Data protection-
and confidentiality policy

This DATA PROTECTION AND PRIVACY POLICY (hereinafter - "Policy") has been developed in accordance with the requirements of Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (Directive on Privacy and Electronic Communications) and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data, on the free movement of such data and repealing Directive 95/46/EC (hereinafter - "Law").

This Policy sets forth the procedure for the processing of personal data provided by Customers by ELVTR US LLC (hereinafter referred to as the "Company") who use the website https://de.elvtr.com/ and its individual services to obtain or provide services (hereinafter referred to as the "User" and the "Website", respectively). The Policy specifies the types of personal data collected, the purposes of use of such personal data, the Company's interaction with third parties, the security measures to protect personal data, the conditions of access to personal data, as well as the contact information for Users regarding access to, modification, blocking or deletion of their personal data and answering any questions they may have regarding data protection.

The Company attaches great importance to the protection of confidential (personal) data of all persons who visit the website https://de.elvtr.com/ and those who use the services offered by the website; therefore, the Company is committed to creating and ensuring the protection of the confidentiality of personal data (information or collection of information about an identified or identifiable person) and thus the most comfortable conditions for the use of the website to users.

The text of the Policy is available to users on the Internet at https://de.elvtr.com/privacy. If the user does not agree with the terms of the policy, he must immediately stop using the website.

 

1. Terms and abbreviations

 

The terms used in this policy, but not further defined herein, carry the following meaning:

1.1. personal data means any information that is directly or indirectly associated with an identified or identifiable natural person (the subject of the personal data)

1.2 Company is ELVTR US LLC, duly registered with business address at 300 Spectrum Center Dr, Irvine, CA 92618.

1.3 Processing of personal data means any act (operation) or set of acts (operations) which is performed upon personal data. set of actions (operations) carried out with the use of automated means or without their use in relation to personal data, including their collection, recording, systematization, accumulation, storage, concretization (renewal, modification), retrieval, use, communication (dissemination, transmission, making available), anonymization, blocking, erasure and destruction.

1.4 Automated processing of personal data means processing of personal data using data processing equipment. Notwithstanding the foregoing, automated processing of personal data shall not include automated processing, including profiling, which produces legal effects concerning the User or significantly affects the User in such a way.

1.5 Dissemination of personal data means actions aimed at disclosing personal data to an unspecified group of persons.

1.6 Provision of personal data shall mean actions aimed at disclosing personal data to a specific person or a specific group of persons.

1.7 Blocking of personal data means temporary suspension of processing of personal data (except for cases when the processing is necessary to specify the personal data).

1.8 Use of personal data means actions (operations) with the personal data performed by the Company for the purpose of decision-making or performance of other actions that cause legal consequences in relation to the subject of the personal data or other persons, or otherwise affect the rights and freedoms of the subject of the personal data or other persons.

1.9 Anonymization of personal data means actions as a result of which it becomes impossible to determine the affiliation of personal data to a concrete subject of personal data without using additional information.

1.10. Destruction of personal data means actions as a result of which it becomes impossible to restore the content of personal data in the information system of personal data and/or as a result of which the data carriers with personal data are destroyed.

1.11. Online Program shall mean an educational program where training is provided exclusively via remote technology on the Company's online platform accessible at the following address: https://de.elvtr.com/

1.12. Online Platform is a software of the Company, which is a set of interconnected web services and modules that constitute a unified space for providing services to consumers on the Internet.

1.13. Trial Class is an audiovisual content (webinar) that the Company makes available free of charge, together with all related content, to all Users who register for such webinar. The Company hosts free seminars for all interested Users. The Trial Lesson does not constitute an educational program, either in whole or in part.

1.14. User Agreement means theagreement publishedon the Internet at https://de.elvtr.com/terms, which constitutes an offer by the Company to enter into an agreement with any third party using the Website on the terms and conditions set forth in the User Agreement.

1.15. Website means a set of information, text, graphic elements, design, images, photographic and video materials and other results of intellectual activity, as well as computer programs contained in an information system thatensuresthe availability of this information on the Internet at the network address https://de.elvtr.com/

1.16. Personal Cabinet is an area of the Website that the User can access after registering on the Website by entering a unique username and password.

1.17. Cookies are data automatically transferred to the Company through the use of the Website via the software installed on the User's terminal equipment, including the IP address, geographical location, information on browsers and the type of operating system of the User's terminal equipment, technical characteristics of the hardware and software used by the User, and the date and time of access to the Website. A distinction is made between so-called persistent cookies, which are stored on the computer until the user deletes them, and so-called session cookies, which are automatically deleted when the browser is closed. In addition, a distinction is made between first-party cookies (which are set directly by the visited website) and third-party cookies (which are set by other websites).

1.18. "IP address" is a numerical identifier used by computers on the network to identify a computer each time it connects to the Internet.

 

2. Consent of the user to processing of personal data by the company

 

2.1. The user agrees with the provisions of the policy and gives informed consent to the company to process his personal data under the conditions specified in the policy and the law:

2.1.1. When registering on the website - for the personal data provided by the user to the company by filling in the online registration form, by checking the box "I accept the terms of the offer agreement and agree to the personal data processing policy" when clicking the "Register" button, the user is deemed to have given their consent to the processing of their personal data; by authorization with personal data provided by the user in social networks or electronic services. By clicking the button of the social network or electronic service selected for authorization, the user is deemed to have given consent to the processing of his/her personal data. By clicking the corresponding button, the User agrees that all personal data made publicly available by him/her in the profile of the respective social network or electronic service may be transmitted to the Company.

2.1.2. When entering or changing personal data in the "Personal Data", "My Interests" section of the Personal Cabinet - for the personal data provided by the User when editing information in the "Personal Data", "My Interests" section of the Personal Cabinet. By clicking the "Save" button, the User is deemed to have given his/her consent to the processing of the personal data newly specified or modified by him/her.

2.1.3. When filling in the feedback form - for personal data provided by the User to the Company when filling in the feedback form on the Website and electronic services (Google, etc.). By clicking the button confirming the submission of the form (the buttons may be referred to as "Submit", "Submit Form" or similar), the User shall be deemed to have given his/her consent to the processing of the personal data entered in the fields of the Feedback Form.

2.1.4. When registering to receive information materials and newsletters from the Company - by filling out a newsletter registration form on the Internet. The subscription form is available only after registration. By clicking the "Subscribe" button by checking the box "I consent to the processing of personal data", the user is deemed to have given consent to the processing of his/her personal data.

2.1.5. Registration for the online program - by filling in the fields of the online registration form. By checking the box in the "Registration for training" form when clicking the "Registration" button, the user is deemed to have given his/her consent to the processing of his/her personal data.

2.1.6. Upon sending a scanned copy of the completed consent form for processing personal data by e-mail - for personal data provided by the User to the Company for the purpose of obtaining educational services on the Website as part of the professional training program. By sending a scanned copy of the declaration of consent to the processing of personal data to the e-mail address with the domain name @elvtr.com the User shall be deemed to have given his consent to the processing of his personal data.

2.1.7. Registration for trial lessons - by filling in the fields of the online registration form. By checking the box in the "Registration for training" form when clicking the "Registration" button, the User is deemed to have given his/her consent to the processing of his/her personal data.

2.1.8. For any use of the Website - for personal data automatically transmitted to the Company during the use of the Website by the software installed on the User's terminal device. With the beginning of the use of the Website, the User's consent to the processing of his/her personal data shall be deemed granted.

2.2. The User's consent to the processing of his/her personal data by the Company shall be valid from the moment of granting the consent to the processing (section 2.1. of the Policy) and for the period necessary to achieve the respective processing purpose (section 5 of the Policy).

2.3. The User has the right at any time to revoke his/her consent to the processing of personal data as defined in Section 9 of the Policy.

 

3. Conditions for the provision of personal data by the user

 

The company assumes that the user, by providing his personal data on the website:

3.1. đíonfirms that he/she has all the necessary rights to acquire citizenship rights for himself/herself and to exercise them independently, as well as the ability to create citizenship obligations for himself/herself through his/her actions, to perform them independently and to bear the responsibility in case of non-performance.

3.2. Provide truthful information about himself/herself to the extent necessary for the use of the Website and keep the provided personal data up to date.

3.3. By uploading his picture through his personal cabinet on the Website, agrees that this picture may be used free of charge for purposes other than identification of the User. The User agrees not to upload photos of third parties as pictures of the User.

3.4. Has acknowledged that the information provided by him/her on the Website about him/herself may be made available to other Users of the Website and may be copied and distributed by such Users in the cases and under the conditions specified in Section 6.7 of the Policy.

3.5. Has acknowledged that all telephone conversations made by him/her with an employee of the Company will be automatically recorded for the purpose of monitoring the quality of service provided to the Users, as well as for the resolution of disputes and conflicts that may arise during such telephone conversations. In addition, the User agrees that the telephone calls may be automatically recorded and stored in accordance with the provisions of this Policy.

3.6. Has familiarized himself/herself with this Policy and thus gives informed consent.

 

4. Personal data processed by the company

 

4.1. The personal data of the user processed by the company include:

  • Last name, first name, patronymic;
  • Cell phone number;
  • E-mail address;
  • Account data in social networks and electronic services (links to user profiles in VKontakte, Facebook, LinkedIn, Skype, Google, Twitter, etc.);
  • Images and photos;
  • Job;
  • Country, City;
  • Date of birth;
  • Occupation;
  • Work experience and position held;
  • IP address;
  • Cookies;
  • Internet browser settings and preferences (user agent);
4.2. The Company ensures the protection of data, the transmission of which occurs automatically when advertising blocks are displayed and when visiting pages where the statistical system script ("Pixel") is installed:
  • IP address;
  • Information from cookies;
  • Information about the browser (or other program that calls the ads);
  • Access time;
  • Address of the page where the ad unit is located;
  • Referrer (address of the previous page);
4.3. All accesses to the website are logged in a log file. Other information on user traffic is neither processed nor stored.

4.4. The Company does not collect information the processing of which is required by law, such as information on racial and ethnic origin, political opinions, religious or ideological beliefs, information on trade union membership, criminal convictions and criminal offenses, as well as health data or data on sexual life or sexual orientation, biometric or genetic data.

4.5. The Company collects data on visit statistics for the Website. This data includes, but is not limited to, information about connections, traffic, the User's browser, and the date, time, and duration of Internet use and access to the Website by the User.

4.6. All other personal data not listed above (visit history, browsers and operating systems used, etc.) are subject to secure storage and non-disclosure.

 

 

5. Use of cookies

 

5.1. The Company cares about its Users and tries to make their stay on the Website as pleasant as For this purpose, the Company needs to analyze the behavior, preferences and interests of the Users with the help of cookies. This analysis allows the Company to make the Users' online experience and interaction with the Website, as well as the interface and navigation of the Service, as user-friendly as possible.

5.2. According to the Cookie Guide of the International Chamber of Commerce, the Company uses the following categories of cookies:

  • Essential cookies are necessary for navigation on a website and for the use of certain services, such as access to secure pages, registration and authorization, and search on the website They can also store previous actions of the user when he returns to a page in the same session.
  • Performance cookies collect information about the use of the website. This data is stored on the user's terminal device during browsing sessions. Examples of such data may include the following metrics: time spent on the Website, most frequently visited pages, information about the areas and services of the Website that are of most interest to the user, or the effectiveness of a particular advertising and/or marketing campaign, etc.
  • All information collected through performance cookies is used for statistical and analytical purposes. Some cookie data may be shared with third parties who have the permission of the web resource, solely for the purposes mentioned above.
  • Functional cookies are used to store settings or configurations that are saved on the user's terminal device between browser sessions. Examples of such data may include the following metrics: Username, profile photo, information about comments left, website language, location, information about whether information or selected benefits were previously provided to the user, and other website settings.
  • These cookies also allow users to watch videos, participate in interactions (surveys, polls, etc.) and interact with social networks.
  • Some cookie data may be shared with third parties who have the permission of the web resource, solely for the purposes mentioned above.
  • These cookies store the information provided by the user in order to make visiting or interacting with the website more pleasant and effective.
  • Targeting or advertising cookies are used to provide content that may be of interest to the user. This data is stored on the user's terminal device during browser sessions.
  • Examples of such data may include the following metrics: Tracking recommended text, graphics, audio and video content to avoid retargeting, managing targeted advertising, evaluating the effectiveness of advertising campaigns, information about user visits to other resources when visiting other pages and other setting parameters of the website.
  • The Website may share this information with third parties, such as media clients, advertisers, agencies, and related business partners, so that they can provide high-quality targeted advertising to users.
Third-party cookies and analytics services:
  • The Company uses third-party services such as Facebook, Twitter, Instagram, Alphabet Inc, Gemius and others to deliver, display and analyze content on the Website in a timely manner.
  • The cookies of the companies mentioned as examples may be used on the User's terminal device while using the Website.
  • Please note that the Website has no control over the cookies used by these services.
  • More information about their use can be found on the respective website.
  • Terms of use for Google Analytics - http://www.google.com/analytics/terms/ru.html
Management of cookies:

Important:

  • for mobile web browsers, the configuration of cookie settings may be different;
  • it should be noted that the full functionality of the website is available only through the use of cookies;
  • however, the complete deactivation of cookies may result in you having limited access to the content and not being able to use all the functions of our website.
Contact the Company regarding the use of cookies by sendingan email to support.de@elvtr.com If a user does not allow the use of cookies or intentionally deletes all cookies from their web browser, they will be prompted to allow and use cookies again when they visit the website again. User data collected through the use of cookies is not sold or made publicly available and is the property of the company that owns the website.

 

 

6. Purposes of processing of personal data

 

The processing of the Users' personal data by the Company is carried out exclusively for the following purposes:

6.1. Registration of the User by the Company on the Website, so that the User can fully use the services of the Website.

6.2. Display of the User's profile on the Website in the personal cabinet.

6.3. Establishing and maintaining communication between the User and the Company, providing advice on the provision of services, providing customer and technical support in case of problems related to the use of the Website.

6.4. Contractual fulfillment of the Company's obligations to the User who has registered for the online program for trial lessons.

6.5. Sending of advertising messages by the Company to the User's e-mail address; targeting of advertising materials.
6.6. Improving the quality of service for Users and improving the Company's website by processing User's inquiries and registrations.

6.7. Statistical and other research based on anonymized data provided by the User.

6.8. Publication on the Company's online platform at: https://de.elvtr.com/ , in official groups in social networks and other online communities of the Company, as well as in other advertising and information sources for purposes not related to the identification of the User:

  • of videos recorded in the course of the provision of services;
  • of feedback from the user about the services provided by the company.
However, the user has the right to unsubscribe from the newsletter. Then his name and e-mail address will be automatically removed from the database. To do this, just click on the corresponding item, which is included in every incoming email.

 

 

7. Processing of personal data

 

7.1. Processing and storage of personal data takes place in the data centers, where the facilities necessary for the operation of the website are located. The provided personal data are processed and may be stored in a database or in a separate table of the Website's database. Since the Company's servers are located in different regions of the world, the processing of a particular User's Personal Data may take place in a country other than that of his or her residence. The level of data protection and legislation in this area may vary from country to country. The Company takes the same security measures described in this Policy regardless of the location of the processing of Users' Personal Data. The Company also complies with a number of data protection laws, including the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework.

7.2. The processing of personal data is carried out with the help of automated systems, unless the non-automated processing of personal data is necessary for compliance with a legal obligation.

7.3. The processing of the User's personal data includes the following actions by the Company: Collection, recording, systematization, accumulation, storage, concretization (renewal, modification), retrieval, use, transmission (dissemination, forwarding, making available), anonymization, blocking, erasure and destruction.

7.4. The collection of the User's personal data is carried out in the cases specified in Section 2.1 of the Policy.

7.5. The storage of the personal data takes place (depending on which event occurs first):

  • until their deletion by the user in the "My profile and programs" and "Settings" sections of the personal cabinet;
  • until their destruction by the Company, if the User revokes his/her consent to the processing of the personal data or requests the destruction of the personal data;
  • until the expiry of the consent period (Section 2.2 of the Directive) or until the purposes of the processing of personal data have been achieved.
7.6. Clarification of personal data can be done by the user in the "Personal data" and "My interests" sections of the personal cabinet or by the company upon the user's request.

7.7. The disclosure of personal data by the Company is permitted only in the following cases:

7.7.1. When processing personal data for the purpose of displaying the User's profile to other users of the Website in order to maintain communication, including when providing services remotely In this case, the User's personal data may be made available to the Users registered on the Website in accordance with Sections 2.1.4. and 2.1.8.

7.7.2. For the purpose of publishing User's feedback on the services offered by the Company in various information sources.

7.7.3. For the purpose of publishing video footage recorded during the provision of services in various information sources.

7.8. The disclosure of personal data by the Company to third parties (processors of the Company) is possible under the following conditions:
  • the third party guarantees the confidentiality of the personal data during its processing and use; the third party undertakes not to disclose and distribute the personal data of the users to third parties without their consent;
  • the third party guarantees compliance with the following security measures for the processing of personal data: Using data security measures; detecting and logging unauthorized access to personal data and taking measures to recover personal data; restricting access to personal data; logging and accounting for actions involving personal data; monitoring and evaluating the effectiveness of the personal data security measures applied;
7.9. The destruction of personal data by the Company shall take place in the following cases:
  • in case of deletion of personal data in the "My Profile and Programs" and "Settings" sections of the Personal Cabinet by the User;
  • in case of revocation of the user's consent to the processing of his/her personal data;
  • in the event of a request by the user for the destruction of his/her personal data;
  • after expiry of the consent period (section 2.2 of the Directive).
There is no disclosure of personal data by the Company to third parties, unless such disclosure is required by law, is made at the request of the subject of the personal data or in other cases specified in this Policy. The Company is aware that personal data is a valuable and inalienable content, including the personal non-property rights of individuals, and therefore takes all possible measures to protect the personal data of users who voluntarily and knowingly provide it to the Company.

7.10. Cross-border transfer of personal data. Prior to the transfer, the Company shall ascertain that a third country to which the transfer of personal data is to be made ensures adequate protection of the rights of the subjects of the personal data.

The cross-border transfer of personal data to countries that do not provide adequate protection of the rights of the subjects of the personal data is permitted in the following cases:
  • in the presence of a written consent of the subject of the personal data to the cross-border transfer of its personal data;
  • upon execution of the contract to which the subject of the personal data is a party.

 

 

8. Protection of personal data

 

The Company takes the necessary and appropriate legal, organizational and technical measures to protect the personal data provided by the users from unauthorized or accidental access, destruction, modification, blocking, reproduction, dissemination, as well as other unlawful acts of third parties. However, despite all its efforts, the Company cannot guarantee absolute protection against threats that are beyond its control.

The Company uses standard procedures such as encrypted communications, secure premises, network security systems and password protection systems to ensure the confidentiality of personal data.

The Company grants access to information and personal data only to authorized employees who have agreed to maintain the confidentiality of such information and data in accordance with the Company's requirements.

The Website may contain links to other websites (for informational purposes only). This Policy does not apply to other websites accessed through links. Therefore, the Company recommends that you review the privacy policies of each website before submitting any personally identifiable information by which you can be identified. More here

 

9. User rights

 

The user has the right:

9.1. At his own discretion, to provide personal data to the Company for processing under the conditions specified in the Policy.However, some of the provided personal data are necessary for the conclusion of a User Agreement, and without their provision the conclusion of such User Agreement is not possible;

9.2. Independently make changes and corrections to your personal data in the Personal Data and My Interests sections of the Personal Cabinet, provided that such changes and corrections contain up-to-date and accurate information;

9.3. To delete Personal Data by editing the "Personal Data" and "My Interests" section of the Personal Cabinet;

9.4. To request from the Company the clarification of its Personal Data, its blocking or destruction, if the Personal Data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, as well as to take legal measures to protect its rights;

9.5. Receive, at the latest within thirty calendar days of receipt of the request, except in the cases provided for by law, an answer to the question of whether personal data are being processed, as well as the content of such personal data;

9.6. To make a reasoned request to the personal data controller to object to the processing of their personal data;

9.7. To seek redress in the event of a breach of data protection law, including the lodging of a complaint with a supervisory authority;

9.8. to update, access, amend, block or delete your personal data, to withdraw consent to the processing of personal data you have provided to the Company under this Policy, or to make comments, requests or complaints regarding your personal data processed by the Company, please contact the Company by email at support.de@elvtr.com

9.9. To notify the Company of his/her requests and demands, including in relation to the use of his/her personal data and the withdrawal of consent to the processing of personal data. The notification may bemadein writing to the Company's address (Section 11 of the Policy) or by e-mail (the document must be sent from the User's e-mail address specified as the authorized e-mail address during the registration on the Website or in the Agreement) to support.de@elvtr.com The Company shall address and respond to the User's requests and/or take action within 30 calendar days from the date of receipt of the request.

9.10. In addition to the rights specified in this Policy, the User has the possibility to exercise all the rights provided by law.

 

10. Changes in the policy

 

10.1. The Company reserves the right to make changes and amendments from time to time and without prior notice to the User, including when the legal requirements change. It is the user's responsibility to be aware of this policy each time he/she visits the website.

Der Benutzer ist dafür verantwortlich, sich bei jedem Besuch der Website über diese Richtlinie zu informieren.

10.2. The new version of the Policy shall become effective upon its publication in the relevant section of the Company's website. By continuing to use the Website or its services after the publication of a new version of the Policy, the User agrees to the Policy and its terms. If the User does not agree with the terms of the Policy, the User must immediately cease further use of the Website and its Services.

10.3. Please check the Policy from time to time to keep up to date with any changes or additions.

 

11. Company information

 

ELVTR US LLC

Correspondence address: 300 Spectrum Center Dr, Irvine, CA 92618

E-mail address: support.de@elvtr.com