Privacy Policy•Elatra•Achieve long-term success by empowering your talent

Partners, Associates, Colleagues and Contractors Personal Information Privacy Policy

Welcome to Elatra Inc. We are excited to collaborate with you and support your professional development and career growth. As you would expect, to effectively deliver our services, we gather and utilize information related to you.

Elatra Inc. is devoted to respecting and protecting your privacy. This Personal Information Privacy Policy outlines the rights you have concerning the personal data we collect, process, and share.

Please read it attentively.

Security reporting

If you have a security concern or believe you have found a vulnerability in any part of our infrastructure or processes, please contact us at security@elatra.io.

Terms that we use in this Statement:

When we use “Policy” we mean Partners, Associates, Colleagues and Contractors Personal Information Privacy Policy.
When we use “Company” or “us” in the Policy, we mean Elatra Inc., registered office at 1407 Calle Mirador, Unit F, San Clemente, CA 92672.
When we use “you” in this Policy, we mean you.
This Policy is about Personal Information - information about people, facts about them and their opinions. And we use the term “Personal Information” in this Policy.
This Policy is not about information about the Company, while sometimes the two might overlap.

What type of personal information we collect and utilise

The Company typically collects personal information, which may include but is not limited to:

Your name, birth date and place, contact information, and qualifications (education, training courses, and internships), proof of identity and work eligibility, and any additional information provided in your resume or CV.
Records of any correspondence if you contact us.
Your name, email, and scheduling preferences if you voluntarily provide them for our calendar scheduling tools.
Feedback regarding you from our staff, customers and third parties you collaborate with, as well as performance evaluations.
Your opinions and feedback about others, including us and our services, collected through satisfaction surveys.
Assessment or test results, which you consent to being used for our selection process and development decisions. These results are not shared with third parties or affiliates unless legally required or authorised by you.
Data on your usage of our systems, such as IP address, browser, timestamp, location, traffic data, and accessed resources, to enhance future user experiences.
Aggregated, anonymised data for testing, research, and analysis to improve our services, create new features and products, and develop solutions related to our services.

Calendars availability and events information

All our users may connect their calendars to their Elatra accounts. Elatra's use of information received from Google APIs adheres to the Google API Services User D a ta Policy, including the Limited Use requirements.

When a user's calendar is connected, it allows us to:

(1) Get free/busy data from the user's calendar.

It includes the start time and the end time of events that are marked as "busy". We do not fetch any other information from user calendars.
We do not save this data, it is only needed during the session scheduling process.
This part of the integration makes the session scheduling process more convenient, because: (I) Users will see their own "busy" time slots directly in the scheduling widget of the Elatra app; (II) When a coach's calendar is connected, the Elatra platform will know the coach's actual free/busy time information. With this data received, all time slots that are marked as "busy" in the coach's calendar will not be allowed to be booked by users.

(2) Synchronize coaching session events into the user's and/or coach's calendar.

This part of the integration allows calendar users: (I) See Elatra events in their calendar; (II) Get notifications for these events; (III) Start a coaching session with a direct link from a synchronized event in their calendar.
The Elatra platform creates coaching session events and works only with these events that were created by the platform. We do not fetch any other data from user calendars.

Users have the ability to stop calendar integration and unlink their calendars at any time.

Upon employment with the Company, we will also collect:

Your nationality, ID documentation, address verification, and proof of work eligibility (visas, work permits, etc.).
Gender, age, and ethnicity data aggregated and anonymised, for fairness research as mandated by law.
Payroll details, including bank account information, national insurance or social security numbers, tax codes, salary and benefits information, and any voluntary deductions requested by you.
Records of attendance, project time allocation, training, promotions, supervision, investigations, and disciplinary matters.
Copy of your indemnity insurance.
Information you provided in your coaching profile, such as information about yourself, such as your coaching style, business and leadership experience, areas of expertise, professional accreditations and memberships, languages you speak.
Information about your legal name in case you operate as a business.
Information about your use of our IT systems and facilities.
Information about your dependents and next-of-kin.
Travel details (travel data, credit card information, passport number, incurred expenses) for organising and reimbursing travel-related activities, including transport, hotels, catering.
Photos and videos from training, CPD or similar events, with an option to request not to be photographed or recorded.
Information about any disabilities and required workplace accommodations. In some cases, we may collect other data as permitted by law.

What is the purpose of using your personal information?

The Company collects and processes your personal information for the following purposes:

Comply with legal and regulatory obligations.
Manage our relationship with you, including communicating about our services and addressing any inquiries or concerns.
Deliver the support to you, such as identifying an appropriate role within the Company, assisting with onboarding, and training, or streamlining the application process for new opportunities within the Company.
Enhance and refine our systems and processes.
Conduct research and perform statistical and analytical studies.

Upon commencing employment with the Company, the following additional purposes apply:

Fulfil our responsibilities as your employer or client (for individual contractors).
Comply with your employment contract, contract for services, and all other agreements and regulations governing our employment or contractual relationship with you.
Streamline and improve the Company’s human resource management, including execution on trainings, absence management, expense management, disciplinary procedures, investigation of incidents and complains, and other human resource activities.
Administer shares and other benefits you may be eligible for.
Ensure the security and protection of individuals, facilities, systems, and assets.
Monitor compliance with internal policies and procedures.
Manage communication and other systems utilised by the Company.
Fulfil obligations and rights and collaborate with investigations conducted by law enforcement, government agencies, regulators.
Engage in any potential or actual M&A, investment, or joint venture.

We may disclose information that we collect in the following circumstances

We may disclose information that we collect to third parties to fulfill the purposes outlines above and in the following circumstances:

To our customers: we share collected information with customers seeking service engagements you may be qualified to perform on behalf of the Company or for whose employees you are providing services through the Company. They are contractually and otherwise obligated to maintain the confidentiality of your data, both to us and to you.
To our suppliers and service providers: For instance, we may engage a provider to execute administrative and operational tasks in support of our relationship with you. These providers are subject to contractual and other legal obligations to maintain the confidentiality of your data and uphold your privacy, with access to only the information necessary for their duties.
To government agencies, law enforcement, or regulators to comply with local, state, federal, international, or other applicable laws if, at our sole discretion, we determine that we are legally obligated or authorized to do so or that it would be prudent to do so.
In relation to due diligence for (or execution of) a merger, acquisition, service provider change, or other business transaction, we may disclose your data to prospective sellers or buyers, new service providers, and their advisors.

Please note that the Company neither rents, sells, nor shares your personal data in a personally identifiable manner with anyone for marketing purposes.

Can your personal information be transferred or stored outside your country of residence?

Your personal information may be transferred to and processed in countries other than your home country.

We only transfer your personal information to countries that offer a sufficient level of data protection as determined by the European Commission or where we have implemented appropriate safety measures to ensure the privacy of your personal data.

What is the duration for retaining your personal information?

The Company may need to, and in certain cases is obligated to, depending on the nature of the data, store your information for an extended period after your employment with us has concluded.

The duration we need to preserve information may vary from 3 to 7 years. The Company retains sensitive personal information only for as long as reasonably necessary.

What rights can you exercise?

Right to access and obtain a copy of your personal information. You have the right to request confirmation of whether we process any of your personal information. If we do, you have the right to access your personal information and request information how we process your personal information.
Right to correct your personal information. If you can prove that the personal information, we hold about you is incorrect, you can request that the information be updated or corrected.
Right to deletion/right to be forgotten. If we don't need to retain or process the data for any other reason, you can request that we stop processing or delete (some or all) of your personal information.
Right to restrict. Under certain circumstances, you have the right to restrict the processing of your personal data. However, such restriction may limit the services you can receive from the Company in some cases.
Right to object. If the Company's processing of your data is based on the Company's legitimate interest (and no other processing ground) or involves direct marketing, you have the right to object to the Company processing of your data, referring to your specific situation.
Right to file a complaint with the data protection authority in the place where you live or work, or where you believe an issue concerning your data has arisen.
California residents (in accordance with the California Consumer Privacy Act 2018) have the right to request a notice that identifies the categories of personal information we share with our affiliates and/or third parties for marketing purposes and provides contact information for such affiliates and/or third parties.

All requests are subject to applicable law. In compliance with the relevant law, we will take measures to verify your identity and the request before processing any request, such as requiring you to provide information about yourself, your account, your prior interactions with us, and/or any other additional information required by law.

Changes to this Privacy Policy

The Company reserves the right to update this privacy policy at its discretion.

When significant alterations occur to the Privacy Policy, we will provide you with appropriate notice according to the circumstances, such as displaying a prominent notice on the website or sending you an email.

Please ensure you read any such notices attentively.

This Privacy Policy was last updated: 24 Jul 2023

If you have any questions about this Personal Information Privacy Policy, please contact us by email at: privacy@elatra.io