1. 1. Who we are

    Elevates Digital Services OÜ is a private limited company registered in the Estonian Commercial Register under registry code 17455911, at Tartu mnt 67/1-13b, 10115 Tallinn, Estonia. We decide why and how the personal data described here is used, which makes us its controller.

    For anything about your data, write to [email protected], or to Hussein S Mohammedameen, member of the management board, at [email protected].

    We are not required to appoint a data protection officer, and we have not appointed one.

  2. 2. What we collect, why, and for how long

    When youWhat we receiveWhyLegal basisHow long we keep it
    Visit the websiteIP address, browser and device details, the page requested, date and timeTo deliver the website and protect it from attacks and abuseOur legitimate interest in running a secure website, Article 6(1)(f) GDPRUp to 12 months in server and network logs
    Allow analytics cookiesPages viewed, clicks, device type, approximate location derived from your IP address, a random identifierTo see which pages people use, and improve the restYour consent, Article 6(1)(a)14 months in Google Analytics
    Send the contact formName, email address, company if you give it, your message, and the signals hCaptcha uses to tell people from automated programsTo reply and discuss your projectSteps you ask for before a possible contract, Article 6(1)(b). The security check rests on our legitimate interest in stopping spam, Article 6(1)(f)24 months after our last contact. Web3Forms keeps its own copy for at most three years, then deletes it automatically
    Book a callName, email address, any answers you give in the booking form, the time you choose, and the Google Meet linkTo hold the callSteps you ask for before a possible contract, Article 6(1)(b)24 months after our last contact
    Write to us by email or WhatsAppWhat you send usTo replyArticle 6(1)(b), or our legitimate interest in answering questions, Article 6(1)(f)24 months after our last contact
    Become a clientContact details of your representatives, the agreement, invoices and paymentsTo deliver the work and keep the accounting records the law requiresPerformance of the contract, Article 6(1)(b), and legal obligation, Article 6(1)(c)For the agreement, then seven years from the end of the financial year for accounting records
    Hear from us firstSee section 5See section 5See section 5See section 5

    We do not record or transcribe calls unless we ask at the start of the call and you agree.

    When a period ends, we delete the data or make it anonymous.

    We do not send newsletters or other marketing emails, apart from contacting businesses as section 5 describes. If we start a newsletter, we will send it only to people who have agreed to receive it, and every issue will let you unsubscribe.

  3. 3. Cookies

    We use one cookie of our own, to remember your cookie choice. Analytics cookies run only after you allow them in the cookie banner, and you can change your choice at any time through Cookie settings at the bottom of every page. The Cookie Notice lists each cookie, who sets it and how long it lasts.

    We do not use advertising cookies. If we start advertising, we will add an advertising choice to the cookie banner, off until you switch it on, and update this statement before any advertising cookie is set.

  4. 4. Who else receives your data

    We share personal data only with the providers below, and only what each one needs.

    ProviderWhat they do for usTheir roleWhere
    Hostinger International LimitedHosts the websiteProcesses data on our behalfEuropean Union
    Cloudflare, Inc.Delivers the website, protects it from attacks, hides our email addresses from spam robotsProcesses data on our behalfUnited States, see section 6
    Google Ireland Limited, with Google LLCGoogle Workspace: our email, calendar, booking page and Google MeetProcesses data on our behalfEU and United States, see section 6
    Google Ireland Limited, with Google LLCGoogle Analytics, only with your consentProcesses data on our behalfEU and United States, see section 6
    Intuition Machines, Inc. (hCaptcha)Checks that a form is sent by a personProcesses data on our behalfUnited States, see section 6
    Web3Creative (Web3Forms)Receives contact form messages and forwards them to our inbox. Its spam filters, CleanTalk and Akismet, check the sender's IP address and email addressProcesses data on our behalf, under a data processing agreementIndia, with servers in the United States and the EU, see section 6

    WhatsApp. If you choose to message us on WhatsApp, WhatsApp handles that message under its own terms and privacy policy.

    Our pages on LinkedIn, Instagram and X. When you visit them, those platforms process your data under their own policies. LinkedIn shares page statistics with us, and for those statistics LinkedIn and we are joint controllers.

    Professional advisers and authorities. Our accountant and our lawyers, when their work for us requires it, and public authorities, when the law requires it.

    A buyer. If we sell the company or its business, the buyer receives client and contact records under a confidentiality agreement.

    Elevates does not sell, rent or trade personal data, and does not make it available to anyone in exchange for payment or any other benefit.

  5. 5. When we contact your business first

    We look for businesses whose websites we could improve and contact them by email or phone. For this we use business contact details that the business has published itself, or that appear in public registers or on professional networks: a person's name, role, business email address or phone number, the company, and what is publicly visible on its website.

    Legal basis: our legitimate interest in offering our services to businesses, Article 6(1)(f).

    Our first message to you says who we are and where we found your details, and links to this section. Every message lets you refuse further messages, free of charge, by replying.

    We keep these details for up to 12 months after our last contact, unless you become a client.

    You can object at any time. Reply "stop" to any message or write to [email protected]. We stop contacting you, and keep only your email address on a do not contact list, so that it stays that way.

  6. 6. Transfers outside the European Economic Area

    Some providers in section 4 process data outside the European Economic Area. Google LLC, Cloudflare, Inc. and Intuition Machines, Inc. are certified under the EU-U.S. Data Privacy Framework, for which the European Commission adopted an adequacy decision on 10 July 2023. Web3Creative, which runs Web3Forms from India, is bound by the standard contractual clauses adopted by the European Commission, through its data processing agreement with us. We rely on the same clauses wherever the framework does not apply.

    Write to [email protected] for a copy of the safeguard that applies to a provider.

  7. 7. Your rights

    You can ask us to show you the personal data we hold about you and give you a copy; to correct it; to delete it; to limit how we use it; and to send it to you or to another provider in a common format, where you gave it to us for a contract or with your consent.

    Where we rely on your consent, you can withdraw it at any time, for cookies through Cookie settings at the bottom of every page. Withdrawing does not affect what happened before.

    Right to object. Where we rely on our legitimate interest, you can object at any time for reasons relating to your situation, and we stop unless we have compelling legitimate grounds that override your interests, or need the data for legal claims. When the purpose is direct marketing, including contacting your business first, we always stop.

    Write to [email protected]. You do not need a form, and it costs nothing. We answer within one month. If a request is complex or we receive many, we can extend this by up to two more months, and we tell you so within the first month. If we cannot tell that a request comes from you, we ask you to confirm your identity first.

    When we correct or delete your data, we pass that on to each provider in section 4 that holds it, and we tell you who they are if you ask.

    We cannot delete records the law requires us to keep, such as invoices, until that period ends. If we refuse any request, we tell you why and how to complain.

  8. 8. Complaints

    You can complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee), or to the data protection authority of the country where you live, where you work or where you believe the infringement happened. We would appreciate the chance to put it right first.

  9. 9. Do you have to give us personal data

    No law or contract obliges you to give us personal data. To reply to the contact form we need your email address and a message, and without them we cannot answer. To book a call we need your name and email address, and without them the booking cannot be made. Everything else is optional.

  10. 10. No automated decisions

    We do not make decisions about you by automated means alone, and we do not build profiles that have legal or similarly significant effects on you.

  11. 11. Children

    Our website and services are meant for businesses and are not directed at children. We do not knowingly collect children's personal data. If you are under 18, please do not send us personal data.

  12. 12. How we protect your data

    Our email, calendar and documents run on Google Workspace. Only the people at Elevates who need your data can reach it, and every account signs in with two step verification. Data travels encrypted between your browser and our website.

    If a personal data breach is likely to result in a high risk to your rights, we tell you without undue delay. We report breaches to the Data Protection Inspectorate as the law requires.

  13. 13. Changes to this statement

    When we change this statement, we update the date at the top. When a change matters to you, such as a new purpose or a new way to use your rights, we tell you before it applies: by email if we have your address, otherwise by a notice on this website.

  14. 14. Language

    This statement is published in English, French, Dutch and Turkish. If a translation differs from the English text, the English text prevails. This never reduces the rights the law gives you.