PRIVACY POLICY

Welcome to the privacy and other policy for Elite Privilege Card, which is owned, managed and operated by Elite Prime Federation. Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use the Elite Privilege Card website, mobile applications, APIs or related services (“Services”).

 

Elite Prime Federation together with its Affiliates (“We/Us/Our”) is a for profit organisation and are engaged in sharing business development geographically.

 

This Privacy Policy is effective as of 01 June 2024. (“Effective Date”).

 

We request you (the visitor and/or user of Elite Privilege Card) to read this Privacy Policy in conjunction with the Terms of Use document. You are requested and required to thoroughly read and understand this Privacy Policy, as amended from time to time, prior to using Elite Privilege Card.

 

We respect your privacy and want you to understand how we collect, use, and share your data during your usage of Elite Privilege Card.

 

This Privacy Policy covers our data collection practices and describes your rights to access, correct, or restrict our use of your personal data.

 

We are the data controller for all data collected from when you utilise the Services.

 

Elite Prime Federation having office at Ground Floor, Sai Kusum Apartment, P.O.Salbari, Dst Darjeeling,  West Bengal Pin 734002. You may get in touch with our privacy team at eliteprivilegecards@gmail.com

 

By using the Services, you agree to the terms of this Privacy and other Policy. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services. Your continuous use of the Services shall be deemed as your continuous acceptance of this Privacy and other Policy.

 

1. The benefits of this card will be valid for 1 year from the date of issue/renewal and the ownership of the card is non transferrable during the subscription period.

2. Card holders shall have physical possession of the card for availing the benefits

3. The type of benefits offered and the list of vendors offering the benefits may change time to time. To know about the latest eligible benefits, kindly scan the QR code or visit our website

4. No duplicate cards will be provided if the card is lost/misplaced

 

1. Legal Basis for Processing Data

We process your data on the basis of the following:

* Your explicit consent for processing your data (as mentioned in Section 2 below), and for the purposes mentioned in Section 4 below;

* For the performance of contracts entered into by you for providing any of the Services; and

* Our legitimate interests, i.e. registering and administering accounts on our Services to provide you access to all content, updates and services you have purchased, and to facilitate the efficient running and operation of our business.

 

2. What Data We Collect

We collect certain data from you directly, like the information you enter yourself, contact details. We

2.1 Data You Provide to Us

We may collect different data from or about you depending on how you use the Services. Here are some examples to help you better understand the data we collect.

When you subscribe to a card or update an existing card on the website / offline, we collect the following data you provide directly:
- Full name
- Email address
- Mobile Number
- IP Address

When you subscribe for our Elite Privilege Card, we will collect your full name and email address, and the newsletter will be delivered to you digitally for the term of your subscription.

 

We may invite you to complete a survey or participate in a promotion, either through the Services or a third-party platform. If you participate, we will collect and store the data you provide as part of participation, such as your name, email address, or phone number. That data is subject to this Privacy Policy unless otherwise stated in the official rules of the promotion or in another privacy policy. The data collected will be used to administer the promotion or survey, including for notifying winners and distributing rewards. Where we use a third-party platform to administer a survey or promotion, the third party’s privacy policy will apply.

If you contact us for support or to report a problem or concern (regardless of whether you have created an account), we collect and store your contact information, messages, and other data about you like your name, email address, location, operating system, IP address, and any other data you provide or that we collect through automated means. We use this data to respond to you and research your question or concern, in accordance with this Privacy Policy.

 

2.2 Data We Collect through Automated Means

When you access the Services (including browsing courses), we collect certain data by automated means, including:
- System data: Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain, and other systems data, and platform types;
- Usage data: Usage statistics about your interactions with the Services, including programs and courses accessed, time spent on pages or the Service, pages visited, features used, click data, date and time, and other data regarding your use of the Services;
-Approximate geographic data: An approximate geographic location, including information like country, city, and geographic coordinates.

The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. It is stored by us and associated with your account

 

 

3. How We Get Data About You

We use tools like cookies, web beacons, analytics services, and advertising providers to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.

• 3.1 Cookies and Data Collection Tools

• 3.1 Cookies and Data Collection Tools

1. Our service providers acting on our behalf (like Google Analytics and third party advertisers) and us, use server log files and automated data collection tools like cookies, tags, scripts, customised links, device or browser fingerprints, and web beacons (“Data Collection Tools”) when you access and use the Services. These Data Collection Tools automatically track and collect certain System Data and Usage Data (as detailed in Section 2) when you use the Services. In some cases, we tie data gathered through those Data Collection Tools to other data that we collect as described in this Privacy Policy.

2. We use cookies (small files that websites send to your device to uniquely identify your browser or device or to store data in your browser) for things like analysing your use of the Services, personalising your experience, making it easier to log into the Services, and recognising you when you return. We use web beacons (small objects that allow us to measure the actions of visitors and users using the Services) for things like identifying whether a page was visited, identifying whether an email was opened, and advertising more efficiently by excluding current users from certain promotional messages or identifying the source of a new page visit.

3. We use the following types of cookies:
   - Preferences: cookies that remember data about your browser and preferred settings that affect the appearance and behaviour of the Services (like your preferred language).
   - Security: cookies used to enable you to log in and access the Services; protect against fraudulent logins; and help detect and prevent abuse or unauthorised use of your account.
   - Functional: cookies that store functional settings.
   - Session State: cookies that track your interactions with the Services to help us improve the Services and your browsing experience, remember your login details, and enable processing of your course purchases. These are strictly necessary for the Services to work properly, so if you disable them then certain functionalities will break or be unavailable.

4. You can set your web browser to alert you about attempts to place cookies on your computer, limit the types of cookies you allow, or refuse cookies altogether. If you do, you may not be able to use some or all features of the Services, and your experience may be different or less functional.

5. Some of the third-party partners who provide certain features on our site may also use local storage objects (also known as Flash Cookies or LSOs) to collect and store data.

• 3.2 Analytics

• We use the 3rd-party browser and mobile analytics services like Google Analytics, Hotjar, GetSiteControl, Mixpanel, Leadsquared, Wistia, YouTube and Drift  on the Services. These services use Data Collection Tools to help us analyse your use of the Services, including information like the third-party website you arrive from, how often you visit, events within the Services, usage and performance data. We use this data to improve the Services, better understand how the Services perform on different devices and provide information that may be of interest to you.

• 3.2 Online Advertising

1. We use third-party advertising services like Facebook, Google’s ad services, and other ad networks and ad servers to deliver advertising about our Services on other websites and applications you use. The ads may be based on things we know about you, like your Usage Data and System Data (as detailed in Section 2), and things that these ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services and may be tailored to your interests.

2. Depending on the types of advertising services we use, they may place cookies or other tracking technologies on your computer, phone, or other devices to collect data about your use of our Services and may access those tracking technologies in order to serve these tailored advertisements to you. To help deliver tailored advertising, we may provide the service providers with your email address and content that you share publicly on the Services.

4. What We Use Your Data For, and How Long We Store it

• 4.1 How we use your data:

1. We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyse how people use our Services, serve personalised advertising, and as required by law or necessary for safety and integrity.

2. We use the data we collect through your use of the Services to:
   - Provide and administer the Services, including to display customised content and facilitate communication with other users;
   - Process your requests for programs, plans, specific services, information, or features;
   - Communicate with you about your account by:
      § Responding to your questions and concerns;
      § Sending you administrative messages and information, including messages from health coaches, yoga instructors or ayurvedic        consultants, notifications about changes to our Service, and updates to our agreements;
      § Sending you information and in-app messages about our services;
      § Sending push notifications to your wireless device to provide updates and other relevant messages (which you can manage from        the “options” or “settings” page of the mobile app).
   - Manage your account preferences;
   - Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse;
   - Solicit feedback from users;
   - Market and administer surveys and promotions administered or sponsored by us;
   - Learn more about you by linking your data with additional data through third-party data providers or analysing the data with the help of analytics service providers;
   - Identify unique users across devices;
   - Tailor advertisements across devices;
   - Improve our Services and develop new products, services, and features;
   - Analyse trends and traffic, track purchases, and track usage data;
   - Advertise the Services on third-party websites and applications;
   - As required or permitted by law; or
   - As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services.

• 4.2 Criterion For Determining Data Retention Period:

• It is not possible for us to determine a specific period for which we may retain your data. However, we will retain your data for longer than necessary, taking into account the following:

1. The purpose(s) and use of your data, both now and in the future (such as whether it is necessary to continue to store that information in furtherance of our obligations under a contract with you, or to contact you in the future);

2. Whether we have any legal obligation to continue processing your data (such as any record-keeping obligations imposed by any applicable law);

3. Whether we have any further legal basis to continue processing your information (including your consent);

4. Whether there is any relevant agreed industry practice on how long such data should be retained;

5. The levels of risk and liability involved for us to continue holding the data;

6. The amount of difficulty we may face to ensure the data can be kept updated and accurate; and

7. Any other circumstances (such as the nature and status of our relationship with you).

5. Who We Share Your Data With

• 5.1 We share certain data about you with our business partners, analytics and data enrichment providers, your social media providers, companies helping us run promotions and surveys, and advertising companies who help us promote our Services.  We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.

• 5.2 We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:

1. With service providers, contractors, and agents: We share your data with third-party companies who perform services on our behalf, like payment processing, data analysis, marketing, and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.

2. With business partners: We have agreements with other websites and platforms to distribute our Services and drive traffic to us.

3. With analytics and data enrichment services: As part of our use of third-party analytics tools like Google Analytics and data enrichment services like Clearbit or Pipl, we share certain contact information, Account Data, System Data, Usage Data (as detailed in Section 2), or de-identified data as needed. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customised manner.

4. To power social media features: The social media features in the Services (like the Facebook/Instagram Share) may allow the third-party social media provider to collect things like your IP address and which page of the Services you’re visiting, and to set a cookie to enable the feature. Your interactions with these features are governed by the third-party company’s privacy policy.

5. To administer promotions and surveys: We may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey.

6. For advertising: If we decide to offer advertising in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools (as detailed in Section 3.1), and to use this data to offer you targeted ad delivery to personalise your user experience (through behavioural advertising) and undertake web analytics. Advertisers may also share with us the data they collect about you. To learn more or opt out from participating ad networks’ behavioural advertising, see Section 7.1 (Your Choices About the Use of Your Data) below. Note that if you opt out, you’ll continue to be served generic ads.

7. For security and legal compliance: We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
   § Permitted or required by law;
   § Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
   § Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
   § Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
   § Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or
   § Reasonably necessary in our discretion to protect against imminent harm to our rights, property, or safety, or that of our users, employees, members of the public, or our Services.
   § We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy.

8. During a Change in Control: If we undergo a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organisation during such transition or in contemplation of a transition (including during due diligence).

9. After Aggregation/De-identification: We can disclose or use aggregate or de-identified data for any purpose.

10. With Your Permission: With your consent, we may share data to third parties outside the scope of this Privacy Policy.

 

6. Security

• 6.1 We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorised access, so it’s important to protect your password and to contact us if you suspect any unauthorised access to your account.

• 6.2 We take appropriate security measures such as using HTTPS to transfer your data to protect against unauthorised access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and us, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorised access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately.

7. Your Rights

You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain analytics providers. You can update or terminate your account from within our Services, and can also contact us for individual rights requests about your personal data such as to restrict our processing of your data, to erase all data we have stored about you, and the right to ask for the data to be provided to you/ported to any other service in a commonly used machine readable format.

• 7.1 Your Choices About the Use of Your Data:

• You can choose not to provide certain data to us, but you may not be able to use certain features of the Services

1. The browser or device you use may allow you to control cookies and other types of local data storage. Your wireless device may also allow you to control whether location or other data is collected and shared.

• If you have any questions about your data, our use of it, or your rights, contact us at eliteprivilegecards@gmail.com.

• 7.2 Accessing, Updating and Correcting, Porting and Deleting Your Personal Data:

1. To terminate your membership:
   - Write to eliteprivilegecards@gmail.com to delete your subscription permanently.
   - Please note: even after your account is terminated, some or all of your data may still be available to us, including without limitation any data that has been (a) copied, stored, or disseminated by other users; (b) shared or disseminated by you or others (including in your shared content); or (c) posted to a third-party platform. Even after your account is terminated, we retain your data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce our agreements. We may retain and disclose such data pursuant to this Privacy Policy after your account has been terminated.

• 7.4 Complaints about our privacy policy or use of your data:

• While we take all measures to protect and secure your data, we understand that you may have grievances about our use of your data, or of our data protection measures. Please feel free to reach out to us at eliteprivilegecards@gmail.com with any such complaints.

• Please note that while we urge you to write to us for any grievances or with any complaints you may have, this does not preclude you from directly approaching the national data protection authorities mentioned above.

8. Updates and Contact Information

When we make a material change to this Privacy Policy, we will notify you via email, in-product notice, or another mechanism required by law. Changes become effective the day they are posted. Please contact us via email with any questions, concerns, or disputes.

• 8.1 Modifications to This Privacy Policy:

• From time to time, we may update this Privacy Policy. If we make any material change to it, we will notify you via email, through a notification posted on the Services, or as required by applicable law. We will also include a summary of the key changes. Unless stated otherwise, modifications will become effective on the day they are posted.

• As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous privacy policies.

• 8.2 Interpretation:

• Any capitalised terms not defined in this policy are defined as specified in our Terms of Use.

• 8.3 Questions:

• If you have any questions, concerns, or disputes regarding our Privacy Policy, please feel free to contact our privacy team (including our designated Data Protection Officer) at eliteprivilegecards@gmail.com

• Our Data Management Team may be contacted with respect to any complaints or concerns including those pertaining to breach of our Terms of Use and/or Privacy Policy.

9. Cookie Policy

• 9.1 What are cookies?

• Cookies are small text files stored by your browser as you browse the internet. They can be used to collect, store, and share data about your activities across websites.

• We use both session cookies, which expire after a short time or when you close your browser, and persistent cookies, which remain stored in your browser for a set period of time. We use session cookies to identify you during a single browsing session. We use persistent cookies where we need to identify you over a longer period, like when you request that we keep you signed in.

• 9.2 Why do we use cookies and similar technologies?

• We use cookies and similar technologies like web beacons, pixel tags, or local shared objects (“Flash Cookies”), to deliver, measure, and improve our services in various ways. We use these cookies both when you visit our site and services through a browser and through our mobile app. As we adopt additional technologies, we may also gather additional data through other methods.

• We use cookies for the following purposes:

• To identify a user's device upon visiting the website, monitor a user's activity throughout the site, and facilitate any e-commerce features. Additionally, to enhance the website's user experience and analyze its usage patterns.

• 9.3 What are my privacy options?

• You have a number of options to control or limit how we and our partners use cookies:
  - Most browsers automatically accept cookies, but you can change your browser settings to decline cookies by consulting your browser’s support articles. If you decide to decline cookies, please note that you may not be able to sign in, customise, or use some interactive features in the Services.
  -Flash Cookies operate differently than browser cookies, so your browser’s cookie-management tools may not remove them.

10. Rights Reserved

All rights of this card are reserved by the Elite Prime Federation