How we protect you and your data.
This Site is the property of Elevate Collective Ltd (‘Elevate’ or ‘we’), a company registered in England and Wales under company number 12652296 and with our registered office at 42 Lewin Road, London SW16 6JR.
This policy covers all data that is shared by a visitor with us whether directly via https://elevateme.ai or via email. This policy is occasionally updated by us so we suggest you review it from time to time. This policy applies to visitors to our Site who do not register as well as those who do.
This policy provides an explanation as to what happens to any personal data that you share with us, or that we collect from you either directly via this Site or via email.
Certain businesses are required under the data protection act to have a data controller. Our data controller is Ben Lewell and can be contacted via email at firstname.lastname@example.org.
Information we collect from you
Personal data, or personal information, means any information about an individual from which that person can be identified.
We collect personal information from users of the Site (“Users”) in a variety of ways, including, but not limited to, when Users visit our Site, place an order, and in connection with other activities, services, features or resources we make available on our Site.
If you order a test via the Site we collect, as appropriate, name, email address, postal address, phone number, gender, and date of birth (DOB). This information is necessary to enable us to perform the test. Without this information we cannot provide our service to you.
We process special categories of more sensitive personal data which require a higher level of protection, including biometric information and data concerning your physical or mental health.
We collect and share special category data solely as necessary to carry out a particular test. Such information is voluntarily provided by you at the point of ordering a test, and you consent to our use of that information (and to the third party providers identified in this notice) for the purpose of carrying out the test and reporting the results back to you.
We, and third parties performing services on our behalf, may process special category data for the purpose of medical diagnosis, pursuant to a contract with a regulated health professional under an obligation of professional secrecy.
We may process special category data without your consent to the extent necessary as required by law or to protect your (or another person’s) vital interests where you are not able to give consent.
Users may visit our Site anonymously. With the exception of information collected in accordance with our Cookies Policy (below) we collect personal information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personal information, except that it may prevent them from engaging in certain Site related activities.
Non-personal identification information
We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilised and other similar information.
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How we use collected information
Elevate Collective Ltd may collect and use Users personal information for the following purposes:
- To improve customer service
- Information such as name and order reference number you provide, helps us respond to your customer service requests and support needs more efficiently. This is necessary for the legitimate interest of improving our Site and our services. We only do this to the extent that your right to privacy does not override our legitimate interests.
- To improve our Site
- We may use feedback you provide to improve our products and services. This is necessary for the legitimate interest of improving our Site and our services. We only do this to the extent that your right to privacy does not override our legitimate interests.
- To perform the contract between us and process payments
- We may use the information Users provide about themselves when placing an order only to provide the service that you have ordered. We may share this information with third parties described in more detail below, to the extent necessary to provide the service or otherwise with our consent, our use of information for this purpose is necessary to perform the contract between us.
- To run a promotion, competition, survey or other Site feature
- We may use your name and contact details for this purpose, this is necessary for the legitimate interest of providing these features on our Site. We only do this to the extent that your right to privacy does not override our legitimate interest and you can opt out of participating in promotions, competitions and surveys at any time by contacting email@example.com.
- To send Users information they agreed to receive about topics we think will be of interest to them.
- We only send marketing materials by email with your consent. You can opt out of receiving this information at any time at firstname.lastname@example.org.
- To manage product reviews and ratings
- To send periodic emails
- We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. Such contact is necessary to perform our contract with you and otherwise for the legitimate interest of managing our business provided that your right to privacy does not override those interests.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, where this is required or permitted by law.
Sharing your personal information
We do not sell, trade, or rent Users personal information to others. We may share generic (anonymised) aggregated information not linked to any personal information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.
We use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. All of our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes.
Upon purchasing, your personal information will be shared with applicable third parties to ensure the running of the service we provide. These include:
- Your email address and order reference number will be shared with a third party payment gateway; Stripe (https://stripe.com/) who will securely administer the payment of our service on our behalf. When making a payment, you’re entering your information such as card number, CSV number and postcode directly into Stripe and is not stored within the Elevate Collective Ltd database.
- Your name and address will be shared with a third party dispatch company who will administer the dispatch of your kit on our behalf.
- Your name, sex and DOB will be shared with our accredited labs. This is required to provide results specific to you. As the lab is conducting the analyses, they will have access to your results once completed.
- Your name, sex, DOB, Email address, telephone number, profile information and results may be shared with a registered healthcare professional who may view and comment on your results.
Disclosing your information
Where applicable, we may disclose your personal information to any member of our group. This includes, where applicable, our subsidiaries, our holding company and its other subsidiaries.
We may also disclose your personal information to third parties:
- Where we sell any or all of our business and/or our assets to a third party.
- Where we are legally required to disclose your information.
- To assist fraud protection and minimise credit risk.
Storing your personal data
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data that is provided to us is stored on our secure servers inside the EEA . Details relating to any transactions entered into via our Site will be encrypted to ensure its safety against unauthorised access, alteration, disclosure or destruction of your personal information.
The transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically and the transmission of such data is entirely at your own risk. Where we have given you (or where you have chosen) a password so that you can access certain areas of our Site, you are responsible for keeping this password confidential.
If the User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. We use the third party service MailChimp (http://www.mailchimp.com/) to help to administer activities on our behalf, such as sending out newsletters or surveys. Your information such as name and email address is shared with the third party but you will not be contacted unless opted-in to receive such communications.
If a User purchases a test, they will receive emails with regards to their order such as a receipt, dispatch notification and notification when results are ready. This is actioned automatically by the Elevate Collective Ltd system, however you may also be communicated directly by a member of Elevate Collective Ltd. To send and receive emails, we use the third party service Google Mail (mail.google.com) to help to administer these activities. Depending on the purpose of the communication, your information such as name, email address and details of your order may be transmitted through this third party.
Third party websites
You might find links to other websites on our Site. These websites should have their own privacy policies which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.
Compliance with children’s online privacy protection act
Protecting the privacy of the very young is especially important. For that reason, we never collect information at our Site from those we actually know are under 18, and no part of our Site is structured to attract anyone under 18.
You have the following rights in connection with personal information:
- the right to be informed about what we are doing with your personal data. This notice sets out how we use it.
- the right to object to the processing of your personal data.
- the right to request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- the right to request us to update the personal information we hold about you.
- the right to request us to delete the information we hold about you (the right to be forgotten).
- the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
- the right to ask us to restrict how we use your personal data for a period of time. If you ask us to restrict our use of your personal data, we may not be able to provide you with our services.
- the right to request us to send to another organisation, information that you have provided to us in a format that can be read by computer.
If you want to exercise your rights please send an email to email@example.com.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).
If you exercise the right to be forgotten the process set out below will apply. Please note that if you ask us to delete your personal information the process is not reversible, once your information is deleted, we will not be able to provide our services to you and you will no longer be able to access your results on our Site.
To delete your information we will:
- Remove your first name
- Remove your last name
- Remove your contact details such as email address, telephone number and home address
- Remove profile picture (if provided)
- Reset the password
- Set your DOB to the 01/01/[Year of your birth]
- Change reference numbers to any tests your may have purchased
This will anonymise the data and will no longer contain any information or data identifiable to the User.
Any personally identifiable data stored in the ‘changes log’ will be removed however your data may still be included within back-ups of up to 12 months.
Accuracy of your data
Personal information is supplied and managed by the User and is the responsibility of the User to ensure it is accurate and kept up-to-date.
To support the accuracy of the data held in the Elevate Collective Ltd database, your information will be kept for up to 3 years from the last point of contact on our main systems after which time it will be anonymised or deleted. We will endeavour to contact you via email before this is actioned.
Your acceptance of these terms
By using this Site, you signify that you have read and understood this policy.
If you would prefer to write to us then our contact address is 32 Blackfriars Rd, London SE1 8PB.
This document was last updated on 12th October 2021.