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PRIVACY POLICY

ELVTR US LLC (otherwise referred as “ELVTR”, “we”, “us” or “our”), is committed to protecting your privacy to the maximum extent possible under the applicable law.

The objective of this Privacy Policy is to describe our practices regarding the information we collect from users through our website https://elvtr.com  (the “Website”), as well as the ancillary services made available through the Website (collectively “Services”). Our Services mainly include the operation and of the ELVTR education platform, but we may expand the scope of our services as we deem fit.

This Privacy Policy sets forth the legally binding terms for your use of our Services, whether you are a “Visitor” (which means you are just accessing and browsing the Website) or a “Subscriber”, which means you have paid for any of our offered Services. Visitors and Subscribers are referred to in this Agreement as a “User” or “you”.

This Privacy Policy forms an integral part of the Terms of Use located at https://elvtr.com/terms  (the “Terms of Use”), which you, or if you have not reached the age of majority in your jurisdiction, a parent or legal guardian, must read and accept on your behalf. The Terms of Use explain your rights and responsibilities when using ELVTR’s Services. Capitalized terms not otherwise defined in this Privacy Policy have the meanings given in our Terms of Use.

BY USING OUR SERVICES, YOU CONSENT TO THE COLLECTION, TRANSFER, USE, STORAGE AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED HEREIN. IF YOU, OR YOUR PARENT/GUARDIAN ON YOUR BEHALF, DO NOT WISH TO BE BOUND BY THE TERMS OF USE, INCLUDING THIS PRIVACY POLICY, PLEASE EXIT THE SERVICES NOW AND DO NOT ACCESS OR USE ELVTR’S SERVICES.

If you have any doubts about any of your rights and obligations under this Privacy Policy, you are hereby advised not to proceed without consulting with a legal counsel. You may also contact us at privacy@elvtr.com for any additional questions.

Acceptance of the Privacy Policy

By electronically accepting, accessing or using our Services, you acknowledge that this Privacy Policy will apply to your use of our Services, and agree to be bound by the Privacy Policy which constitutes an agreement between you and ELVTR.

This Privacy Policy shall apply to all personal information transmitted by you to ELVTR, whether in the course of visiting our Website and/or using any other of our Services. This includes information that we collect via e-mail, text, audio, photos and other electronic messaging, as well as interactions between you and third-party webpages or applications that include a link to this Privacy Policy.

ELVTR is not, nor shall be in the future, responsible for the privacy rules and regulations of any third-party application, website and/or service, regardless if such third-party app, website and/or service was linked from or through our Services. The foregoing sentence shall extend also to any person employed or otherwise engaged under the payroll by such third-party.

Opting Out

ELVTR fully upholds your right to privacy and in case you decide to opt-out of tracking by ELVTR, we will fully support your decision. You can delete your account on ELVTR and/or all or any of your Personal Information stored by us or our service providers by contacting us at privacy@elvtr.com, and we will instruct you on how to proceed with your request. Please note that it will take up approximately 10 (ten) business days to process opt-out requests. Remember that the account and/or the Personal Information you requested to be deleted will be lost forever.

In case you wish not to receive any marketing communications through the our Services, you may contact us at privacy@elvtr.com, and we will instruct you on the ways to cease receiving marketing communications. If you “opt out” of these messages, you will still receive emails from us about your account, our services and other pertinent information related to our Services. These communications are considered part of the service and your account, which you cannot opt-out from receiving.

Let’s Define the term “Information”

Before we get started, it may be helpful to define some terms. There are two types of information that may be collected.

The first one is called “Personal Information”, which is personally identifiable information that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing Information.

“Anonymous Information” means information that is not associated with or linked to your Personal Information and does not, by itself, permit the identification of individual persons. Anonymous Information does not directly identify an individual or may have been personal information but has had the personally identifiable information removed. We may collect Anonymous Information about the use of our Services to help us improve them.

A Noted About Children

The Website is just for people who have reached the age of 16. We share your concern for the privacy of under-aged children and do not knowingly collect any personally identifiable information about children through the Services. We may, however, do use third party analytics services that collect anonymous information about usage of our Services.

Personal Information You Submit Us

We collect Personal Information that you directly submit to us while:

  • Subscribing for online courses;
  • Subscribing to a newsletter on our Website;
  • Requesting technical support either through our Website, by messaging us via our proprietary Learning Management System, Google Classroom via our page on Facebook, or by e-mail.

Such Personal Information may include:

  • your email address;
  • your name;
  • IP address, device type, operating system and browser type;
  • any other information you’ve decided to provide us.

We use this Personal Information for two purposes:

  1. to deliver the newsletter that you’ve subscribed for

    We use a service provider called HubSpot to deliver the newsletter, so your email address will be stored on their servers. HubSpot is a GDPR-compliant marketing automation service. Please visit their website to find more info about HubSpot or contact us at privacy@elvtr.com.

    You may always cancel your newsletter subscription at any time by clicking the ‘unsubscribe’ button in such newsletter. You can also request a permanent deletion of your email from the newsletter mailing list by sending us a request at privacy@elvtr.com.

  2. to provide you with the assistance you requested

    We do not store the information you provide us through our Website, our Page on Facebook or by email on our infrastructure. However, this information may be stored:

    • by your email provider (should you decide to contact us by email).
    • by our email provider. We use HubSpot’s email, CRM and helpdesk service to process and respond to all incoming support requests.
    • within your Facebook account (should you decide to contact us through the our
      Page on Facebook ). Click here  to learn more about Facebook’s Privacy Policy.
    • Users may disclose information about themselves by posting on the Website or on our Page on Facebook . ELVTR is not responsible for what Users say and post in these sections. In addition to being collected, such information is made public for others to see. The User is responsible for the disclosure of any such data there.

Information That we Collect Automatically When You Visit Our Website

We collect several types of Personal Information, as well as Anonymous Information (when relevant), from and about Users who visit our Website and use our Services. Such information includes:

  • traffic data;
  • your location;
  • logs and communication data;
  • resources on our Website which you access and use;
  • IP address, operating system and browser type;
  • information which is collected through cookies, web-beacons and other tracking technologies;

The technologies we use for this automatic data are further explained in our Cookie Policy.

You hereby consent that ELVTR may use the above information to analyse trends, administer our Website, track users' movement, and gather broad demographic information for statistical purposes.

Intended Use

The legal basis for the processing Personal Information and Anonymous Information in the Website includes, but is not limited to:

  • Consent. By using our Services, you hereby agree to his Privacy Policy.
  • Fulfilling our legal obligations towards you. Such as ensuring that your Personal Information is accessible to you for the purpose of using our Services.
  • Meeting our legitimate interests. Your Personal Information allows us to derive knowledge which enables us to enhance and maintain our existing Services and develop new ones.
  • Compliance with our applicable law, regulatory and audit obligations. We may retain Personal Information in case we are obliged to do so by the applicable law and/or regulatory body.

Use of Collected Information

Your Personal Information, as well as Anonymous Information (when relevant), is necessary for the following purposes:

  • to setup your account on our Services and save your settings (i.e: language, sound settings), course progress and to recognize you when you return to our Website;
  • to improve the existing Services through analysing aggregated data on how Users engage with our Services;
  • to develop new Services and tools;
  • to deliver content localized for your language;
  • to understand what kind of content is more relevant in particular areas;
  • to promptly identify and solve the technical problems our Website and Users encounter;
  • to notify you about new content and special offers;
  • to estimate the size of our target group and their user pattern;
  • to estimate the efficiency of our marketing campaigns;
  • to improve our customer services;
  • to ensure the stability and security of our Services.

You hereby consent that ELVTR may use the above information to analyse trends, administer our Website, track users' movement, and gather broad demographic information for statistical purposes.

Tracking Technologies on our Website

Google Analytics: In order to optimize our Website, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how you use this Website. The information generated by the cookie about your use of this Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. If the IP anonymization is activated on this Website, your IP address will previously be truncated by Google within the EU member states or EEA member states. Only in exceptional cases will the IP address be transferred to Google on a server in the United States and thereafter be truncated. On behalf of the website operator, Google will use this information for the purpose of evaluating your use of the Website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. The IP address that was transmitted by your browser will not be combined by Google with any other data. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this Website.

You may also prevent the collection of the data that was generated by the cookie and that is related to the use of the Website (including your IP address) as well as its processing by Google by downloading and installing a browser plugin that is available under the following link: https://tools.google.com/dlpage/gaoptout  . Additional information thereto is available at https://support.google.com/analytics/answer/6004245?hl=en  (general information to Google Analytics and privacy). Our Website uses Google Analytics with its extension code “gat._anonymizeIp()“ so that IP addresses will therefore only be processed in a shortened form to prevent persons from being identified.

Google AdWords: is another Google service that we use. This is a web analytics service, which places a cookie in your browser (“Conversion Cookie”) in case that you have accessed our Website via a Google ad. These Conversion Cookies are valid for 30 days. If you access some websites and the Conversion Cookies are still valid, we and Google can recognize that you clicked on the ad and thereafter was transferred to our Website. You shall note that every AdWords customer uses a different cookie, and therefore it is not possible to track cookies via the websites of AdWords customers. The information obtained via the Conversion Cookie is used in order to assemble conversion reports for AdWords customers. The AdWords customers receive the number of users that have clicked on their ad and have been transferred to a site that includes the Conversion Tracking tag, but they do not receive any information that would allow them to identify the user.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our Website.

Facebook Pixel: We use the “visitor action pixels” from Facebook Inc. on this Website. This allows user behaviour to be tracked after they have been redirected to our Website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual Users.

However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy  .

Facebook is certified under the US-EU Privacy Shield Agreement and thus guarantees compliance with European data protection legislation. You can allow Facebook and its partners to place ads on and off Facebook, and a cookie may also be stored on your computer for these purposes. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads in your account-settings.

HubSpot: We use HubSpot as our email, CRM and helpdesk software provider and use user their tracking code snippet. Please familiarize yourself with their cookies policies here: https://legal.hubspot.com/cookie-policy 

Webflow: We use Webflow to build and host some portions of our website. Webflow’s cookies policy is available at: https://webflow.com/legal/cookie-policy 

Sharing of Information

Without your consent, we will not rent, sell or share the personal information we have collected from you with third-parties outside ELVTR (or the group of companies of which ELVTR is or may become a part), except as described below:

  • when we believe, in good faith, that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes, or respond to lawful requests or legal authorities, including responding to lawful subpoenas, warrants or court orders;
  • to protect the rights and property of ELVTR, our agents, customers, and others (including enforcing our agreements, policies, and terms of use), or to investigate fraud, intellectual property infringement, and any other conduct that might be illegal or expose ELVTR or a user of its services to legal liability;
  • in case the disclosure is required for a third-party to assist ELVTR with the operation and/or enhancement of our Website and/or our other Services;
  • In case the Personal Information is aggregated or de-identified for the purpose of analytics, analysis, trends and the like, and no User of our Services will be individually identifiable from these aggregated and/or anonymised information and statistics;
  • in connection with, or during negotiations of, a change or proposed change in the ownership of ELVTR, i.e. when we do a business deal, or negotiate a business deal, involving sale or transfer of all or a part of our business or assets. These deals can include any sale, merger, financing, acquisition, or bankruptcy transaction or proceeding, or in any other situation where personal information may be disclosed or transferred as one of our business assets. The buyer or transferee will have to honor the commitments we have made in this Privacy Policy;
  • in case of an emergency, which includes protecting the safety of our employees and agents, our customers, or any person.

How do we Protect Your Data?

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. We continuously take steps to further improve the way we store and process Personal Data.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of Personal Information is at your own risk.

We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

It remains your own responsibility to: (i) ensure no one else uses our Services while you are "signed in" to your account; (ii) sign out from your account when not using it; and (iii) keep his password or other access information secret.

How Do We Store Your Information?

The information we collect through our Services is stored and processed on the servers located in the US and the EU, hosted by Digital Ocean, Amazon Web Services & Fastly.

The servers of our Service Providers are located in the United States, and the EU. By registering for and using the Services you consent to the transfer of information to the United States and the EU.

Data Retention and Accuracy

ELVTR retains the data collected pursuant to this Privacy Policy for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Thereafter, if the collected data is no longer needed for purposes specified in this Privacy Policy, ELVTR deletes all aforementioned data in its possession within a reasonable timeframe.

ELVTR does not verify the accuracy of Personal Data. We may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce ELVTR user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of the Services

Third-Party Terms and Conditions and Links to Other Websites

A User’s access to and use of the Services may be subject to other third-party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, social networking services and payment providers. ELVTR is not liable for any such third-party terms and conditions and their use of Users’ Personal Data.

ELVTR may, in its discretion, make available links through advertisements or otherwise enable Users to access third-party products or services. ELVTR is not responsible for the actions of such third-parties, the content of their products or services, the use of information a User provides to them, or any products or services they may offer. ELVTR’s linking to those products or services does not constitute its sponsorship of, or affiliation with, such third-parties.

Any information you provide on those websites or applications is provided directly to the owner of that website or application and is subject to that party's privacy policy. Our Privacy Policy does not apply to such websites and applications, and we are not responsible for the content or privacy and security practices and policies of those websites and applications.

Your rights according to the GDPR

General Data Protection Regulation (GDPR) (EU) 2016/679, which can be found in the following link https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679  , is a regulation in the European Union (EU) and the European Economic Area (EEA) on data protection and privacy.

With respect to your Personal Information, as being a data subject, you have the right to:

  • access your Personal Information;
  • rectify your Personal Information;
  • erase your Personal Information;
  • restrict the processing of your Personal Information;
  • restrict the portability of your Personal Information;
  • option to file a complaint against the processing of your Personal Information with the competent supervisory authority.

If you have given us your consent to the processing of your Personal Information, you can revoke the given consent at any time. You may, of course, object only to the processing of your Personal Information for advertising and data analysis purposes at any time. If you wish to do so, please send us an e-mail to privacy@elvtr.com  .

You should note that such revocation affects the admissibility of the processing of your Personal Information after you make such revocation.

In case you object for only some of our processing of your Personal Information, we kindly ask for an explanation of the reasons for the objection. In the case of your justified objection, we will examine the situation and will either discontinue or adapt the data processing or point out to you our compelling legitimate reasons based on which we continue the processing your Personal Information.

How to Contact Us About a Deceased User?

In the event of the death of ELVTR’s user, please send us an email to the following email address: privacy@elvtr.com.

How to Contact Us

If you have any questions about this Privacy Policy or the Services, please contact us at privacy@elvtr.com. We will usually conduct our communication via email. Should we require any other information, we will contact you at the email address you have provided in your request.

Effective date and Changes to Our Privacy Policy

We may change or update the Privacy Policy at any time as we add new or different features, or as the law changes. Unless another date is given, the changes are effective upon posting. Thus, you should review the Privacy Policy frequently.

The Privacy Policy detailed herein applies to any and all information that a User may have obtained from or provided to ELVTR. We reserve the right, at its full and complete discretion and without prior notice, to change, modify, amend, add, subtract, or otherwise remove portions of its Privacy Policy at any time and for any or no reason. If we make any changes, we will change the last updated date below. Although ELVTR may attempt to email Users a copy of the revised Privacy Policy at the email address on file, if any, please periodically continue to check the this Privacy Policy at https://elvtr.com/privacy  for any changes. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Such modifications will apply to disputes arising under the Privacy Policy from the date of posting forward. A User’s use of the Services after the posting of any amendments, deletions or other changes to the Privacy Policy will constitute acceptance, acknowledgment and agreement to the respective changes. If any such modification requires ELVTR to provide notice to a parent or receive parental consent, ELVTR will take the steps necessary to comply with those requirements at that time.

The effective date of this Privacy Policy is August 10, 2020. This Privacy Policy was written in English (US). To the extent any translated version of this Privacy Policy conflicts with the English version, the English version controls.