Last updated: November 8, 2023

1. Introduction

At Elev, we understand that privacy is a fundamental right. Our updated Privacy Policy reflects our commitment to protecting the privacy and security of our users' personal information. We've crafted this policy to be transparent, empowering, and user-centric.

Purpose of This Policy

This Privacy Policy informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

2. Scope of This Privacy Policy

Services Covered

This Privacy Policy applies to all services and features provided by [Your Company Name] through our website, mobile application, customer service interactions, and other related services where this policy is referenced, regardless of how you access or use them, including through mobile devices.

Users Covered

The Policy applies to all users of our platform, including students seeking accommodation, hosts offering their properties, and any visitors interacting with our services. We are dedicated to protecting the privacy of all users, both within Canada and globally.

Jurisdictions and Applicability

While [Your Company Name] primarily serves users in Canada, we extend our privacy considerations to our international users, particularly those in India and Nigeria. We are dedicated to complying with local data protection laws, the General Data Protection Regulation (GDPR), and other global privacy standards as applicable.

3. Information We Collect

Information from Students

• Personal Identification Information: We collect full legal names, dates of birth, contact information (such as email addresses and phone numbers), and government-issued identification numbers.

• Educational Background: Details about the educational institution, field of study, and level of education to help us tailor our services.

• Financial Information: Proof of funds and financial background information to confirm the ability to fulfill payment obligations.

• Payment Data: Through Stripe integration, we collect payment method details, transaction history, and billing information to process payments securely.

Information from Hosts

• Personal Information: Full legal name, contact details, and identification information for the purpose of creating a secure and trusted environment.

• Lease Agreements: We facilitate the creation and storage of lease agreements on our platform. These documents may include personal information from both the student and the host, as well as additional details related to the lease terms.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

• App Store Connect. Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/

• Mixpanel. Their Privacy Policy can be viewed at https://mixpanel.com/legal/privacy-policy/

• Google Analytics. Their Privacy Policy can be viewed at https://policies.google.com/technologies/partner-sites

• Facebook Analytics. Their Privacy Policy can be viewed at https://www.facebook.com/privacy/policy/

Usage, Performance and Miscellaneous

We may use third-party Service Providers to provide better improvement of our Service.

• Typeform. Their Privacy Policy can be viewed at https://admin.typeform.com/to/dwk6gt/

• Digital Ocean. Their Privacy Policy can be viewed at https://www.digitalocean.com/legal/privacy-policy/

• Ionic Framework. Their Privacy Policy can be viewed at https://ionicframework.com/privacy

• Apple Developer Program. Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/

• Firebase. Their Privacy Policy can be viewed at https://policies.google.com/privacy

• Google developer program. Their Privacy Policy can be viewed at https://policies.google.com/privacy

• One signal. Their Privacy Policy can be viewed at https://onesignal.com/privacy_policy

How We Collect Your Information

We collect information through various means, such as when you:

• Create an account on our platform.

• Use our services or interact with our website or app.

• Voluntarily provide information in free-form text boxes through the platform or through responses to surveys or questionnaires.

• Send us an email or communicate with us in any other way.

Why We Collect Information

• To Provide Services: We use your information to operate, maintain, and provide to you the features and functionality of the Service.

• To Improve and Optimize: We use your information to understand and analyze the usage trends and preferences of our users.

• To Communicate: We may use your information to communicate with you directly, such as to send you updates, security alerts, and support messages.

Legal Basis for Processing

The processing of your data is grounded on the following legal bases:

• Consent: We process certain information based on the consent you expressly grant to us at the time we collect such information.

• Contractual Necessity: We process personal information as a matter of 'contractual necessity', meaning that we require certain information to provide the Service to you.

• Compliance with a Legal Obligation: We may process your information when we have a legal obligation to do so, such as in response to court orders or legal process.

• Legitimate Interests: We may process your information when it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights.

4. Sharing and Disclosure of Information

Disclosure to Third Parties

At Elev, we only share information with third parties under the following circumstances:

• Service Providers: We employ third-party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

• Business Transfers: If Elev is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred.

• Legal Requirements: We may disclose your Personal Data in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of [Your Company Name], prevent or investigate possible wrongdoing in connection with the Service, protect the personal safety of users of the Service or the public, or protect against legal liability.

Security of Data Transfers

• We take precautions to ensure that when your data is shared with third parties, it is done so with the utmost security, using encrypted and secure channels. We also vet our third-party service providers to ensure they comply with high standards of data protection.

5. Your Data Rights and Choices

The Rights You Have Over Your Data

• You have the right to access, update, or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

• You have the right of rectification. If your information is inaccurate or incomplete, you have the right to have the information corrected.

• You have the right to object. You can object to the 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 have the right to withdraw your consent at any time.

• You have the right to complain to a Data Protection Authority about our collection and use of your personal information.

Exercising Your GDPR Rights

• For individuals in the European Economic Area (EEA), you have certain data protection rights under the General Data Protection Regulation (GDPR). [Your Company Name] takes steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

• If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

Your Data Choices

• Account Information: You may update, correct, or delete information about you at any time by logging into your online account and modifying your information or by emailing us.

• Cookies and Tracking Technologies: You may adjust your browser settings to refuse all or some browser cookies or to alert you when cookies are being sent.

• Promotional Communications: You may opt out of receiving promotional communications from us by following the unsubscribe instructions in those communications or by contacting us directly.

6. Security Measures

How We Protect Your Data

• [Your Company Name] takes the security of your data very seriously. We implement a variety of security measures designed to maintain the safety of your personal information when you enter, submit, or access your personal information.

• Despite our efforts, no security measures are impenetrable. In the event of a security breach, we have in place procedures to address such situations and will notify you and any applicable regulator when we are legally required to do so.

Our Commitment to Data Security

• To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

• Regular Cybersecurity Assessments: We regularly review and update our security practices to improve the protection of your information and to ensure our systems are secure and resilient.

7. Data Retention and Deletion

How Long We Keep Your Data

• Elev retains personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).

• When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Your Right to Deletion

• You have the right to request that we delete your personal information under certain conditions. Upon receiving such a request, we will confirm whether the personal information has been deleted or the reason why it cannot be deleted (for example, because we have to keep that information for legal reasons).

8. Information Security

Commitment to Security

• Elev takes the security of your personal information very seriously. We implement a range of security measures designed to protect your personal information from unauthorized access, alteration, disclosure, or destruction.

• Our security measures include, but are not limited to, data encryption, firewalls, and physical access controls to our data centers. Our employees are bound by confidentiality obligations and may be subject to disciplinary action, including termination and criminal prosecution, if they fail to meet these obligations.

Security Breach Procedures

• In the unlikely event of a data breach, we will promptly notify you and the relevant authorities as required by law. We have incident management policies and procedures in place to handle such an event effectively.

9. International Data Transfers

Transferring Data Across Borders

• Elev is headquartered in Canada, and we store data in Canada and other countries through third parties that we use to operate and manage our services.

• When we transfer your personal information internationally, we ensure that it is protected and transferred in a manner consistent with legal requirements. If you are located in the European Union, the European Economic Area, or other regions with laws governing data collection and use, we comply with legal frameworks that establish a mechanism for the lawful transfer of data.

10. Changes to This Privacy Policy

Updates to Policy

• Elev may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

• You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the beginning of the Privacy Policy.

Acceptance of Changes

• By continuing to use our services after those changes become effective, you agree to be bound by the revised Privacy Policy. If you do not agree to the new terms, please stop using our services.

11. Your Rights and Choices

Access, Review, and Update of Personal Data

• As a user, you have the right to request access to the personal information that [Your Company Name] holds about you and to request corrections or updates to this information.

• To exercise these rights, please log in to your account settings or contact us directly at [Contact Information].

Deletion of Personal Data

• You may also request the deletion of your personal information, subject to necessary retention for legal or operational purposes, such as fraud prevention or enforcing our agreements.

Data Portability

• Where applicable law provides for the right of data portability, you may request that we transfer a copy of your personal information to another entity.

Opt-Out of Communications

• If you no longer wish to receive marketing or promotional communications from us, you may opt-out by following the unsubscribe link or instructions provided in any email we send.

12. Contact Us

Questions or Concerns

• If you have any questions or concerns about this Privacy Policy or our treatment of your personal data, please contact us at:

  • Email: hello@elevhomes.ca

Data Protection Officer

• We have appointed a Data Protection Officer to ensure continuous responsibility for managing and protecting personal data. Our Data Protection Officer can be contacted at [DPO Contact Information].

13. Governing Law and Jurisdiction

Applicable Law

• The terms of this Privacy Policy and any disputes related to it are governed by and in accordance with the laws of Canada, without giving effect to any choice of law rules that may require the application of the laws of another jurisdiction.

Jurisdiction

• By using our services, you consent to the exclusive jurisdiction of the courts of Canada for any disputes arising out of or relating to this Privacy Policy or your use of our services.