ELEVATE SOLUTIONS PRIVACY POLICY

Effective Date: January 1, 2024

1. Introduction

Welcome to Elevate Solutions, operated by Elevate Holdings Inc. (“Elevate,” “we,” “us,” or “our”), a California corporation. We are committed to protecting your personal information and your right to privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal data when you visit our website or use our services (collectively, the “Services”). By using our Services, you agree to the collection and use of your personal data in accordance with this Privacy Policy. If you do not agree with any part of this Privacy Policy, please discontinue use of our Services.

2. Data We Collect

Depending on your interactions with our Services, we may collect the following categories of personal data:

Identification Data:

Name, email address, phone number, and other contact information.

Account Information:

Usernames, passwords, and other authentication details for account creation (if applicable).

Payment Information:

Credit/debit card information, billing address, and transaction details when you make purchases or donations (if applicable).

Device and Usage Information:

IP address, browser type, operating system

Referring URLs, pages viewed, links clicked

```
Date and time of visits
```

Cookies and Similar Technologies:

We use cookies, web beacons, and similar technologies to gather information about your browsing activities and improve your experience on our website. (See Section 7: Cookies and Tracking Technologies for details.)

Other Information You Provide:

Feedback, inquiries, survey responses, or other data you voluntarily submit to us.

SMS opt-in consent or phone numbers for SMS purposes will NOT be shared with third parties and affiliates for marketing purposes.

3. How We Use Your Data

We use your personal data for the following purposes:

Service Delivery:

To provide, maintain, and improve our Services.

Account Management:

To set up and manage your user account and profile, including password recovery.

Customer Support:

To respond to your inquiries, requests, or feedback.

Payment Processing:

To process payments for services or products you purchase from us.

Marketing and Communication:

To send newsletters, promotional materials, or other information you may be interested in.

You can opt out of marketing communications at any time by following the unsubscribe instructions included in each email or by contacting us directly through the methods provided in this policy.

Analytics and Research:

To analyze trends, usage, and behaviors on our Services.

To personalize user experiences and improve our offerings.

Legal Compliance:

To comply with applicable laws, regulations, or legal obligations.

To protect our rights, property, and safety or that of our employees, users, or others.

4. Legal Bases for Processing (GDPR Notice)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, we process your personal data under one or more of the following legal bases:

Consent:

Where you have given clear consent for us to process your personal data for a specific purpose (e.g., receiving marketing materials).

Contract:

Where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract.

Legal Obligation:

Where processing is necessary for compliance with a legal obligation.

Legitimate Interests:

Where processing is necessary for the purposes of our legitimate interests, provided those interests are not overridden by your rights and interests (e.g., fraud prevention, security).

5. Data Sharing and Disclosure

We only share your personal data in the following circumstances:

Service Providers:

We may engage third-party vendors to help us operate or improve our Services (e.g., payment processors, analytics providers, email service providers). These third parties only have access to the data necessary to perform tasks on our behalf and are contractually bound to protect and use it solely for the purposes they were engaged for.

Corporate Transactions:

In the event of a merger, acquisition, financing, or sale of all or a portion of our business, your data may be transferred as part of that transaction, subject to confidentiality agreements.

Legal Requirements:

We may disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Protection of Rights:

We may disclose your data to enforce or apply our agreements, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.

6. Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy (unless a longer retention period is required or permitted by law). When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it.

7. Cookies and Tracking Technologies

We use cookies (small text files stored on your device) and similar tracking technologies (like web beacons and pixels) to collect and use personal data about you. This data helps us:

```
Remember your preferences and settings.
```
```
Understand how users navigate our site.
```

Personalize our content and communications.
You can control or disable cookies through your browser settings. Disabling cookies, however, may limit your ability to use certain features of our Services.

8. International Data Transfers

We may transfer and process your personal data outside the country in which you are located (e.g., if our servers or third-party providers are located in other jurisdictions). When we transfer your personal data internationally, we will take appropriate measures, in accordance with applicable data protection law, to ensure an adequate level of data protection (e.g., implementing standard contractual clauses approved by the European Commission).

9. Security of Your Data

We implement reasonable administrative, technical, and physical security measures to protect your personal data from unauthorized access, use, alteration, or destruction. However, please note that no electronic transmission or storage of information can be guaranteed to be 100% secure.

10. Children’s Privacy

Our Services are not intended for individuals under the age of 16 (or the relevant minimum age in your jurisdiction). We do not knowingly collect personal data from children. If you believe that we have inadvertently collected personal data from a child, please notify us using the method provided at the end of this policy, and we will promptly take steps to delete the data.

11. Your Rights and Choices

Depending on your place of residence, you may have certain rights regarding your personal data, including:

Access, Correction, and Deletion:

Request access to, correction, or deletion of your personal data.

Object to Processing:

Object to the processing of your personal data, or request the restriction of processing.

Data Portability:

Request a copy of your personal data in a structured, commonly used, and machine-readable format.

Withdraw Consent:

If we rely on your consent to process your personal data, you can withdraw that consent at any time.
To exercise any of these rights, please see the contact information at the end of this policy. We will respond to your request within the timeframe required by applicable law.

12. Contact Us

Elevate Solutions
Elevate Holdings Inc.
Attn: Privacy Team
6230 Wilshire Blvd, Suite 2120
Los Angeles, CA 90048, USA

13. SMS Terms and Conditions

We may offer the ability to receive notifications, alerts, or marketing communications via SMS/text messages. This section describes how we handle SMS communications and outlines our compliance with carrier and legal requirements, including the Telephone Consumer Protection Act (TCPA).

Opt-In and Consent

We provide multiple methods for you to opt in or out of receiving SMS/text messages, including:

Electronic Form: By checking a box, clicking a “Consent” button, or electronically signing our online form.

Paper Form: By physically signing or initialing a paper document indicating your preference.

Verbally: By explicitly telling us over the phone or in person that you wish to opt in or out.

Messaging Us First: If you initiate a text to our support line or designated SMS contact, this may indicate your interest or consent to communicate via SMS.

Support Ticket: By indicating your preference when you open or update a support ticket with us.

Client Contract: By specifying your preference on your client contract or service agreement with Elevate Solutions.

Where required by law, we will obtain your express consent (e.g., through a checkbox or written/electronic agreement) before sending marketing text messages.

You are not required to provide consent to receive SMS marketing messages as a condition of purchasing any products or Services.

Message Frequency and Costs

Message frequency may vary depending on your use of our Services and your communication preferences.

Standard message and data rates may apply. Please check with your mobile service provider for details on applicable fees.

How to Opt Out

You can opt out of receiving SMS marketing messages at any time by replying “STOP,” or by following the opt-out instructions included in each SMS message.

You may also opt out by using any of the methods mentioned above to indicate you no longer wish to receive SMS communications.

Even if you opt out of marketing messages, we may still send you transactional or administrative messages (e.g., password reset instructions, order confirmations) as permitted by law.

Help or Support

If you need help regarding our SMS messages, reply “HELP” to any text message you receive from us, or email Support@ElevateSolutions.io.

If you have questions about these policies, you may also refer to our mailing address provided in Section 12.

Third-Party Service Providers

We may use third-party platforms or service providers to facilitate SMS communications. These third parties will only process your personal data on our behalf and under our instructions, consistent with Section 5 of this Privacy Policy.

Carrier Limitations

Delivery of SMS messages may be subject to effective transmission from your mobile carrier/network operator and is outside of our control. We are not liable for delayed or undelivered messages.

Participating carriers may change without notice, and the list of supported carriers may vary.

SMS opt-in consent or phone numbers for SMS purposes will NOT be shared with third parties and affiliates for marketing purposes.

14. Additional U.S. State-Specific Disclosures

In addition to the general provisions in this Privacy Policy, certain U.S. states have enacted laws providing additional rights and disclosures regarding personal data. If you reside in one of these states, the following disclosures may also apply:

California (CCPA/CPRA):

Categories of Personal Information Collected: As described in Section 2 above, we collect identifiers (like names and emails), payment details, usage data, and more.

Purposes of Collection: As described in Section 3, we use personal data for providing our Services, processing transactions, marketing, and more.

Categories of Third Parties: As described in Section 5, we share data with service providers (e.g., payment processors), and in corporate transactions or legal contexts.

No Sale or Sharing of Personal Information: We do not sell or share personal information with third parties for monetary or other valuable consideration.

Right to Know, Delete, Correct, Opt-Out of Sale/Sharing:

California residents have the right to request that we disclose what personal information we collect, use, disclose, or sell. You also have the right to request deletion or correction of your personal information, subject to certain exceptions.

Because we do not sell or share personal information, the right to opt out of sale/sharing does not apply.

Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

Colorado, Connecticut, Virginia, Utah, and Other States:

Residents of certain states may have additional rights, including the right to access, correct, delete, or opt out of certain forms of data processing. You may exercise these rights by following the contact instructions at the end of this policy.

15. GDPR Compliance for Non-U.S. Users

If you are accessing our Services from outside the United States, especially from the EEA, UK, or Switzerland, we process your personal data under the legal bases described in Section 4. In addition:

You may withdraw consent if we rely on consent as our legal basis.

You may request the transfer of your data (data portability).

You may lodge a complaint with a supervisory authority if you believe our processing of your data is not lawful.

16. HIPAA Notice

We are not a healthcare provider or business associate governed by the Health Insurance Portability and Accountability Act (HIPAA) in most circumstances. Therefore, HIPAA typically does not apply to the information you provide to us. However, if we do receive or handle any protected health information (PHI) on behalf of a covered entity or in another capacity regulated by HIPAA, we will comply with all HIPAA requirements applicable to that specific context, including entering into a Business Associate Agreement (BAA) when necessary.

17. External Links / Third-Party Sites Disclaimer

Our Services may contain links to third-party websites, plug-ins, or applications that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We are not responsible for the privacy practices or content of these external websites or services. We recommend that you review the privacy policies of every website you visit.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time in response to evolving legal, technical, or business developments. When we update our Privacy Policy, we will post the new version and update the Effective Date at the top of this policy. Your continued use of our Services after any modifications indicates your acceptance of the revised policy.

19. Data Breach Notification Policy

Although we strive to maintain the highest standards of data security, no method of transmitting or storing data can be guaranteed as 100% secure. In the event of a data breach that affects your personal information, we will:

Identify and Contain the Breach: We will work diligently to identify the cause of the breach and take immediate steps to contain and limit any further unauthorized access.

Assess the Scope: We will evaluate the nature and extent of the personal data involved.

Notify Affected Individuals and Authorities (as Required by Law):

We will notify you and any relevant regulatory bodies within the timeframes mandated by applicable data breach notification laws (e.g., the GDPR’s 72-hour notification requirement, state-specific breach notification statutes in the U.S.).

Notifications will include a description of what happened, the data involved, the steps we have taken to address the breach, and recommended actions for you to take to help protect yourself.

Review and Improve Security Measures: Following a breach, we will review our procedures, implement any additional security measures, and provide further training to our staff if necessary.

20. Remote Access and Viewing of Data

By using our Services—including but not limited to remote access, backups, troubleshooting, or any other assistance that requires access to your devices—you understand and agree to the following:

Access to Personal, Confidential, and Sensitive Information:

In providing our Services, we may have the ability to view or access personal information, confidential information, and sensitive information that is stored on or accessible through your device(s). This can include, but is not limited to, any file or folder on your computer, server, or other devices.

Confidentiality Commitment:

We treat all personal, confidential, and sensitive information that we may view as strictly confidential. We do not sell, rent, or otherwise share such information with any third party, except as may be required by law or described in this Privacy Policy.

Scope of Potential Access:

Any file on your device(s) may be accessible during remote access or backups, depending on the nature of the support or service requested.

Acknowledgment and Waiver:

By allowing us to perform remote services, backups, or any other form of access to your devices, you acknowledge and consent that we may view the contents of your device(s) as necessary to provide the requested Service.

You further agree to waive any rights or claims, whether material or immaterial, arising out of or related to any breach, unauthorized disclosure, or access to the data, whether caused by negligence, gross negligence, or otherwise, to the fullest extent permitted by law.

This waiver does not limit any rights you may have under applicable law that cannot legally be waived.

Questions or Concerns?

If you have any questions, concerns, or comments about this Privacy Policy or our data practices, please contact us at:
Support@ElevateSolutions.io

Elevate Solutions

Location

Contact