore, Elevate Security does not knowingly collect personally identifiable information (PII) from persons under the age of 13. If you are under the age of 13, please do not provide us with information of any kind whatsoever. If you have reason to believe that we may have accidentally received information from a child under the age of 13, please contact us immediately at firstname.lastname@example.org. If we become aware that we have inadvertently received Personal Information from a person under the age of 13, we will delete such information from our records.
9. Protective Measures We Use
We protect your information using commercially reasonable technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
10. The Legal Basis for Collection and Processing Your Personal Information
The legal basis upon which we rely for the collection and processing your Personal Information under the GDPR are the following:
- It is necessary for entering into, or performing, the obligations of a contract between you and Elevate Security, including, without limitation, the Elevate Security Master Service Agreement, and any addendums or statements of work attached thereto;
- It is necessary for our legitimate interests in the proper administration of our website and business; analyzing the use of the website and our Services; assuring the security of our website and Services; maintaining back-ups of our databases; and communicating with you.
- It is necessary for our legitimate interests in the protection and assertion of our legal rights, and the legal rights of others, including you;
- It is necessary for our compliance with certain legal provisions which may require us to process your personal data. By way of example, and without limitation, we may be required by law to disclose your personal data to law enforcement or a regulatory agency.
11. How We Use Information We Collect
Our primary purpose in collecting, holding, using and disclosing your Information is for our legitimate business purposes and to provide you with a safe, secure, smooth, efficient, and customized experience. We will not rent, sell, lease or barter your information to anyone unless you grant us explicit permission for this information to be shared.
We will use this information in order to:
- Provide users with our Services and customer support including, but not limited to, confirming emails related to our services, providing instructions, reminders, confirmations, requests for information and transactions.
- Contact you and provide you with information.
- Analyze, improve and manage our Services and operations.
- Resolve problems and disputes, and engage in other legal and security matters.
- Enforce our Elevate Security Master Service Agreement and any addendum or statement of work attached thereto.
Additionally, we may use the information we collect about you to:
- Send you communications we think will be of interest to you, including information about services, products, promotions, news, and events of Elevate Security and other companies, where permissible and according to local applicable laws.
- Display advertising, including advertising that is targeted to you or other users based on your location, interests, as well as your Elevate Security activities.
- Verify your identity and prevent impersonation, spam or other unauthorized or illegal activity including, without limitation, infringement of intellectual property rights of third parties.
12. How We Share Information We Collect
- With third party Service Providers to enable them to provide the Services you request or that we require to provide our Services, including, without limitation, an independent third-party email services provider.
- With the general public if you submit content in a public forum, such as your reviews, comments or other features of our Services that are viewable by the general public;
- With third parties with whom you choose to let us share information, for example other Websites or Apps that integrate with our API or Services, or those with an API or Service with which we integrate.
- With Elevate Security subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data verification, data centralization and/or logistics purposes;
- With affiliated entities that provide payment processing services on our behalf;
- With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;
- In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
- With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with any user agreements, policies, or to protect the rights, property, or safety of Elevate Security or others;
- In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
- 10. If we otherwise notify you and you consent to the sharing; and
- In an aggregated and/or de-identified form which cannot reasonably be used to identify you. We only use such data in the aggregate form and our analytical services do not record any personal information.
b. We may disclose Your Information:
- To any person who, in our reasonable judgment, is authorized to receive Your Information as your agent, including as a result of your business dealings with that person (for example, your attorney);
- To our third-party vendors and service providers so that they may provide support for our internal and business operations, including for the processing of payments, handling of data processing, data verification, data storage, email services, surveys, research, internal marketing, delivery of promotional, marketing and transaction materials, and our Services maintenance and security. These companies are authorized to use Your Information only as necessary to provide these services to us and are contractually obligated to keep Your Information confidential;
- As required by law or ordered by a court, regulatory, or administrative agency;
- As we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule or regulation, or are otherwise interfering with another’s rights or property, including, without limitation, our rights or property;
- If requested by authorities in the event of any act of terrorism or instance of local, regional or national emergency;
- To enforce or protect our rights.
13. Sharing Information with Law Enforcement
- Elevate Security is committed to cooperating with law enforcement while respecting each individual’s right to privacy. If Elevate Security receives a request for user account information from a government agency investigating criminal activity, we will review the request to be certain that it satisfies all legal requirements before releasing information to the requesting agency.
- Furthermore, under 18 U.S.C. §§ 2702(b)(8) and 2702(c)(4) (Voluntary Disclosure Of Customer Communications or Records), Elevate Security may disclose user account information to law enforcement, without a subpoena, court order, or search warrant, in response to a valid emergency when we believe that doing so is necessary to prevent death or serious physical harm to someone. Elevate Security will not release more information than it prudently believes is necessary to prevent harm in an emergency situation.
14. Analytic Services Provided by Others
15. Links to Third-Party Websites
16. Do Not Track Settings
17. International Privacy Practices
In order to provide our Services to you, we may send and store your personal information outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your personal information may be transferred outside of the country where you reside or are located, including countries that may not, or do not, provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred. If you reside or are located within the European Economic Area and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the European Economic Area to the extent feasible under applicable law. By using and accessing our Services, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and assume the risk that the protection of such information may be different and may be less protective than those required under the laws of their residence or location.
18. Account Information
You may correct your account information at any time by logging into your online account. If you wish to cancel your account, please email us at email@example.com Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debit on your account, or if we believe you have committed fraud or breached our Elevate Security Master Service Agreement and any addendum or statement of work attached thereto, we may seek to resolve the issue before deleting your information.
19. Promotional Information Opt Out
You may opt out of receiving promotional messages from us by following the instructions in those messages. If you opt out, we may still send you non-promotional communications, such as those about your account, about Services you have requested, or our ongoing business relations.
20. Your Access and Rights to Your Personal Information
You have certain rights in relation to Personal Information we hold about you. You can exercise any of the following rights by contacting us using any of the methods in the Contact section below.
- Right of Correction or Completion. If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data corrected or completed.
- Right of Deletion. In certain circumstances, you have the right to request that personal information we hold about you is deleted. If we cannot delete the information you want, we will let you know and explain why.
- Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your personal information. For example, you have the right to object to use of your personal information for direct marketing purposes. Similarly, you have the right to object to use of your personal information if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which supersede your rights and interests. You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.
- Withdrawal of Consent. If you have given your consent to us to process and share your Personal Information after we have requested it, you have the right to withdraw your consent at any time.
21. Your California Privacy Rights
- California Civil Code Section 1798.83 entitles California residents to request information concerning whether a business has disclosed Personal Information to any third parties for their direct marketing purposes. California residents may request and obtain from us once a year, free of charge, information about the personal information, if any, we disclosed to third parties for direct marketing purposes within the immediately preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information within the immediately preceding calendar year.
- If you are a California resident and would like to make such a request, please submit your request in writing to: firstname.lastname@example.org
22. Our Information Retention Policy
Unless you request that we delete certain information, we retain the information we collect for as long as your account is active or as needed to provide you services. Following termination or deactivation of your account, we will retain information for at least 3 years and may retain the information for as long as needed for our business and legal purposes unless explicitly requested or contractually required to delete earlier.
If you have any questions or if you would like to contact us about our processing of your personal information, including exercising your rights as outlined above, please contact us at email@example.com. When you contact us, we will ask you to verify your identity.