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PRIVACY POLICY

Last updated on October 10, 2025.

ELVTR US LLC (otherwise referred to as “ELVTR”, “we”, “us” or “our”), is committed to protecting your privacy to the maximum extent possible under the applicable law.

The objective of this Privacy Policy is to describe our practices regarding the information we collect from users through our website https://apac.elvtr.com (the “Website”), as well as the ancillary services made available through the Website (collectively “Services”). Our Services mainly include the operation of the ELVTR education platform, but we may expand the scope of our services as we deem fit.

This Privacy Policy sets forth the legally binding terms for your use of our Services, whether you are a “Visitor” (which means you are just accessing and browsing the Website) or a “Subscriber”, which means you have paid for any of our offered Services. Visitors and Subscribers are referred to in this Agreement as a “User” or “you”.

This Privacy Policy forms an integral part of the Terms of Use located at https://apac.elvtr.com/terms  (the “Terms of Use”), which you, or if you have not reached the age of majority in your jurisdiction, a parent or legal guardian, must read and accept on your behalf. The Terms of Use explain your rights and responsibilities when using ELVTR’s Services. Capitalized terms not otherwise defined in this Privacy Policy have the meanings given in our Terms of Use.

BY USING OUR SERVICES, YOU CONSENT TO THE COLLECTION, TRANSFER, USE, STORAGE, AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED HEREIN. IF YOU, OR YOUR PARENT/GUARDIAN, ON YOUR BEHALF, DO NOT WISH TO BE BOUND BY THE TERMS OF USE, INCLUDING THIS PRIVACY POLICY, PLEASE EXIT THE SERVICES NOW AND DO NOT ACCESS OR USE ELVTR’S SERVICES.

If you have any doubts about any of your rights and obligations under this Privacy Policy, you are hereby advised not to proceed without consulting a legal counsel. You may also contact us at privacy@elvtr.com for any additional questions.

Acceptance of the Privacy Policy

By electronically accepting, accessing, or using our Services, you acknowledge that this Privacy Policy will apply to your use of our Services, and agree to be bound by the Privacy Policy, which constitutes an agreement between you and ELVTR.

This Privacy Policy shall apply to all personal information transmitted by you to ELVTR, whether in the course of visiting our Website and/or using any other of our Services. This includes information that we collect via e-mail, text, audio, photos, and other electronic messaging, as well as interactions between you and third-party webpages or applications that include a link to this Privacy Policy.

ELVTR is not, nor shall be in the future, responsible for the privacy rules and regulations of any third-party application, website, and/or service, regardless of whether such third-party app, website, and/or service was linked from or through our Services. The foregoing sentence shall also extend to any person employed or otherwise engaged under the payroll by such third-party.

Let’s Define the Term “Information”

Before we get started, it may be helpful to define some terms. There are two types of information that may be collected: 

  • “Personal Information”, which is personally identifiable information that allows someone to identify or contact you, such as your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing Information.
  • “Anonymous Information” means information that is not associated with or linked to your Personal Information and does not, by itself, permit the identification of individual persons. Anonymous Information does not directly identify an individual or may have been personal information, but has had the personally identifiable information removed. We may collect Anonymous Information about the use of our Services to help us improve them.

A Note About Children

The Website is just for people who have reached the age of 16. We share your concern for the privacy of underage children and do not knowingly collect any personally identifiable information about children through the Services. We may, however, use third-party analytics services that collect anonymous information about usage of our Services.

Personal Information You Submit to Us

We collect Personal Information that you directly submit to us while:

  • Subscribing to online courses;
  • Subscribing to a newsletter on our Website;
  • Requesting technical support either through our Website, by messaging us via our proprietary Learning Management System, via our page on Facebook, or by e-mail.

Such Personal Information may include:

  • your email address;
  • your name;
  • IP address, device type, operating system, and browser type;
  • any other information you’ve decided to provide us.

We use this Personal Information for two purposes:

  1. to deliver the newsletter that you’ve subscribed to

    We use a service provider called HubSpot to deliver the newsletter, so your email address will be stored on their servers. HubSpot is a GDPR-compliant marketing automation service. Please visit their website to find more info about HubSpot or contact us at privacy@elvtr.com.

    You may always cancel your newsletter subscription at any time by clicking the ‘unsubscribe’ button in such newsletter. You can also request a permanent deletion of your email from the newsletter mailing list by sending us a request at privacy@elvtr.com.

  2. to provide you with the assistance you requested

    We do not store the information you provide us through our Website, our Page on Facebook, or by email on our infrastructure. However, this information may be stored:

    • by your email provider (should you decide to contact us by email).
    • by our email provider. We use HubSpot’s email, CRM, and helpdesk service to process and respond to all incoming support requests.
    • within your Facebook account (should you decide to contact us through our
      Page on Facebook). Click here to learn more about Facebook’s Privacy Policy.
    • Users may disclose information about themselves by posting on the Website or on our Page on Facebook. ELVTR is not responsible for what Users say and post in these sections. In addition to being collected, such information is made public for others to see. The User is responsible for the disclosure of any such data there.

Information That We Collect Automatically When You Visit Our Website

We collect several types of Personal Information, as well as Anonymous Information (when relevant), from and about Users who visit our Website and use our Services. Such information includes:

  • traffic data;
  • your location;
  • logs and communication data;
  • resources on our Website, which you access and use;
  • IP address, operating system, and browser type;
  • information which is collected through cookies, web-beacons, and other tracking technologies;

The technologies we use for this automatic data collection are further explained in our Cookie Policy. We may use the above information to analyse trends, administer our Website, track users' movement, and gather broad demographic information for statistical purposes.

Intended Use

The legal basis for the processing of Personal Information and Anonymous Information on the Website includes, but is not limited to:

  • Consent. By using our Services, you hereby agree to our Privacy Policy.
  • Fulfilling our legal obligations towards you. Such as ensuring that your Personal Information is accessible to you for the purpose of using our Services.
  • Meeting our legitimate interests. Your Personal Information allows us to derive knowledge which enables us to enhance and maintain our existing Services and develop new ones.
  • Compliance with our applicable law, regulatory, and audit obligations. We may retain Personal Information in case we are obliged to do so by the applicable law and/or regulatory body.

Use of Collected Information

Your Personal Information, as well as Anonymous Information (when relevant), is necessary for the following purposes:

  • to set up your account on our Services and save your settings (i.e, language, sound settings), course progress, and to recognize you when you return to our Website;
  • to improve the existing Services through analysing aggregated data on how Users engage with our Services;
  • to develop new Services and tools;
  • to deliver content localized for your language;
  • to understand what kind of content is more relevant in particular areas;
  • to promptly identify and solve the technical problems our Website and Users encounter;
  • to notify you about new content and special offers;
  • to estimate the size of our target group and their user pattern;
  • to estimate the efficiency of our marketing campaigns;
  • to improve our customer services;
  • to ensure the stability and security of our Services.

You hereby consent that ELVTR may use the above information to analyse trends, administer our Website, track users' movement, and gather broad demographic information for statistical purposes.

Sharing of Information

Without your consent, we will not rent, sell, or share the personal information we have collected from you with third parties outside ELVTR (or the group of companies of which ELVTR is or may become a part), except as described below:

  • when we believe, in good faith, that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes, or respond to lawful requests or legal authorities, including responding to lawful subpoenas, warrants, or court orders;
  • to protect the rights and property of ELVTR, our agents, customers, and others (including enforcing our agreements, policies, and terms of use), or to investigate fraud, intellectual property infringement, and any other conduct that might be illegal or expose ELVTR or a user of its services to legal liability;
  • in case the disclosure is required for a third-party to assist ELVTR with the operation and/or enhancement of our Website and/or our other Services;
  • In case the Personal Information is aggregated or de-identified for the purpose of analytics, analysis, trends, and the like, and no User of our Services will be individually identifiable from these aggregated and/or anonymised information and statistics;
  • in connection with, or during negotiations of, a change or proposed change in the ownership of ELVTR, i.e., when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any sale, merger, financing, acquisition, or bankruptcy transaction or proceeding, or in any other situation where personal information may be disclosed or transferred as one of our business assets. The buyer or transferee will have to honor the commitments we have made in this Privacy Policy;
  • in case of an emergency, which includes protecting the safety of our employees and agents, our customers, or any person.

How do We Protect Your Data?

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. We continuously take steps to further improve the way we store and process Personal Data.

We cannot guarantee the complete security of your personal information transmitted to our Website, as any transmission of information over the internet is not entirely secure. While we strive to protect your personal information, you acknowledge and accept that any such transmission is at your own risk.

We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

It remains your own responsibility to: (i) ensure no one else uses our Services while you are "signed in" to your account; (ii) sign out from your account when not using it; and (iii) keep his password or other access information secret.

How do We Store Your Information?

The information we collect through our Services is stored and processed on the servers located in the US and the EU, hosted by Digital Ocean, Amazon Web Services & Fastly.

The servers of our Service Providers are located in the United States, and the EU. By registering for and using the Services you consent to the transfer of information to the United States and the EU.

Data Retention and Accuracy

ELVTR retains the data collected pursuant to this Privacy Policy for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Thereafter, if the collected data is no longer needed for purposes specified in this Privacy Policy, ELVTR deletes all aforementioned data in its possession within a reasonable timeframe.

ELVTR does not verify the accuracy of Personal Data. We may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce ELVTR user agreements, and comply with technical and legal requirements and constraints related to the security, integrity, and operation of the Services

Third-Party Terms and Conditions and Links to Other Websites

A User’s access to and use of the Services may be subject to other third-party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, social networking services, and payment providers. ELVTR is not liable for any such third-party terms and conditions or their use of Users’ Personal Data.

ELVTR may, in its discretion, make available links through advertisements or otherwise enable Users to access third-party products or services. ELVTR is not responsible for the actions of such third parties, the content of their products or services, the use of information a User provides to them, or any products or services they may offer. ELVTR’s linking to those products or services does not constitute its sponsorship of, or affiliation with, such third parties.

Any information you provide on those websites or applications is provided directly to the owner of that website or application and is subject to that party's privacy policy. Our Privacy Policy does not apply to such websites and applications, and we are not responsible for the content or privacy and security practices and policies of those websites and applications.

Your Privacy Rights 

We are committed to protecting your personal information in accordance with applicable data protection laws, including but not limited to the Delaware Personal Data Privacy Act (DPDPA), California Consumer Privacy Act (CCPA), the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), the Texas Data Privacy and Security Act (TDPSA), and other U.S. state privacy laws in effect, or other regions or states from which you may access our website.

As a consumer or data subject, you have the following rights regarding your personal information, subject to applicable laws:

  • Access: Request access to the personal information we collect, use, or store about you, including details about how it is processed.
  • Rectification: Request correction of inaccurate or incomplete personal information.
  • Deletion: Request deletion of your personal information, where permitted by law.
  • Restriction: Request restriction of the processing of your personal information in certain circumstances.
  • Data Portability: Request to receive your personal information in a structured, commonly used, and machine-readable format, or have it transferred to another entity, where applicable.
  • Opt-Out of Sales or Sharing: Opt out of the sale or sharing of your personal information for targeted advertising or other purposes, as defined under applicable laws like the CCPA and VCDPA. 
  • Non-Discrimination: Exercise your rights without facing discrimination, such as denial of services or changes in pricing, as protected under laws like the CCPA.
  • Objection: Object to the processing of your personal information for specific purposes, such as targeted advertising or profiling, where permitted by law.
  • Lodge a Complaint: File a complaint with a relevant regulatory authority if you believe our processing of your personal information violates applicable law.

To exercise any of these rights or object to specific processing activities, permanently remove your account, withdraw your consent or unsubscribe from marketing emails, please contact us at privacy@elvtr.com. Note that opting out of marketing will not affect essential transactional emails about your account, services, or related updates, which are integral to your use of our platform and cannot be unsubscribed from.

If you object to certain processing, please provide a clear explanation of your reasons. We will review your request and either cease or adjust the processing or explain our legitimate grounds for continuing the processing, in accordance with applicable law. 

ELVTR is committed to upholding your right to privacy. To opt out of tracking or adjust your privacy preferences, use the "Do Not Sell or Share My Personal Information" link in the website footer. You may change your decision at any time. For more details on tracking technologies and cookies, please review our Cookie Policy.

How to Contact Us

If you have any questions about this Privacy Policy or the Services, please contact us at privacy@elvtr.com. We will usually conduct our communication via email. Should we require any other information, we will contact you at the email address you have provided in your request.

Effective Date and Changes to Our Privacy Policy

We may modify or update this Privacy Policy at any time to reflect changes in our services, the introduction of new features, or updates to applicable data protection laws

Unless otherwise specified, any changes to this Privacy Policy will take effect immediately upon posting at https://apac.elvtr.com/privacy. We will make reasonable efforts to notify you of material updates, such as by sending a notification to the email address we have on file or by posting a notice on our website. However, we encourage you to periodically review the Privacy Policy at https://apac.elvtr.com/privacy to stay informed of any changes.

Your continued use of our services after the posting of any updates constitutes your acceptance of the revised Privacy Policy. If any modifications require specific notice or consent, such as parental consent under applicable laws, we will take appropriate steps to comply with those requirements at that time. For questions or to exercise your privacy rights, please contact us at privacy@elvtr.com.