Elevate Ecosystem Private Limited
Privacy Policy 

Last Updated: October 31, 2023
Effective: October 31, 2023

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Elevate Ecosystem respects your privacy, and we created this Privacy Policy (Policy) to help you recognize and appreciate how we collect, use, and handle information pertaining to business organizations and Business people (“Business Information”).

By using this site (https://www.elevateecosystem.co/), you consent to the practices described in this policy. 

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Definitions:
“Personal Data” means any information related to a natural person or ‘Data Subject’ that can be used to identify the person directly or indirectly.
“Data Subject” means the individual to whom Personal Data relates.
“Data Controller” is the entity that determines the purposes, conditions, and means of the processing of personal data.
“Data Processor” is the entity that processes data on behalf of the Data Controller.
“Business Information” includes your company name, industry, number of employees, and other information associated with your company that can be obtained through publicly available resources.

“Elevate” means and includes Elevate Ecosystem Pvt Ltd and its associated entities, subsidiaries, etc. The acronym EEPL may be used for Elevate Ecosystem in this document or on our website.

I. Introduction
This policy aims to explain who Elevate Ecosystem is, what services it provides, and as a part of that service, what Business information it collects. It also guides you about the value of remaining in our database and how you can opt-out if you so desire.

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We collect business contact information – such as the Title, email, and phone numbers of individuals working in their professional capacity. We use this information and build professional profiles of individuals as well as profiles of business entities. We organize and provide this information to our customers, for their own business-to-business sales, marketing activities, and outreach.

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If you wish to opt out of our database, you may visit our Privacy Center. You can also claim your professional profile and update your profile information. Alternatively, you may also send us an email or call us. Our contact information is provided in the “Contact Us” section of this Policy.

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If your profile remains in our database, our customers may contact you, for their business-to-business sales and marketing activities and outreach. Communications sent by our customers would generally be relevant to your profession or employment; however, we cannot assure you that you will find such communications to be relevant or interesting to you.

 

II. How Elevate Ecosystem Collects Information

Where does EEPL get the Business Information for its Business Profiles?
EEPL develops profiles of businesses and people in those businesses. These are termed as “Business or Company Profile” and “Contact Profile”.  Once we have collected Business Information about a person or company, we discover and append multiple data points regarding a single person or business entity into a Contact or Company Profile. This directory of Professional and Business Profiles is then made available to our customers. Information in a Company or Contact Profile may include name, email address including business and other email addresses, job title and role, phone number (general or direct business numbers and/or mobile numbers), company name, and address of the company. Company or Contact Profiles may also include links to an individual’s or a business’s social media profile.

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EEPL collects the data for its Business Profiles in multiple ways, including:

1. Automated and human research including web scans and scraping to collect publicly available information.
2. Obtaining information from other companies and our partners and affiliates.
3. Information provided by our customers.
4. Information collected through research, surveys, and interviews, including phone interviews, undertaken by our in-house research team through market surveys, phone interviews, and other forms of research.
5. Through patterns and correlation of data points to infer and then test further data points, including a business email ID of the person, if it is not publicly available.

 

 

How else does EEPL Collect Information?
a) Using EEPL Integrations.
As part of our Services, EEPL may offer its customers certain “Integrations” (automated connects and exchanges). While using EEPL’s Integrations, Business or professional Information from the customer’s CRM, Marketing Automation or sales enablement software may be sent to EEPL for purposes of enriching, matching, or cleansing the customer’s data against EEPL’s database. 
EEPL may store and process such Business Information to enrich the records, identify contacts, or enhance the services. 
EEPL may verify the accuracy of such Business Information, remove obsolete Business Information, or otherwise improve EEPL’s research processes, and the information provided through the Services. We shall not reveal the source of specific data except as required by law. It is generally difficult to attribute such data to any specific source.

b) From third parties.
EEPL may obtain personal information from our partners, data and information providers, and affiliates. This information is used to improve the accuracy of our records and we may use this information to enhance our records.

c) Use inferences to arrive at more information.
Our data research and modeling team uses the information we have to develop correlations and model cause-effect scenarios and thus lead to inferences or to designate a propensity or intent score or rating. 

We develop algorithms that assess multiple data points to arrive at a score predicting the likelihood of a data subject responding to our customers’ marketing outreach efforts. We also use patterns and correlations to infer specific data points about a subject, which may include a business email ID, if not publicly available.

d) Business Data submitted through our Site.
We collect personal data and business information such as first name, last name, email address, company name, phone number, and any comments/messages you submit by filling out a contact form on our site, newsletter subscription form, or by sending us an email. As a user of our site, you agree to the provisions described in this Policy regarding the information collected from you. If you do not agree to this, please do not submit any information through our Site.

e) Information provided by our customers.
We receive information from our customers about their end-users or prospects. This information may typically include name, contact information, and company information, such as company name. Information may also be collected through the use of our processes and research activities. Any information provided by a customer that uses our services is subject to the customer’s privacy policy and applicable terms including contracts executed with the customers. When we provide our Services to a customer, we generally act as a “data processor,” and the customer is the “data controller.

When EEPL is a Processor. Our customers using our Services are acting as the data controller. They are responsible for ensuring that personal information collected about data subjects is being processed lawfully.

We become the data processor and we receive personal information as agents of our customers merely for processing as instructed by our customers. Our customers as the data controllers are solely responsible for determining what services they wish to use from us> they also have to ensure that all data subjects arising out of such services have been given adequate notice related to the processing of their personal information, have provided informed consent where such consent is necessary or desired, and that all legal requirements applicable to the processing of personal information through our Services have been met by such customers. 
Our customers are also responsible for handling any requests from data subjects regarding their rights under applicable law. Our agreements with our customers lay down EEPL’s obligations regarding personal information for which we are merely a data processor. Our obligations as mere data processor are not covered under this Policy.  If customers provide additional information for our database or where the information is solely sourced by EEPL, without any input from our customer, EEPL may be deemed an independent controller of personal information.

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When EEPL is a Controller. EEPL becomes the data controller when we collect and use information about data subjects who are visitors to our Site, as well as when we collect and use information about data subjects for purposes of creating and maintaining our Professional Profiles and providing the Services.

Purposes of processing and legal basis for processing:  We process personal information in various ways. The following are the legal provisions under which we process personal information.

1. Consent, or
2. as necessary to perform our agreement to provide Services or other applicable contracts, or
3. as supported by the legitimate interests of EEPL and our customers and partners to engage in marketing and sales outreach activities,
4. as supported by EEPL’s legitimate interests in developing and providing Professional and Business Profiles, considering the limited risk, the use of this Business Information presents to an individual’s privacy expectations, or
5. as required for compliance with a legal obligation applicable to us.

When we process information in fulfillment of our business contracts: A contract governs the processing by EEPL as a data processor and is binding on us with regard to the controller (our customer) and sets out the subject matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects and the obligations and rights of the controller. Processing will be done only as per a written contract documenting the following.
a. persons authorized to process the personal data have committed themselves to confidentiality.
b. all measures required pursuant to security requirements for processing.
d. assisting the controller to protect the data subject.
e. assisting the controller in ensuring compliance with the obligations on the security of personal data pursuant to Articles 32 to 36.
f. at the choice of the controller, to delete or return all the personal data to the controller after the end of the provision of services.
g. make available to the controller all information necessary to demonstrate compliance with the GDPR obligations. 

III. How We Use Information
Besides the uses listed above, we may use the Professional or Business information for any of the following purposes:
Build and develop, manage, update, improve, and offer our Business Directory
Enhance the personalization features on our Site
Review, update, validate, modify, and improve Business Information that we provide to our customers
Respond to individuals’ requests to access, modify, or remove their information.
Create inferred data, aggregated statistical data, or anonymized data (data that is transformed to make it non-personal and non-identifiable), which may be used by us or our business partners or customers.
Fulfill our contractual and legal obligations, and comply with our agreements
Use the information for any other purpose that is laid out at the time of collecting the information

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IV. How Information is shared
Providing Business Profiles. We may offer any Business Information that we collect through multiple means described in this Policy available to our affiliates, partners, and to our customers

This may include Business information that is contributed for our Directory, collected from public web sources, collected through market surveys and phone interviews conducted by our in-house research team, licensed from third parties, or otherwise collected as described in this Policy. 

Sharing for Legal Reasons. We may be required to disclose collected information, to a public authority if such disclosure is required or preferred: (i) to meet lawful requests or orders from Government authorities; (ii) to safeguard the rights, assets, or safety of EEPL or its users; (iii) to address requests from data subjects for access to data as required under applicable laws and regulations. or (v) to allow EEPL to use its legal rights or to respond to a legal claim.

Disclosures to a Buyer of the Company. Information in our Business profiles and information collected by you may be among the information that is transferred in the event our company or our assets are acquired, or in the event of a merger or bankruptcy.

Other Disclosures
We may generally share information about individuals who register for our customer event with the Customer or any sponsor or partner of the event.

 

V. Regarding Cookies and related technologies
To improve your site experience, we use Cookies. Cookies help us to provide additional features and allow us to analyze your site usage. You can disable cookies for the site, but this may limit your ability to use our site entirely. You can control the use of cookies at the individual browser level.

Through server log files and cookies, we may also collect information such as internet protocol (IP) addresses, browser type, internet service provider (ISP), referring and exit pages, operating system, date/time stamp, page views and clicks, domain names, landing pages, page load durations and/or clickstream data. We use this information to enhance site experience and functionality. IP addresses help us to diagnose problems with our servers and to administer the site. This information may be associated by us with other information that we may have on a data subject.

Besides cookies, EEPL may use other technologies that are similar in nature.

 

VI. Options available to you
A. Changing or Deleting your Professional information
You may use self-service features at our Privacy Center, and request access to your Professional Profile and update profile information or opt out of inclusion from our database.

Right of access:  Requesting Access to Information Collected by EEPL. If you want to access the information that EEPL has collected about you, you can submit an access request at our Privacy Center or via email. Once we have verified your identity, we will provide you with the information we have available about you.

Right to rectification: You have a right to rectification of inaccurate personal data, and a right to have incomplete personal data completed, including by means of providing a supplementary statement

Right to object: You have the right to object at any time to the processing of personal data concerning you on grounds relating to your situation, or processing of personal data for direct marketing purposes. EEPL shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override your interests or rights or for the establishment, exercise, or defense of legal claims.

Right to erasure (‘right to be forgotten’): Removing your Professional Profile Completely. If you wish to remove your existing Professional Profile from our database completely, please make a request through our Privacy Center. Based on such a request, your Professional Profile, and the information within it will be removed from our search results at the earliest.

Alternatively, a request may be submitted through the contact information listed in the “Contact Us” section on our website.

B. Changing or Deleting Company Information
An authorized representative of a business can also update their Business Profile through our Privacy Center.

Removing Business Profiles. EEPL is a specialized research agency focused on finding information about companies and professionals. We collect information from websites and publicly accessible directories, social media sites, and other sources such as press releases, and/or documents available with the local, state, and federal Government agencies and institutions. EEPL will not remove a Business Profile; however, an authorized representative can request updating of the information about that business

C. Opting out of Certain Uses of Information
Individuals can “opt-out” of having their information used for certain purposes. You will have to make the specific request through our Privacy Center.

 

VII. How Do We Keep Information Secure?
EEPL observes best practices across multiple avenues to keep your information secure. While it is in our possession, or it is being transmitted to our customers or affiliates. We observe industry standards and are certified to ISO 27001:2013

 

VIII. Data Retention
Personal information is retained for a period depending on the original purpose(s) for which it was collected. This could be (a) if we must provide our customers, or our partners our Services; (b) as required to fulfill our agreements and meet our contractual obligations; (c) as required to meet our legal commitments; (d) as needed to resolve disagreements or to protect EEPL from potential disagreements. We determine the retention period based on the type of data collected and its sensitivity and privacy obligations, as well as the reason for the collection of such data. We will delete the personal information when the retention period is over. In case deletion is not possible, we ensure that such data cannot be used.

 

IX. Information for Data Subjects in Europe and Elsewhere Outside the U.S.
Data subjects outside of the United States should understand that we may collect, process, and store their personal information in the United States and other countries in which we or our affiliates maintain facilities.

A. For residents of the EEA, the UK, or Switzerland.
EEPL strives to adhere to the provisions of the General Data Protection Regulation (“GDPR”) as relevant to the information available with it regarding EEA-, UK-, and Switzerland-based persons (“data subjects”). We undertake data processing involving personal (Business related only) information, only where there are legitimate reasons to do so. These may involve the consent of the person (as obtained through a campaign), execution of a contract, fulfillment of a legal obligation, or the legitimate interest of EEPL or a third party. EEPL sends email notices to all data subjects as required by GDPR Article 13 or 14, as appropriate, and values the rights of data subjects provided in Articles 12-23, including the right to be forgotten. Notice is provided only where we have access to the email ID of the data subject and where the information has been partially or fully received from non-public sources. For any opt-out requests or other inquiries related to privacy, please visit our privacy center or email

GDPR requires a data controller or processor to integrate data protection concerns into every aspect of processing activities. This approach is known as ‘data protection by design and by default’. It is a key element of the GDPR’s risk-based approach and its focus on accountability.  EEPL adheres to this approach

Data Transfers: We may transfer to or store and process the personal information we collect in the United States or any other country where we or our affiliates or partners have facilities. As required under GDPR, we ensure that the transfer of personal information to a third country or an international organization is undertaken with safeguards as described in Article 46 of the GDPR, such as the UK or EU Standard Contractual Clauses, as applicable.

Individual Rights: The following rights under the GDPR are available to Individuals who are a resident of the EEA, the UK, or Switzerland.

The right to access, correct, or restrict processing. Such data subjects can request access to, and receive a copy of, their personal information free of cost. They can ask about our processing activities related to their data. They can request a modification of their personal information if it is inaccurate or incomplete. They can also ask us to suspend processing if they contend that the data, we hold about them is not accurate until the accuracy is verified.
The right to data portability. Such data subjects can request a copy of their data. They can also request that this data be sent to some other entity, if technically feasible
The right to request data removal. Such data subjects can ask us to remove their data from our records and stop processing if the data is no longer required for its original purpose if they withdraw consent and opt out, if there is no legal obligation for such processing, or if their rights to data privacy transcend our legitimate interest in such data processing.

The right to object to our processing. Such data subjects can object to our processing if such processing is based on legitimate interests or in undertaking a task in the public interest or using such data for direct marketing.

X. Children’s Privacy
Our Services are not directed to or intended for individuals under the age of 16. Any personal information of those who are under the age of 16 is not collected by us. We will delete the personal information as soon as possible if we realize that we have collected information from someone who is under 16. Individuals who believe we may have collected personal information from someone under 16 should contact us at team@elevateecosystem.co.

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XI. Changes to this Policy
EEPL may make changes to this Policy at any time.

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XII. Contact Us
If you have questions or concerns regarding this Privacy Policy, please contact us at:

Email: Team@elevateecosystem.co