Privacy Policy

1. Introduction

1.1 This Elate Platform Privacy Policy, together with our Terms and Conditions and any       other documents referred to in it, describe how Elate, operated by Cross Digital Ltd registered under company number 10157215, (“Cross Digital Ltd.”, “we”, “us”) will process any personal data we collect from you, or which you provide to us, in the course of using the website (the “Elate Platform”) services to which you are granted access (the “Services”).

1.2 It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.
1.3 By accessing or using the Elate Platform and our Services, you acknowledge that you have read and understood this Privacy Policy, and agree and consent to the use, processing and transfer of your personal data by us, as described in this Privacy Policy.  
1.4 Under Data Protection Law we are a Data Controller. We are ICO registered with registration number ZA241061.. “Data Protection Law” means all applicable legislation in force from time to time in the United Kingdom applicable to data protection and privacy including, but not limited to, the UK GDPR, the Data Protection Act 2018 (and regulations made thereunder), and the Privacy and Electronic Communications Regulations 2003 as amended, and any successor legislation.

2. Scope of our Services

2.1 We operate a platform that allows social care providers to manage the care of their clients. The Elate Platform enables the care staff of social care providers (“Users”) to access and add to the care and personal records of individuals that they care for (“Service Users”) on mobile devices.
2.2 Through the Elate Platform website, service managers or those deemed responsible enough to have administrator access (“Managers”) can manage access rights to the System and the profiles of Users and Service Users.

3. The information we collect

3.1 When you access the Elate Platform and/or use our Services, there are a number of ways in which you provide information and other data to us. You may be asked to provide us with the following personal information:
Full name
Email address
Date of birth
Medical history
Other care documents and information.

3.2 Users may be required to input information for their Service Users, which may include providing detailed information on their medical history.
3.3 By accessing the Elate Platform, you consent to us processing and collecting this data, on the terms and for the reasons which are explained below.

4. How your information is used

4.1 As is true of most websites, it will be possible to gather information from your computer or device such as your IP address, browser type, referring/exit pages, operating system and other information. This may be used to:
Create your personal Elate profile.
Enable communication between all Users.
Enhance user experience and improve our website/Elate Platform.
Drive future product development in line with customer platform and technology use.
Send you push notifications when you are using the Elate Platform (if you do not want to receive these notifications, you can amend your settings from your account within the Elate Platform and you can contact us at to request no further notifications).
Send out a newsletter, service alerts or marketing communications.
Respond to your questions and concerns.
4.2 Certain features of the Elate Platform (such as uploading or downloading content) may need to access information on your device in order to work. By using such functionality, you consent to Cross Digital Ltd accessing your device and information. If we can, we will ask you before the Elate Platform accesses your device or information.

5. How to edit, delete or access your information

5.1 You have the right to ask for a copy of any personal information that we hold about you, to correct any inaccuracies and to update any out-of-date information. You can also ask us not to send you direct marketing communications. However, please note that we may continue to send you service-related, non-marketing communications.

5.2 If you wish to exercise any of these rights or wish to object to our use of your personal information, please write to us at .

6. Sharing your information

6.1 Except as described below, we will not share your information with any third parties.
6.2 We may disclose the information you provide us:
To other Users and Managers from your organisation and their respective Service Users.
To our third-party APIs, including but not limited to Intercom and Google Analytics.
To any of our group companies (which means our subsidiaries, and our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
To protect the rights, property, or safety of ourselves or others, as required by law under website regulation. This may include disclosing information to other companies and organisations in connection with fraud protection and credit risk reduction.
To protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, when we believe in good faith that disclosure is necessary.
If Cross Digital Ltd. is involved in a merger, acquisition, or sale of all or a portion of its assets, to any prospective seller or buyer of all (or part of) our business or assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
As part of a completely anonymised data set to research bodies or other organisations to perform analysis.
To any other third party with your prior consent to do so.

6.3 We will never pass your information or your Service Users’ information to a third party for them to use in their own direct marketing without your express consent.
6.4 Please note, that if you click on or follow any links from the Elate Platform to external websites, our Privacy Policy will no longer apply to you. Please check the privacy policies of any such external website or app before submitting any personal data, as we cannot accept any responsibility or liability in relation to them.

7. Security, data retention and storage

7.1 The security of your personal information is important to us. All information you provide to us is stored using Amazon Web Services and hosted within the European Economic Area (“EEA”).
7.2 Any payment transactions and database information will be encrypted using SSL technology and AES-256 respectively.

7.3 We will retain your information for as long as needed to provide you Services via the Elate Platform. Once your account has been deleted, we will only retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
7.4 If you wish to cancel your account or request that we no longer hold your personal information, contact us at .

8. International transfers

8.1 Information we collect may be transferred to, stored and/or processed in any country or territory where one or more of our partners or third-party service providers (for example, our hosting company) are located or maintain facilities, including destinations outside the EEA.
8.2 While other territories may not have the same standards of data protection as those within your home country, we will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.
8.3 By submitting your personal data, you agree to this.

9. Contacting you

9.1 We may contact you from time to time about Cross Digital Ltd, including marketing messages relating to Cross Digital Ltd. We will do this electronically, for example by email, text, notifications or other messages on your Elate Platform, mobile device, telephone or by post.
9.2 We may contact you with information about our products and services (and those of specially selected parties that may be of interest to you) in line with your marketing contact preferences provided to us either through the Elate Platform or by emailing us. All such communications will come from Cross Digital Ltd.

10. Use of location data

10.1 The Elate Platform may make use of location data sent from your web browser. You can turn off this functionality at any time by switching off the location settings for Elate on your browser.
10.2 If you use these services, you consent to the transmission, collection, maintenance, processing and use of your location data and queries to provide and improve location-based and road traffic-based products and services, by us, our partners and licensees. You may withdraw this consent at any time by turning off the location services setting on your mobile device.

11. Syncing with other apps

11.1 The Elate Platform may enable a User to sync their Elate Platform with the camera feature on their device. Photos will be stored in the Elate Platform and not on Users’ devices. We may ask permission to sync with your camera on your device to:
Enable uploading your photos into the care record of Service Users.
Scan barcodes of medications, stickers or other products.

11.2 By using the Elate Platform, you accept that:
Other Users, Managers and Administrators from your organisation will have access to the uploaded photos.
If you sync your camera with the Elate Platform, you consent to us accessing your photos and storing these solely for the purposes described above. We will not collect or store any names, emails, addresses or other contact information from your device. If you do not want to use this feature or do not want your photos to be uploaded or accessed in any way you may unsubscribe from our Services.

12. Your rights

12.1 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by contacting us at .
12.2 The Act and the GDPR give you the right to access information held about you. Your right of access can be exercised in accordance with the Act and the GDPR.
12.3 You also have the right to:
Access the information that we hold about you.
Be informed of what data we hold and the purpose for processing the data as a whole or in parts.
Request data to be erased/be forgotten by ourselves and our affiliates (this is not an absolute right).
Rectify information that we hold about you that is incorrect or incomplete by ourselves and affiliates.
Restrict processing of the information we hold about you (so that inaccuracies may be corrected etc.).
Object to the processing of your data.
Obtain and reuse the information that we hold about you.
You may revoke your consent at any time by emailing us at .

13. Accessibility and changes to this Privacy Policy

13.1 We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the website  prior to the change becoming effective. We encourage you to periodically review the website for the latest information on our privacy practices.
13.2 This Privacy Policy and all changes made hereto as described in the previous paragraph remain effective unless and until we inform you otherwise via a push notification through the Elate Platform, through email (sent to the e-mail address specified in your account) or by means of a notice on our website prior to the expiration of this Privacy Policy.

14. Contact

14.1 If you have any questions about our Privacy Policy and the data we hold on you, or you would like to exercise your data protection rights, you can contact us at .

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