Elevay Citizenship & Residency by Investment

Privacy Policy

Effective Date: May 15, 2018

Welcome and thank you for your interest in Elevay LLC (“Elevay”, “we” or “us”), our website at https://elevay.com and subdomains (“Sites”), related services provided by us, and all other communications with individuals through written or oral means, such as email or phone, (collectively, together with our site, our “Service”)

This Privacy Policy explains:

  1. Personal Information We Collect;
  2. How We Use Your Information;
  3. How We Share Your Information;
  4. Storage, Transfer and Processing of Your Information;
  5. How We Protect Your Information;
  6. GDPR Specific Regulations;
  7. Interest Based Advertising;
  8. Remarketing;
  9. Compromise of Personal Information;
  10. Your Choices About Your Information;
  11. Dispute Resolution;
  12. Our Retention of Your Information;
  13. Children’s Privacy;
  14. Notification Procedures;
  15. Links to Other Websites;
  16. Social Media Widgets;
  17. Changes to Our Privacy Policy

We understand the importance of how your information is used and shared and are committed to providing a clear and transparent policy on our data collection practices. We will not use or share your information with anyone except as described in this Privacy Policy.

1. Personal Information We Collect

We collect different types of personal information in the delivery of our Services. The legal basis for the processing of personal data is primarily that this information is necessary to provide a Service and is in Elevay’s legitimate interest. Services include the performance of tasks as requested by you, such as a consultation, or, in the case of clients, the performance of contracted duties.

  1. User-provided Information: When you use a service provided by Elevay, we may collect and you may provide personal data. Examples of Personal Data includes your name, email address, mailing address, and phone number. Personal information also includes other information, such as geographic or language preferences, which may be linked to personally identifiable data. You may provide us with Personal Data in a number of ways. For example, you may submit a contact form on our website or through communication with any of our staff members.
  2. Automatically Collected Information: Through the use of our website, we may automatically record certain information by using various types of technology such as cookies and tracking technology. We collect this information from all visitors. This automatically collected information may include IP address, browser type, visit duration, pages visited, date and time of visit and more. We may also use this technology to collect information regarding interaction with email messages or other communications, such as email opens and clicks.
  3. Information from other sources: We may obtain information, including Personal Data, from third parties and sources other than the methods mentioned above. This could be through partners, advertisers, and other service providers to the extent necessary to fulfill the Service. We will treat this Personal Data in accordance with this policy.

2. How We Use the Information We Collect

The information collected by Elevay is used in a variety of ways to provide the Service and operate our business, including the following:

  1. Operations: We use the information to operate, maintain, enhance, and provide all of the features of the Site and Service. We process Personal Data in accordance with the method of collection and directions provided by the Client. For members of the European Union, the legal basis for this processing is Article 6(1)(f) of the General Data Protection Regulation (GDPR).
  2. Improvements:We use information to better understand and analyze the usage trends and preferences of our visitors and Clients. This is done to help improve the Service and Sites, develop new content, improve current services and offer additional services.
  3. Communications: We may use provided information, such as email or phone number to contact that Visitor as required to (i) fulfill the Services requested, such as consultations or proposals or (ii) provide updates on promotions, news, related products and services offered by us and third parties we work with. You have the ability to opt-out of receiving communications as described below under “8 – Your Choices About Your Data”. The legal basis for the processing can be found in Article 6(1)(a) and Article 6(1)(b) of the GDPR.
  4. Services: We may also use information provided as necessary for the performance of a contract or at the request of a Visitor prior to entering into a contract. Examples include gathering of documentation required for a citizenship application or to prepare an accurate proposal. The legal basis for processing is Article 6(1)(b) of the GDPR.
  5. Cookies and Tracking Technologies: We use automatically collected information from cookies and tracking technology to: (i) provide customized advertisements, content and information (ii) monitor and analyze the effectiveness of our Service, Sites and Marketing Activities (iii) monitor aggregate site usage metrics such as total visitors and bounce rate (iv) track entries, submissions or interactions with any promotions or marketing activities. Cookies are an industry standard and most major web sites use them. A cookie is a small text file that our site may place on your computer as a tool to remember your preferences. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.
  6. Analytics: We use Google Analytics to measure and evaluate traffic and trends to our Sites. We also use Google Analytics to aggregate data regarding demographics about our user base as a whole. Google operates independently of Elevay and has its own privacy policy. Google may use the information collected through Google Analytics to evaluate activity on our site. For more information, please see – https://policies.google.com/privacy. You may also opt out of Google Analytics by installing a browser add-on provided by Google – https://tools.google.com/dlpage/gaoptout

3. How We Share Your Information

  1. Personally Identifiable Information: Elevay will not rent or sell your personally identifiable information to others. We may store personal information in locations outside of the direct control of Elevay, for instance, on the servers or databases of third-party service providers relevant to providing the Service or Site. These third-parties may have access to, or process Personal Data as part of providing services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions and our contracts with them require them to maintain the confidentiality of such information. All personally identifiable information will remain privately stored, unless consented by the individual, for example public testimonials or reviews. Personally Identifiable information may be shared with third-parties to the extent necessary to fulfill the Service, for example, lawyers or due diligence firms.
  2. Non-Personally Identifiable Information: We may share non-personally identifiable information (such as anonymous usage data, number of visitors) for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist third-parties in understanding our Clients’, Users’ and Visitors’ interests, habits and usage patterns as it relates to the Service.
  3. Instances Where We Are Required To Share Your Information: Elevay will disclose your information where required to do so by law, if subject to subpoena or other legal proceeding or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) to enforce our Terms of Service or to protect the security or integrity of our Service; and/or (iii) to exercise or protect the rights, property, or personal safety of Elevay, our users or others.
  4. What Happens In The Event Of A Change Of Control: We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as customer names and email addresses, and other User information related to the Elevay Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

4. Storage, Transfer and Processing of Your Information

Your information, as collected through Elevay’s Service, may be stored and processed in the United Arab Emirates, United States, or any other country in which Elevay or its subsidiaries, affiliates or service providers maintain facilities. Elevay may transfer information that we collect about you, including personal information, to other third party service providers as necessary to fulfill the requirements of the Service. You may request further information on the storage and the third-party services used in processing your personal data by contacting privacy@elevay.com. Other countries may not have the same data protection framework as the country from which you may be using the Services. When we transfer your information, we will protect it as described in this privacy policy.

5. How We Protect Your Information

Elevay is concerned with protecting your privacy and data. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal data in our possession. But we cannot ensure or warrant the security of any information you transmit to Elevay or guarantee that your information may not be accessed, disclosed, altered or destroyed by any breach of the industry standard physical, technical or managerial safeguards we have implemented. No method of transmission over the internet or method of electronic storage is 100% secure, therefore we cannot guarantee its absolute security, and so you do so at your own risk. If you believe your Personal Data has been compromised, please contact privacy@elevay.com. If we learn of a security breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

6. GDPR Specific Regulations

Elevay self-certifies compliance with the EU GDPR framework as set forth by the European Union regarding the collection, use and retention of personal data from European Union member countries. Elevay has certified that adheres to the requirements of notice, choice, onward transfer, security, data integrity, access and enforcement.

DATA Controller:
Elevay Global
United Arab Emirates
Saleh Bin Lahej Building,
Office 210, Al Garhoud St,
PO Box 36566

Under the GDPR, citizens of the EU are afforded the following rights:

  1. Data Access: Under GDPR, you are able to request access to your Personal Data and learn how Elevay uses that data. If you wish to obtain a copy of your data, please contact privacy@elevay.com.
  2. To Be Informed: Under GDPR, Elevay must be transparent about how we gather personal information, and must do it before we collect the data. As part of this, you must freely give consent for your data to be gathered for a specific purpose.
  3. Data Correction: You can also require any errors in personal data to be corrected, and Elevay must reply to the request within one month. If you wish to correct your data, please contact privacy@elevay.com.
  4. Data Erasure: You have the right to withdraw consent to store and use personal data and the right to have the information erased. If you wish to erase your data, please contact us at privacy@elevay.com.
  5. Restrict and Stop Processing: This gives you the right to block and suppress processing of your personal data. Under this restriction, Elevay can still store personal information but cannot use it in any way. If you gave your consent to have information processed by Elevay and wish to revoke it, please contact us at privacy@elevay.com.
  6. Data Portability: You have the right to transfer your data from one service provider to another, and Elevay must comply with this request. Under this regulation, Elevay will provide any Personal Information gathered, at your request, with which you can switch providers.

In addition, the third-party services we use have certified their participation and compliance with the Privacy Shield framework. This allows the transfer of personal data outside of the European Union, provided an adequate level of protection exists for the personal data in the country or organization the data is being transferred:

7. Interest Based Advertising

Interest based advertising is the collection of data from different sources and across different platforms in order to predict an individual’s preferences or interest and to deliver to that individual, or his/her computer, smart phone or tablet, advertising based on his/her assumed preference or interest inferred from the collection of data pertaining to that individual or others who may have a similar profile or similar interests.

We work with a variety of third parties to attempt to understand the profiles of the individuals who are most likely to be interested in Elevay Services so that we can send them promotional emails, or serve our advertisements to them on the websites and mobile apps of other entities.

These third parties include: (a) advertising networks, which collect information about a person’s interests when that person views or interacts with one of their advertisements; (b) attribution partners, which measure the effectiveness of certain advertisements; and (c) business partners, which collect information when a person views or interacts with one of their advertisements.

In collaboration with these third parties, we collect information about our customers, prospects and other individuals over time and across different platforms when they use these platforms or interact with them. Individuals may submit information directly on our Sites or on platforms run by third parties, or by interacting with us, our advertisements, or emails they receive from us or from third parties. We may use special tools that are commonly used for this purpose, such as cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar technologies. We may have access to databases of information collected by our business partners.

The information we or third parties collect enables us to learn what ads or content the person sees, on which ads or links the person clicks, and other actions that the person takes on our Sites, or in response to our emails, or when visiting or using third parties’ platforms.

We, or the third parties with which we work, use the information collected as described above to understand the various activities and behaviors of our customers, Site visitors and others. We, or these third parties, do this for many reasons, including: to recognize new or past visitors to our Sites; to present more personalized content; to provide more useful and relevant ads – for example, if we know what ads you are shown we can try not to show you the same ones repeatedly; to identify visitors across devices, sales channels, third party websites and Sites, or to display or send personalized or targeted ads and other custom content that is more focused on a person’s perceived interest in products or services similar to those that we offer.

Our interest-based ads may be served to you in emails or on third-party platforms. We may serve these ads about our products or services or send commercial communications directly ourselves or through these third parties.

Visitors may opt out of receiving interest based advertising by advertising networks that may be delivered to them by visiting the following websites: http://www.aboutads.info/consumers; and http://www.networkadvertising.org. These features will opt a Visitor out of many – but not all – of the interest-based advertising activities in which we or third parties engage.

8. Remarketing

Elevay and third party vendors, including Google, use first-party cookies (Google Analytics cookie) and third party cookies (DoubleClick cookie) together to inform, optimize, and serve ads based on past visits to our website. More specifically, our website has implemented and uses display advertising and we utilize Google Analytics to implement a specific feature called remarketing. Remarketing is a feature of Google’s AdWords that allows us to optimize the delivery of ad content specifically targeted to a visitor’s interests based upon previous visits to our site. If you’d like more information about remarketing lists in Google Analytics please visit the following site – https://support.google.com/analytics/answer/2611268″

If you would like to opt-out of Google Analytics for display advertising you may do so by using the Ads Preferences Manager – https://adssettings.google.com/

You may also use the Google Analytics opt-out browser add on that you can download at https://tools.google.com/dlpage/gaoptout/.

9. Compromise of Personal Information:

In the event that personal information is compromised as a breach of security, Elevay will promptly notify our customers in compliance with applicable law.

10. Your Choices About Your Information:

For current Elevay users and clients, you can request to review, correct, update or delete information that Elevay keeps on file by submitting a request to privacy@elevay.com. Email submissions will be reviewed and replied to within 72 hours.

Data protection law gives you a range of rights in connection with our processing of your personal data. In this regard, you have the right to request that we rectify or delete the personal data or restrict the processing of your personal data, if you think they are inaccurate. Furthermore, you have the right to object against the processing based on our legitimate interests as a legal basis. We are required to assess and act on your requests.

In the case of email communications, you will be able to withdraw your consent at any time via an unsubscribe link included at the bottom of emails we send.

11. Dispute Resolution:

Should you have any complaints about your privacy and our collection or use of your personal information, please contact us at privacy@elevay.com to resolve the concerns.

12. Our Retention of your Information:

  1. If you have submitted personal information, via a contact form, consultation request, signed a client agreement or other methods, we will retain your information for as long as is required to provide you Service or until otherwise requested to remove. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
  2. If you are a visitor to Elevay Sites, we will retain your information for as long as necessary, but no longer than 26 months after your last visit to our Sites.

13. Children’s Privacy:

We do not knowingly collect or solicit personal information from anyone under the age of 18 from our sites. As a requirement of a Service contract, it may be necessary to collect information on a client’s child to fulfill the contractual Service, but in this case, parental consent will be obtained. The Service is not intended to be used by minors. If you are a parent or guardian and discover your child under 18 years of age has submitted information to us, please alert us at privacy@elevay.com and request that we delete that child’s Personal Data from our systems.

14. Notification Procedures

It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via email, written or hard copy notice, or through conspicuous posting of such notice on the Service, as determined by Elevay in its sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described in this Privacy Policy.

15. Links to Other Web Sites

We are not responsible for the practices employed by websites or services linked to or from the Elevay Service or Sites, including the information or content contained therein. Please remember that when you use a link to go from the Elevay Service or Sites to another website or service, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third party’s own rules and policies.

16. Social Media Widgets:

Our Site includes social media features, such as the Facebook Like button and other widgets, that run on our Site. These features may collect your IP address and which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the organization providing it.

17. Changes to Our Privacy Policy

All changes to this Privacy Policy are effective when they are posted on this page. When we change the policy in a material manner, we will let you know via email and/or a prominent notice on our Site, prior to the change becoming effective and update the ‘effective date’ at the top of this page.

If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this website, please contact us at privacy@elevay.com.

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