Elevating Community Privacy Policy

Effective Date: July 8, 2023

1. Personal Information We Collect
2. How We Use Your Personal Information
3. How We Share Your Personal Information
4. Your Rights and Choices
5. Third Party Sites and Services
6. Security Practices
7. International Data Transfers
8. Storage and Retention
9. Children’s Privacy
10. Changes to this Privacy Policy
11. How to Contact Us
12. Information for California Residents
13. Personal Information We Collect

• Business contact data, such as your first and last name, email and mailing addresses (including email address for any person assisting with your scheduling) and phone number.
• Profile data, such as your username and password that you may set to establish an online account with us, your interests and preferences, your date of birth, and any content uploaded to the Service (such as text, images, audio, and video, along with the metadata associated with the files you upload).
• Registration data, such as information that may be related to a service, application information for a Membership or an account or an event you register for, including, but not limited to, the following:

• Personal and professional goals, such as what you are passionate about, how you look to grow personally and professionally, how powerful you consider your professional network, how satisfied you are with your current career accomplishments and how you rank your personal well-being.
• Membership goals, such as why you joined Elevating Community as a member, what you want to get most out of your Membership (i.e., strengthen network of senior power players, connect on deeper level with like-minded people, sharpen senior leadership skills, partake in interesting events and programming, access to space outside your office to meet people), what you want to make the biggest priority of your Membership, and what you would love to learn more about.
• Protected classification characteristics, such as your ethnicity, sexual orientation, gender identity, relationship status and family overview. If you choose to provide any such protected classification characteristics, we will request your consent to our processing in accordance with this Privacy Policy.
• Sponsorship information, such as whether you requested and/or received sponsorship from your company for your Membership.

• Communications, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
• Marketing data, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
• Professional and employment data, including, but not limited to, the following:

• Company information, such as your company’s name, industry, type of company and size of company.
• Role information, such as your professional title, function, and any professional credentials (e.g., professional level and level you report into) and skills (e.g., whether you manage a P&L, sales or marketing budget or have raised or been involved in raising capital for a business)
• Other information of the type that may be included on a resume or curriculum vitae, such as whether you currently sit on a board at your company and/or outside of your company.

• Financial data, such as the credit card or other payment card details that you use to pay for the Service, and your Service-related billing information and transaction history.
• Other information, including information we may collect that is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

• Public sources, such as social media platforms. When you visit or interact with our social media pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the third party platform, and we will treat such information in accordance with this Privacy Policy.
• Calendar Synchronization, such as when you choose to connect your personal Microsoft or Google calendar to the Service so that Elevating Community may automatically sync, update, and/or delete Elevating Community events for which you register. This feature is completely optional and may be completed by following the prompts under the Membership settings page. You may also revoke the connection to your calendar at any time through following the prompts on the same Membership settings page. You may also be able to revoke access directly from your Microsoft account or Google account.
• Other users, such as the coaches that provide you mentorship and coaching through our Services and that may provide information to us in accordance with professional, legal, or ethical obligations.
• Marketing partners, such as joint marketing partners and event co-sponsors.

• Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, the website you visited before browsing to our Sites, and general or inferred location information such as city, state or geographic area from your IP address.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
• Precise geolocation data, such as when you authorize our mobile application to access your location. Where you grant this permission, we will collect information about your location using GPS, wireless, or Bluetooth technology. You can control access to precise location information through your mobile device settings. We also may look up your IP address to determine your general location.
• For example, the Services uses Google Maps API to visually display geographic information for demonstrating where jobs are located. Pursuant to the Google Maps APIs Terms of Service, use of this location feature is subject to Google’s Privacy Policy. Both the Google Terms of Service and Google Privacy Policy are incorporated into this Privacy Policy by reference.

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality and helping us understand user activity and patterns.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
• Software development kits, or SDKs, which are used to incorporate third party computer code into our App that allows our third party service providers or advertising partners to collect data directly from it for a variety of purposes, including to provide us with analytics regarding the use of the App, to integrate with social media or to add features or functionality to our App.

• provide and operate the Services and;
• provide information about your Membership and our products and Services;
• establish and maintain your Membership profile;
• communicate with you about your Membership, including by sending you announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events or groups in which you participate, including introductions to other members and groups;
• provide support and maintenance; and
• to respond to your requests, questions and feedback.

• Direct marketing. We may send you Elevating Community-related or other direct marketing communications in accordance with your marketing preferences as necessary for our legitimate interest in conducting direct marketing, or to the extent you have provided your prior consent. You may opt-out of our marketing communications as described in the “Your Rights and Choices” section below.

• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce the terms and conditions that govern our Service;
• protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
• comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

• Affiliates. We may share your personal information within the Elevating Community corporate group of companies, for purposes consistent with this Privacy Policy.
• Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Services (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose.
• Partners and sponsors. We may share your personal information with partners. For example, if we co-host an event with a third party, we may share your information to the extent related to such event. If required by applicable law, you can consent to such sharing via the registration form. In these circumstances, your information will be subject to the sponsors' privacy statements. If you do not want your information shared, you can choose to not opt in upon registration, or you can opt out according to the "Your Rights and Choices" section below.
• Coaches. As part of the Membership, Elevating Community provides mentorship and coaching programs. Therefore, if you are a member, we may disclose your personal information to our coaches and experts in order to provide these Services to you.
• Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processor, PayPal, and we never physically receive or store your full payment card information. PayPal commits to complying with the Payment Card Industry Data Security Standard (PCI-DSS) and using industry standard security. PayPal may use your Payment Information in accordance with its own Privacy Policy here: https://www.paypal.com/webapps/mpp/ua/privacy-full.
• Other users and the public. Other parties may be able to view your content when you provide such content through your public user profile or voluntarily disclose it in a manner that other users or the public can view it. In addition, your username will be displayed to other users through the Service, and other users may be able to contact you through the Service. Content that you post publicly on, through or in connection with the Service, including on third party services such as a social media platform, may also be public. We do not control how other users, or third parties use any personal information that you make available to them. Please be aware that any information you post publicly can be cached, copied, screen captured or stored elsewhere by others (e.g., search engines) before you have a chance to edit or remove it.
• Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services they render to us.
• Compliance and protection. We may disclose your personal information as we believe appropriate to government or law enforcement officials or private parties (a) for the compliance and protection purposes described above; (b) as required by law, lawful requests or legal process, such as to respond to subpoenas or requests from government authorities; (c) where permitted by law in connection with any legal investigation; and (d) to prosecute or defend legal claims.
• Business transferees. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

1. All users

• Access or update your information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.
• Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us here. You may continue to receive service-related and other non-marketing emails.
• Cookies. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third party websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly.
• Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
• Linked third-party calendars. If you choose to connect the Service through your third-party calendar, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party calendar or platform, that choice will not apply to information that we have already received from that third party.
• Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.

• You can request deletion of your personal information.
• You can access, correct or update your personal information.
• You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
• If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the UK are available here.

• Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
• The categories of Personal Information that we have collected.
• The categories of sources from which we collected Personal Information.
• The business or commercial purpose for collecting and/or selling Personal Information.
• The categories of third parties with whom we share Personal Information.
• Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
• Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion. You can ask us to delete the Personal Information that we have collected from you.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.

• Right to information, access and deletion. You can request to exercise your information, access and deletion rights by emailing us here. We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights. As part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
• We do not sell your personal information. Based on our understanding of the term “sell” under the CCPA, we do not “sell” your Personal Information and have not sold it to third parties for a business or commercial purpose in the 12 months preceding the effective date of this Privacy Policy.

• Identifiers
• What we collect: Business contact data, profile data, registration data, communications
• Sources: You, business partners, nominations
• Commercial Information
• What we collect: Business contact data, profile data, registration data, online activity data
• Sources: You, business partners, automatic collection
• Financial Information
• What we collect: Financial data
• Sources: You
• Geolocation Data
• What we collect: Device data, precise geolocation data
• Sources: Automatic collection
• Online Identifiers
• What we collect: Business contact data, profile data, online activity data, device data
• Sources: You, automatic collection
• Internet or Network Information
• What we collect: Device data, online activity data
• Sources: Automatic collection
• Inferences drawn from any of the above information to create a profile reflecting your preferences, characteristics, and behavior.
• May be derived from: Profile data, registration data, device data, online activity data
• Professional or Employment Information
• What we collect: Business contact data, profile data, registration data, professional and employment data
• Sources: You
• Protected Classification Characteristics,
• What we collect: Registration data, may also be revealed in other data we collect
• Sources: You