Privacy Policy

This Privacy Policy was last updated on March 23, 2023. Thank you for engaging with Elevify. Elevify (Elevify, we, the Company) respects users’ privacy and wants everyone to understand how we collect, use, and share user data. This Privacy Policy covers our data collection practices and describes users’ rights regarding their personal data. Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use Elevify’s websites, mobile applications, APIs, or related services (the Services). It also applies to prospective customers of our professional or enterprise products. By using the Services, you agree to the terms of this Privacy Policy. Do not use the Services if you do not agree with this Privacy Policy or any other agreement that governs your use of the Services.

Index

• 1. Types of Data Collected
• 2. How We Collect User Data
• 3. Purposes for Using User Data
• 4. With Whom We Share Your Data
• 5. Security
• 6. User Rights
• 7. Updates and Contact Information

1. Types of Data Collected

We collect certain data directly from users, such as information you enter, data about your consumption of content, and data from third-party platforms to which you connect with Elevify. We also collect some data automatically, such as information about your device and which parts of our Services you interact with or use. All data listed in this section are subject to the following processing activities: collection, recording, structuring, storage, alteration, retrieval, encryption, pseudonymization, deletion, combination, and transmission.

1.1 Data Provided by the User

We may collect different data about you, or provided by you, depending on how you use the Services. Here are some examples to help you better understand the data we collect. When you create an account and use the Services, including through a third-party platform, we collect all data you provide directly, including:

Account Data

To use certain features (such as accessing content), you need to create a user account, which requires collecting and storing your email address, password, and account settings. As you use certain features on the site, you may be asked to submit additional information, such as occupation, government-issued identity information, verification photo, date of birth, race/ethnicity, skill interests, and phone number. After your account is created, we assign you a unique identification number.

Legal Basis for Processing:

1. Contract performance
2. Legitimate interests (service provisioning, identity verification, security and fraud prevention, communication)

Profile Data

You may also choose to provide profile information, such as a photo, headline, biography, language, website link, social media profiles, country, or other data. Your Profile Data may be publicly viewable by others.

Legal Basis for Processing:

1. Contract performance
2. Legitimate interests (enhanced platform functionality, attribution of content origin)

Shared Content

Certain parts of the Services allow you to interact with other users or share content publicly, including by uploading responses and other educational content, posting reviews about content, questions or answers, sending messages to learners or mentors, or posting photos or other work you submit. Such shared content may be publicly viewable by others depending on where it is posted.

Legal Basis for Processing:

1. Contract performance
2. Legitimate interests (service provisioning, enhanced platform functionality)

Learning Data

When you access content, we collect some data, including which courses, assignments, labs, workspaces, and tests you start and complete; purchased subscriptions and content and credits; subscriptions; certificates of completion; interactions with mentors, teaching assistants, and other learners; and essays, quiz answers, and other items submitted to satisfy course and related content requirements.

Legal Basis for Processing:

1. Contract performance
2. Legitimate interests (service provisioning, enhanced platform functionality)

Learner Payment Data

When you make purchases, we collect certain data about that purchase (such as name, billing address, and ZIP/postal code) when necessary to process the order, which may be saved to process future orders. You must provide certain payment and billing data directly to our payment processing partners, including your name, credit card information, billing address, and ZIP/postal code. We may also receive limited information from these partners to facilitate payments, such as notice that you have a new card and the last four digits of that card. For security reasons, Elevify does not collect or store sensitive cardholder data, such as the full credit card number or card authentication data.

Legal Basis for Processing:

1. Contract performance
2. Legal obligation
3. Legitimate interests (payment facilitation, security and fraud prevention, compliance)

Data About Your Accounts on Other Services

We may obtain certain information via your social network accounts or other online accounts if they are connected to your Elevify account. If you connect to Elevify via Facebook or another third-party platform or service, we request your permission to access certain information about that other account. For example, depending on the platform or service, we may collect your name, profile photo, account ID number, login email address, location, the physical location of your access devices, gender, birthday, and list of friends or contacts. These platforms and services make information available to Elevify through their APIs. The information we receive depends on what information you (through your privacy settings) or the platform or service decide to provide to us. If you access or use our Services through a third-party platform or service or click on third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of those third parties.

Legal Basis for Processing:

1. Legitimate interests (identity verification, improving user experience)

Sweepstakes, Promotions, and Surveys

We may invite you to complete a survey or participate in a promotion (such as a contest, sweepstakes, or challenge), either through the Services or via a third-party platform. If you participate, we will collect and store the data you provide as part of your participation, such as name, email address, mailing address, date of birth, or phone number. Unless otherwise stated in the official rules of the promotion or another privacy policy, this data is subject to this Privacy Policy. The collected data will be used to administer the promotion or survey, including to notify winners and distribute prizes. To receive a prize, we may need your permission to publicly disclose some of your information (such as on a winners page). When we use a third-party platform to administer a survey or promotion, that third party’s privacy policy applies.

Legal Basis for Processing:

1. Contract performance
2. Legitimate interests (administration of promotions, prize fulfillment, compliance)

Communications and Support

If you contact us for support or to report a problem or inquiry (whether or not you have created an account), we collect and store your contact information and messages and other data about you, such as name, email address, messages, location, Elevify user ID, refund transaction IDs, and any other data you provide or that we collect by automated means (described below). This data will be used to respond to you and research your inquiry, in accordance with this Privacy Policy.

Legal Basis for Processing:

1. Legitimate interests (technical and customer support)

The data listed above are stored by Elevify and associated with your account.

1.2 Data Collected by Automated Means

When you access the Services (including browsing content), we collect certain data by automated means, including:

System Data

Technical data about your computer or device, such as IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain, and other system data and platform types.

Legal Basis for Processing:

1. Contract performance
2. Legitimate interests (service provisioning, technical and customer support, security and fraud prevention, communication, product improvement)

Usage Data

Usage statistics about your interactions with the Services, such as content accessed, time spent on pages or the Service, pages visited, features used, search queries, click data, date and time, referrer, and other data regarding your use of the Services.

Legal Basis for Processing:

1. Legitimate interests (service provisioning, improving user experience, product improvement)

Approximate Geographic Data

Approximate geographic location, which includes information such as country, city, and geographic coordinates, calculated based on your IP address.

Legal Basis for Processing:

1. Legitimate interests (improving user experience, security and fraud prevention, compliance)

The data listed above are collected through server log files and tracking technologies, as detailed in the Cookies and Data Collection Tools section below. The data are stored by Elevify and associated with your account.

1.3 Third-Party Data

If you are an enterprise customer or prospect of Elevify, in addition to the information you submit to us, we may collect certain contact information from third-party business sources.

2. How We Collect User Data

We collect certain data directly from users, such as information you enter, data about your consumption of content, and data from third-party platforms to which you connect with Elevify. We also collect some data automatically, such as information about your device and which parts of our Services you interact with or use. All data listed in this section are subject to the following processing activities: collection, recording, structuring, storage, alteration, retrieval, encryption, pseudonymization, deletion, combination, and transmission.

2.1 Cookies and Data Collection Tools

We use cookies, which are small text files stored by your browser, to collect, store, and share data about your activities across websites, including Elevify. Cookies allow us to remember details about your visits to Elevify, such as your preferred language, and make the site easier to use. We may also use clear pixels in emails to track delivery and open rates. Elevify and service providers acting on Elevify’s behalf (such as Google Analytics and third-party advertisers) use server log files and tools for automated data collection, such as cookies, tags, scripts, custom links, device or browser fingerprinting, and web beacons (collectively, Data Collection Tools), when you access and use the Services. These Data Collection Tools track and automatically collect certain System Data and Usage Data (detailed in Section 1) when you use the Services. In some cases, we associate the data collected through Data Collection Tools with other data we collect, as described in this Privacy Policy.

2.2 Why We Use Data Collection Tools

Elevify uses the following types of Data Collection Tools for the purposes described:

• Strictly Necessary: These Data Collection Tools enable you to access the site, provide basic functionality (such as logging in or accessing content), protect the site, protect against fraudulent logins, and detect and prevent abuse or unauthorized use of your account. These are necessary for the Services to work properly, so if you disable them, parts of the site will break or be unavailable.
• Functional: These Data Collection Tools remember data about your browser and preferences, provide additional functionality on the site, personalize content to make it more relevant to you, and remember settings that affect the appearance and behavior of the Services (such as your preferred language or video playback volume).
• Performance: These Data Collection Tools help assess and improve the Services by providing usage and performance data, visit counts, traffic sources, or the location from which an app was downloaded. These tools help us test different versions of Elevify to see which features or content users prefer and to determine which email messages are opened.
• Advertising: These Data Collection Tools are used to display relevant ads (on the site and/or on other sites) based on information known about you, such as System Data and Usage Data (as detailed in Section 1), and information advertising service providers know about you based on tracking data. Ads may be based on your recent or historical activity on other sites and services. To help display personalized advertising, we may provide service providers with an anonymized, hashed version of your email address (in a human-unreadable format) and the content you publicly share on the Services.
• Social Media: These Data Collection Tools enable social media functionality, such as sharing content with friends and contacts. These cookies can track a user or device across sites and create a profile of user interests for targeted advertising.

You can configure your web browser to alert you when attempts are made to place cookies on your computer, limit the types of cookies allowed, or refuse cookies altogether. If you do, some or all features of the Services may not be usable, and your experience may differ or be less functional. To learn more about managing Data Collection Tools, see Section 6.1 (User Options Regarding the Use of Your Data) below.

3. Purposes for Using User Data

We use user data for purposes such as providing our Services, communicating with you, troubleshooting, protecting against fraud and abuse, improving and updating our Services, analyzing how people use our Services, delivering personalized advertising, as required by law, or as necessary for safety and integrity. Data are retained for as long as necessary to fulfill the purposes for which they were collected. Data collected when you use the Services are used to:

• Provide and administer the Services, including facilitating participation in educational content, issuing certificates of completion, displaying personalized content, and facilitating communication with other users (Account Data; Shared Content; Learning Data; System Data; Usage Data; Approximate Geographic Data);
• Process your requests and orders for educational content, products, specific services, information, or resources (Account Data; Learning Data; Learner Payment Data; System Data; Communications and Support);
• Communicate with you about your account (Account Data; Shared Content; Learning Data; Sweepstakes, Promotions, and Surveys; System Data; Communications and Support):
• Respond to your questions and inquiries;
• Send messages and administrative information, messages to learners and teaching assistants; notifications about changes to our Service; and updates to our agreements;
• Send you information by email or text message about your progress in courses and related content, rewards programs, new services, new features, promotions, and newsletters (which you can opt out of at any time);
• Send push notifications to your wireless device to provide updates and other relevant messages (manageable on the mobile app’s options or settings page);
• Facilitate the technical functioning of the Services, including identifying and resolving issues, protecting the Services, and preventing fraud and abuse (Account Data; Learner Payment Data; Communications and Support; System Data; Approximate Geographic Location);
• Solicit user feedback (Account Data; Communications and Support);
• Market products, services, surveys, and promotions (Account Data; Learning Data; Sweepstakes, Promotions, and Surveys; Usage Data; Cookie Data);
• Market Subscription Plans to prospective customers (Account Data; Learning Data; Cookie Data);
• Learn more about you by linking your data to other data via third-party data providers and/or analyzing the data with the help of analytics service providers (Account Data; Data About Your Accounts on Other Services; Usage Data; Cookie Data);
• Identify unique users across devices (Account Data; System Data; Cookie Data);
• Personalize advertising across devices (Cookie Data);
• Improve our Services and develop new products, services, and features (all data categories);
• Analyze trends and traffic, track purchases, and track usage data (Account Data; Learning Data; Learner Payment Data; Communications and Support; System Data; Usage Data; Approximate Geographic Data; Cookie Data);
• Advertise the Services on third-party websites and apps (Account Data; Cookie Data);
• As required or permitted by law (all data categories); or
• As Elevify, in our sole discretion, determines necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services (all data categories).

You can configure your web browser to alert you when attempts are made to place cookies on your computer, limit the types of cookies allowed, or refuse cookies altogether. If you do, some or all features of the Services may not be usable, and your experience may differ or be less functional. To learn more about managing Data Collection Tools, see Section 6.1 (User Options Regarding the Use of Your Data) below.

4. With Whom We Share Your Data

We share certain data about you with other learners, companies that provide services to Elevify, Elevify affiliates, our business partners, analytics and data enrichment providers, your social media providers, companies that help us run promotions and surveys, and advertising companies that help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Finally, we may share data in other ways if it is aggregated or de-identified, or if we obtain your consent.

We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:

• With other Learners: Depending on your settings, shared content and profile data may be publicly viewable, including by other learners. If you ask a question to an instructor or a teaching assistant, your information (including name) may also be publicly viewable. (Account Data; Profile Data; Shared Content.)
• With service providers, contractors, and agents: We share your data with third-party companies that provide services on our behalf, such as payment processing, fraud and abuse prevention, data analysis, marketing and advertising services (including retargeted advertising), email services and hosting, and customer care and support. These service providers may access your personal data and are required to use it only as directed by Elevify to provide the requested service. (All data categories.)
• With Elevify Affiliates: Your data may be shared with our corporate group of companies, related by common ownership or control, to enable or support the provision of the Services. (All data categories.)
• With Business Partners: We maintain contracts with other sites and platforms to distribute our Services and increase traffic to Elevify. Depending on your location, we may share your data with these trusted partners. (Account Data; Learning Data; Communications and Support; System Data.)
• With Organizations Granting Continuing Education Credit: If you take a course to meet a continuing professional education requirement, we may share that information upon request of the organization granting continuing education credit. (Account Data; Learning Data.)
• With Analytics and Data Enrichment Services: As part of our use of third-party analytics tools, such as Google Analytics, and data enrichment services, such as ZoomInfo, we share certain contact information or de-identified data. De-identified data means data from which information such as your name and email address has been removed and replaced with a token ID. This allows providers to deliver analytics services or combine your data with information from publicly available databases (including contact and social information from other sources). The goal is to communicate with you more effectively and personally. (Account Data; System Data; Usage Data; Cookie Data.)
• To Enable Social Media Features: Social media features included in the Services (such as the Facebook Like button) may allow the social media provider to collect information such as your IP address and which page of the Services you are visiting, and to set a cookie to enable the feature. Your interactions with these features are governed by the third-party company’s privacy policy. (System Data; Usage Data; Cookie Data.)
• To Administer Promotions and Surveys: We may share your data as necessary to administer, market, or sponsor promotions and surveys in which you choose to participate, as required by applicable law (for example, providing a winners list or making required filings) or in accordance with the rules of the promotion or survey. (Account Data; Sweepstakes, Promotions, and Surveys.)
• For Advertising: If we decide to use an advertising-supported revenue model in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools (as detailed in Section 2.1) and use that data to provide targeted ads to personalize your experience (via behavioral advertising) and perform web analytics. Advertisers may also share with us data they collect about you. To learn more or opt out of behavioral advertising from participating ad networks, see Section 6.1 (User Options Regarding the Use of Your Data) below. Note that if you opt out, you will continue to receive generic ads. (System Data.)
• For Security and Legal Compliance: We may disclose your data (all data categories) to third parties if (in our sole discretion) we believe in good faith that the disclosure is:
• Requested as part of an investigation, order, or judicial, governmental, or legal process;
• Reasonably necessary as part of a valid subpoena, warrant, or other legally valid request;
• Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
• Necessary to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rules or regulations), or technical or security issues;
• Reasonably necessary, in our judgment, to protect against imminent harm to the rights, property, or safety of Elevify, our users, employees, the public, or our Services;
• We may also disclose data about you to our auditors and legal advisors to assess our disclosure obligations and rights under this Privacy Policy; or
• As required or permitted by law.
• In Cases of Transfer of Control: If Elevify undergoes a business transaction, such as a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or part of its assets, we may share, disclose, or transfer all user data to the successor organization during the transition or in contemplation of a transition (including during an audit). (All data categories.)
• After Aggregation/De-identification: We may disclose or use aggregated or de-identified data for any purpose.

With User Permission: With your consent, we may share data with third parties outside the scope of this Privacy Policy. (All data categories.)

5. Security

Elevify adopts appropriate security measures to protect against unauthorized access to, alteration, disclosure, or destruction of the personal data we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secure, so we cannot guarantee that communications between you and Elevify, the Services, or any information provided to us in connection with data we collect through the Services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with third parties, and if you believe your password or account has been compromised, you should change it immediately and contact our Support team.

6. User Rights

You have certain rights regarding the use of your data, including the ability to opt out of receiving promotional emails, cookies, and data collection by certain third parties. You may update or terminate your account within our Services and also contact us with questions regarding individual rights over your personal data. Parents who believe we have inadvertently collected personal data about their underage children should contact us for assistance in deleting that information.

6.1 User Options Regarding the Use of Your Data

You may choose not to provide certain data to Elevify, but you may not be able to use certain features of the Services.

• You can opt out of receiving promotional communications. To do so, use the unsubscribe mechanism in the promotional communication you receive. Note that regardless of your email preference settings, Elevify will send transactional and relationship messages related to the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
• If you are in the European Economic Area, you may disable certain Data Collection Tools by clicking the Cookie Settings link at the bottom of any page.
• Your browser or device may allow you to control cookies and other types of local data storage. Wireless devices may also allow control over the collection and sharing of location and other data.
• Apple iOS, Android OS, and Microsoft Windows provide their own instructions on how to control personalized in-app ads. For other devices and operating systems, review the platform’s privacy settings.

If you have questions about rights, data, and how Elevify uses data, you should contact us at privacy@elevify.com.

6.2 Access, Update, and Deletion of Your Personal Data

To access and update personal data collected and maintained by Elevify, you can proceed as follows:

• To update data provided directly, sign in to your account and update it at any time.
• To terminate your account:
• If you are a learner, go to your profile settings page and follow the detailed steps.
• Note: Even after an account is terminated, some or all of your data may still be visible to others, including, among other things, data that have been (a) copied, stored, or disseminated by other users (including comments on content); (b) shared or disseminated by you or others (including within your shared content); or (c) posted on a third-party platform. Even after an account is terminated, we will retain your data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce our agreements. We may retain and disclose such data in accordance with this Privacy Policy after termination of your account.
• To request access to, correct, or delete personal data, use our online form available on the site’s support page. You may also email support@elevify.com or write to Elevify at: Avenida Jandira, 1350, casa 5, Planalto Paulista, São Paulo, SP, 04080–007. Please allow up to 30 (thirty) days for a response. For your protection, we may request that the request be sent from the email address associated with your account. You may be required to verify your identity before we implement your request. Note that we retain certain data when we have the right to do so, including where record retention is mandatory and to complete transactions.

6.3 Our Policy Toward Children

We recognize the privacy interests of children and encourage parents and guardians to take an active role in children’s online interests and activities. If you are under 18 years of age but have reached the minimum age for consent to use online services in your country of residence (for example, 13 in the U.S. or 16 in Ireland), you cannot create an account, but we suggest asking your parent or guardian to open an account and help you enroll in appropriate content. Individuals who have not reached the minimum age for consent to use online services may not use the Services. If we learn that we have collected personal data from a child below these ages, we will take the necessary steps to delete it. Parents who believe Elevify may have collected personal data from a child below these ages may send a removal request to privacy@elevify.com.

7. Updates and Contact Information

If there are material changes to this policy, we will notify users by email, in-product notices, or another mechanism required by law. Changes will take effect on the date they are posted. Contact us by email or mail with questions, clarifications, or disputes.

7.1 Changes to This Privacy Policy

From time to time, we may update this Privacy Policy. If there are material changes, we will notify you by email, by posting a notice within the Services, or as required by applicable law. We will also include a summary of key changes. Unless otherwise stated, changes will take effect on the date they are posted. As permitted by applicable law, by continuing to use the Services after the effective date of any change, your access and/or use will be deemed acceptance of the revised Privacy Policy (and agreement to follow and be bound by it). The revised Privacy Policy supersedes all prior Privacy Policies.

7.2 Interpretation

All capitalized terms not defined in this policy are defined as specified on Elevify’s Terms of Use page. Any version of this Privacy Policy in a language other than English is provided for convenience. In case of any conflict with a non-English version, you agree that the English version will prevail.

7.3 Questions

If you have questions, clarifications, or disputes regarding our Privacy Policy, contact our privacy team (including the data protection manager) at privacy@elevify.com. Alternatively, send correspondence to Elevify at: Avenida Jandira, 1350, casa 5, Planalto Paulista, São Paulo, SP, 04080–007