Last updated on Feb 08 2024
This Privacy Policy provides a clear explanation of how Elementum collects information about you when you interact with Elementum, including through our websites, applications, and services. It also lets you know what choices you have regarding our use of your information and how you can exercise access and update that information.
Please read this Privacy Policy carefully. We have made modifications to our previous policy to help you better understand how we use your information. By using and/or accessing our Services (defined below) you acknowledge that you have read and understood this Privacy Policy.
“Policy” refers to this Privacy Policy.
“Elementum”, “we”, “us” and/or “our” refers to Elementum Ltd and any of our corporate affiliates.
“Services” refers to, individually and collectively, our supply chain orchestration, collaboration, and related services, support, professional services, websites (including elementum.ai), and end user software on any platform. The Services are not intended for personal or consumer use.
“You” and “your” refer to individuals using or otherwise interacting with our Services.
“Information” refers to data about you and your use of Services, may be retained in electronic or paper format, and includes personal data as defined by the General Data Protection Regulation.
We may process your information if:
We collect information from you when you voluntarily provide that information to us. This may occur, for example, when you complete and submit a form through the Services, contact us with inquiries, participate in an event or promotion, or respond to one of our surveys.
We collect information from you when you voluntarily provide that information as part of your use of the Services. Examples of this include: when you submit a technical support request, submit a form for “request a demo” or “request a whitepaper”.
We collect information about you from third parties including other Service users, third-party service providers which you have linked to your use of our Services (including social media accounts, single-sign-on services, and scheduling applications), resellers, distributors, your employer, your administrator, publicly available sources, data enrichment vendors, payment and delivery service vendors, advertising networks, analytics providers, and our business partners. The information which we receive from third parties depends on what policies that third party follows and our and your respective relationships with the third party.
Personal data relating to you that we process may include:
The Elementum websites also use a technology called “cookies” to collect certain information. A cookie is a piece of computer code that your internet browser is given when you access the website. Our cookies help provide additional functionality to the website, track the traffic patterns for our website, and study how our users use and interact with the Services. For instance, our website may set a cookie on your browser that allows you to access the website without needing to remember and then enter a password more than once during a visit to the Site. Please refer to your web browser’s instruction guide or help section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to better take advantage of some of the Services. Further information on our use of cookies is located at https://elementum.ai/cookie-policy
We currently do not participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your information.
How we use the information is shaped by the source of the information, the type of Services you use, and any privacy preferences that you have specified to us. Below are the specific purposes for which we use the information we collect or receive about you.
The Services are not intended to be used for profiling, automated processing, personal data relating to criminal convictions or offenses, other systematic monitoring of a public area, or any other operations which may result in a high risk of significantly affecting you or your legal rights.
If you are an EU resident, the following terms also apply:
Elementum processes your personal data when we have an adequate legal basis for doing so. This means we collect and use your personal data where:
If you have consented to our use of personal data for a specific purpose, you have the right to change your mind at any time, and the procedures for communicating that revocation of consent are detailed below. Any such decision will not affect any processing that has already occurred. Where you withdraw your consent, but we are using your information because we or a third party (e.g. your employer) have a legitimate interest in doing so, or we have different legal basis for using your information (for example, fulfilling a contract with you), we may continue to process your information, subject to your rights to access and control your information. However, this may mean your access to the Services will be limited or suspended, and your accounts may be terminated, as applicable.
Elementum will generally retain information for so long as you are an active user of the Services. For more extensive requests, you may make a request per the guidelines below.
Following the end of your subscription to the Services if the Services are made available to you through an organization (e.g., your employer), we retain your information per your organization’s instructions. For more information, see the “Additional Information Regarding Processing Information of Our Customers” section below.
Some information may be retained to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, for marketing purposes according to your registered preferences if you have opted to receive such communication, information derived from cookies, and information required to continue to develop and improve our Services.
Where we retain information after your use of the Service, we take reasonable steps to make that data is not personally identifiable beyond the extent required to comply with our legal and regulatory obligations.
How We Protect Information Elementum takes appropriate physical, technical, and organizational measures to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your information from unauthorized access, use or disclosure.
Our primary data hosting service providers are in the United States. A limited amount of information may be accessed or processed in Argentina and/or The Philippines.
No Internet, e-mail or other electronic transmission is ever fully secure or error free, so you should take special care in deciding what information you send to us in this way.
There are certain circumstances in which we may share your information with certain third-parties. Any access by a third party to the information is managed by Elementum, and the third parties are vetted based in part on their ability to protect information. International movement of information consistent with this sharing is discussed in the “How We Move Information” section below.
As part of your use of the Service, you may share information with other users of the Service. Those users of the Service may be located in nearly any location around the world, may be communicating with Third Party Sites (as defined below) while using the Services, and may be limited by law or by an agreement with us about their use of information you share. However, this Policy only addresses our use of the information.
We may share information with employees, contractors, agents, or consultants with a strict need-to-know under appropriate confidentiality obligations.
When we employ another company to perform services of this nature, we only provide such company the right to use such information that is reasonably necessary to perform their specific function.
We may share information with other third parties, including when you provide consent for a specific situation. If Elementum intends on sharing any information in a manner other than as described above using any personal data in any manner that is not compatible with this Privacy Policy, and we do not have a legal basis for sharing that information without your consent, you will be informed of such anticipated use and be given an opportunity to provide your consent for such use.
We may share information with third parties if we reasonably believe that such action is necessary to:
This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
We may share information with our subsidiaries and corporate affiliates who support our processing of personal data under this Policy.
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, acquisition, merger, reorganization, dissolution or similar event, information may be part of the transferred assets. You will be notified via email and/or other means with any news of a transaction and any choices you may have regarding your information.
We provide our Services primarily from the United States, where we are based. Your use of the Services requires the movement of information to our locations and the locations of our third-party service providers. Your use of the Services may require that our international affiliates and subsidiaries in countries including Argentina, Germany, and Philippines have access to the information.
If you are an EU resident:
Your information may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) that may not be subject to equivalent data protection law. It may be processed by staff situated outside the EEA who work for us or for one of our suppliers.
We may transfer your personal information outside the EEA:
When we share information about you within Elementum and with third parties in countries with local laws which may differ from yours, we make use of standard contractual data protection clauses, which have been approved by the European Commission, and we rely on the EU-U.S. Privacy Shield Framework to safeguard the transfer of information we collect from the European Economic Area to the United States. In some cases we may use other appropriate legal mechanisms to safeguard the transfer.
Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy.
Where we provide access to the Services to you under contract with an organization (for example your employer), or if you use an email address provided by an organization to access the Services, that organization may act as the controller of the information. Your use of the Services may be subject to that organization’s policies. Each organization may appoint administrative users of the Services. An administrator may have the ability to access, modify, and/or delete certain information that you have provided, give information to Third Party Sites (as defined below), and restrict your access to the Services and information in whole or in part.
In this situation, Elementum is the processor, rather than the controller, of your information. Where we are the processor, we do not control why or how your information is used, and you will need to contact your relevant controller (e.g. your employer and/or the company which provides you access to the Services) to find out about your data protection rights and responsibilities. All questions about your organization’s policies and administrative user access rights should be directed to your organization.
How You Can Access and Control Information
Your ability to control the information includes the ability to:
You may opt out of non-transactional emails through the email notification center. For any issue that cannot be handled on a self-service basis, please reach out to our Support team for assistance. You can also exercise the rights listed above at any time by contacting us at privacy@elementum.com. In some instances, if you access the Services under contract with an organization, we may be required to direct your inquiries to an administrative user.
If you no longer want to use our Services, you may choose not to access our website or services at any time and, as applicable, you will need to reach out to our Support team or an administrative user to deactivate your account. If you are an organizational user of the Services, you will need to arrange for an administrative user to remove personal data associated with your account.
You may contact our Support team to ask us to stop accessing, storing, using and otherwise processing your information where our legal basis for doing so relies on your consent or is otherwise objectionable by law. Where you gave us consent to use your information for a limited purpose, you can contact our Support team to withdraw that consent, but this will not affect any processing already occurred. Where you withdraw your consent, but we are also using your information under a different legal basis (for example, fulfilling a contract with you), we may continue to process your information, subject to your rights to access and control your information. Please note that we may need to retain certain information to fulfill legal obligations, in accordance with our record retention practices, or to complete transactions.
Elementum does not knowingly collect information from children under the age of 13, and our Services are not intended for use by minors (as defined in your relevant jurisdiction). By using our Services, you confirm to us that you are not under the age of 13 and/or not a minor.
If you are a minor, please do not submit any information through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide information via the Services without permission. If you have reason to believe that a minor has provided information to Elementum, please contact us and we will endeavor to delete that information from our databases.
The Services may contain links, add-ins applications, social media widgets or other access points that will take you and your information to other websites and resources on the Internet that are not operated or controlled by Elementum (“Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. We have no control over, are not responsible for, and do not endorse the information practices of such third party websites and resources. Your access to and use of such third party websites or resources, including your use of any content, information, data, advertising, products, or other materials on or available through them, is solely at your own risk and is subject to the terms and conditions of use and privacy policy(ies) applicable to such Third Party Sites and related resources. Once you choose to be directed to a Third Party Site, you should read the applicable privacy statement before sharing any personal or other information. If you object to information about you being shared with a Third Party Site, please disable any applications or plug-ins which communicate with the Third Party Site or contact your administrator to do so.
The Services and our business may change from time to time. As a result, at times it may be necessary for Elementum to make changes to this Policy. Elementum reserves the right to update or modify this Policy at any time and endeavor to give you the opportunity to review the revised Policy before you choose to continue using our Services.
Please review this Policy periodically. Your continued use of the Services after any changes or revisions to this Policy indicates that you have read and understood the terms of such revised Policy.
This Policy shall not apply to any unsolicited information you provide to Elementum through this website or otherwise through the Services. This includes, but is not limited to, any ideas for new products or modifications to existing products. All such unsolicited information shall be deemed to be non-confidential. Elementum shall be free to reproduce, use, disclose, distribute and exploit such unsolicited information without limitation or attribution. However, if such unsolicited information also includes personal data, we will also determine whether we have a lawful basis for the collection and use of that information prior to doing so.
If you have a complaint about Elementum’s privacy practices, please write to us at the address below. We will take reasonable endeavors to work with you to attempt to resolve your complaint. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. The dispute resolution process will be conducted in English.
If you are an EU resident, and you have a request or concern about how we handle your personal information, you can also contact your local supervisory authority. A full list can be found on the European Commission website here.
If you have any questions about our Privacy Policy or the information practices of the Services, please contact Elementum Ltd, Attn: Elementum Privacy Team, at our business address of 50 W Broadway Ste 333 PMB 86814, Salt Lake City, UT 84101 or by visiting our Contact Us page.