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Ethical values for business success: A conversation with L’Oréal’s Chief Ethics Officer

  • Published: 15 November 2017
  • Author: Isabelle Morin

Individuals are generally considered morally responsible for their actions. But who is responsible when those individuals become part of a business organization? Can we impute moral responsibility to the organization itself?

The imperatives of day-to-day performance in large organisations are compelling and there is little time to divert attention to the ethical dimension of management decisions. But increasingly, companies realise that they bear the responsibility for an individual’s misdeeds in their entire value chain as well as globally as a company.

More and more companies though are actively shaping organizational ethics and seize this as an opportunity to create a corporate culture that strengthens the relationships and the reputation on which their success depends. Is business ethics the key to long-term success? CSR Asia asked Emmanuel Lulin, Senior Vice President and Chief Ethics Officer for L’Oréal.

How do you define ethics and how has L’Oréal formalised it?

Ethics is about the principles we define for ourselves, in terms of how the company operates as well as how people behave within the organisation. In the case of L’Oréal, it was a proactive approach which started in 2000. L’Oréal was one of the first companies to establish a Code of Ethics and appoint a Chief Ethics Officer in 2007.

L’Oréal articulates ethics around four ethical principles: Integrity, Respect, Courage and Transparency. These principles are expressed in the daily operations of our teams around the world and must be understood by all L’Oréal employees. Acting with integrity for instance is vital to building and maintaining trust. Respect because what we do has an impact on many people’s lives. Courage because ethical questions are difficult ones but they must be addressed. Transparency is something we envisioned as a key trend a while ago, it affects all our activities, our communication and our engagement with stakeholders. Transparency is critical to be truthful, sincere and to be able to justify our decisions.

How is ethics different from compliance?

Ethics simply goes beyond compliance. It is about creating a corporate culture and it is based on sincerity. The pace of innovation is such that we see new ethical issues emerging all the time. Legislation simply can’t follow and move fast enough. If we can’t fully rely on legislation and compliance, it becomes even more important that companies develop a proactive approach to ethics.Ethics also comes before compliance. Often the discussion starts with questions around ethics and is later transformed into a legislation. The debate around consumer data for instance is now being translated into data privacy and protection regulations.

Most companies now start to understand that a lack of integrity and transparency is putting them at risks whereas a company with strong ethical principles is a company you can trust. Trust is one of the biggest competitive advantage a company can have. It is a great investment to focus on ethics but it takes time to drive change. Most companies who try to rapidly develop ethics programmes purely based on compliance usually fail to create a strong culture of ethics. When we look at some of the biggest corporate scandals that occurred over the last few years, we can see that most of these organisations had rigorous compliance systems in place which did not stop individuals from making unethical choices.

How did you create this culture of ethics a L’Oréal?

When we started 10 years ago, we acknowledged that first and foremost, we needed to promote an open environment to encourage our employees to speak up if they have concerns and ensure that managers are able to listen. In most countries, this is still extremely challenging, as many people haven’t been educated to air their views, express their opinions and report unacceptable demands and behaviour.

As Chief Ethics Officer, I can rely on a network of 74 Ethics Correspondents whose role is to support Country Managers in deploying L’Oréal’s Ethics Program. Each year, this network is reinforced, giving all employees access to a local correspondent. The Country Manager is in charge of ensuring that the Code of Business Ethics is respected in his or her country. L’Oréal also holds an Ethics Day every year for the entire workforce. Employees all around the world are invited to put questions on ethics directly to our Chairman and Chief Executive, Jean-Paul Agon. This year, we received over 5,700 questions from our employees all over the world.

Can you give some examples of the questions that were asked?

When we started the Ethics Day we had a lot of HR-related questions. Employees would ask about remuneration and compensation, work hours, sometimes about harassment or management styles. These were recurring topics and mostly personal issues. The topics that emerged over the last few years have more to do with organizational ethics, relating to how the company operates and how we do business in general. For instance, the questions we receive may be related to the products we develop, the markets where we sell our products or our diversity. These are important and valid questions because Ethics for L’Oréal encompasses all functions within the group from marketing, to HR, finance etc… All stakeholders within the organisation are actively contributing to Ethics. Our sourcing department for instance is conducting regular audits of our suppliers on the base of L’Oréal’s Code of Business Ethics.

[L’Oréal Singapore Employee Engagement on Ethics]

Can we transmit this culture of ethics outside the company?

Yes, this is the objective. Driving change outside the organisation. If we really believe in our values, it becomes natural to select business partners and suppliers who share similar values. I believe that companies can transmit their culture overtime but it needs to be really authentic to be contagious. It also needs to starts from the top. If L’Oréal succeeded with its ethics programme, it is because we have a genuine interest from leadership and it is supported by a dedicated organization. Authenticity is a critical success factor here. As much as management needs to be vocal on the topic of ethics, they need to walk the talk.

How do you monitor performance and measure success?

The deployment of L’Oréal’s ethics program is based on three major levers. First, a steering and monitoring system including tools for ethical risk analysis and assessment, a country reporting system and regular audits. Our strong commitment around Ethics, have drawn the attention of the public, our investors and NGOs, it is therefore essential that it happens in a measurable way and we report our progress to external stakeholders. We measure ethics at the leadership and management levels for instance, evaluating how managers manage and their personal involvement to promote this culture of ethics. All managers have key performance indicators related to ethics. The Board of Directors and the Executive Committee look at our progress as they look at our business and financial performance. The two other levers are awareness-raising and engagement to promote the involvement of employees at all levels of the group on ethics and promoting a culture of dialogue and transparency, the “Open Talk” policy.

Do you think L’Oréal ethical principles resonate well in Asia or does ethics need to be localised somehow?

Our Principles are universal but in some countries, there may be a confrontation between traditional and modern values. Our approach was to first work towards a global alignment to our ethical principles and then, recognising that each country has a different context and challenges, we are having local discussions on values and priorities. The difficulty is that there aren’t many best practice examples that we can leverage to know that we are on the right track. It is a journey and we are learning every day.

This year I am visiting each country where we operate. I’m meeting the management board and working on concrete issues related to ethics. This helps us map and prepare ourselves globally to address future issues such as big data, responsible sourcing or transhumanism. Human rights are universal regardless of the culture and tradition. This year, L’Oréal launched a human rights policy and this is an important step which allows us to explain more clearly how we respect our commitment in practice. As an example, human rights are taken into consideration when choosing our natural ingredients. Our research and innovation teams therefore have to ensure that the local populations producing these ingredients have access to their land, to their natural resources and ensure the respect of their traditional knowledge.

Are you optimistic?

Yes, I’m optimistic. Ethics drives business value as well as differentiation and innovation. It is not in any company’s DNA, it can be developed, but it requires time and a dedicated approach.

 

Emmanuel Lulin joined L’ORÉAL in 1999 as Group General Counsel for Human Resources. In 2007, under the leadership of Jean-Paul Agon, he set up the Office of the Group Chief Ethics Officer. Before joining L’ORÉAL, he was admitted to the Paris Bar in 1988 and practiced as a corporate and tax attorney at Debevoise & Plimpton in Paris and New York.

L’Oréal’s ambition is to be an exemplary company worldwide and integrates ethics into the very heart of its business practices. In 2017, the group was recognized for the eighth time by the Ethisphere Institute as one of the “World’s Most Ethical Companies”.


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Information collected

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When you create an account and profile on ELEVATE’s technology solutions web sites, we collect some information such as your name and contact information for the purposes of providing you access to the solution. Your name, photo, and any other information that you choose to add to your profile in our solutions may be available for viewing to other users (either from your firm, or to people in ELEVATE).

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As you navigate the company’s websites, ELEVATE may also collect information through the use of commonly-used information-gathering tools (“website navigational information”). Website navigational information includes cookies, log files, pixel tags, local storage objects, and other tracking technologies to automatically collect information about your activities, such as your searches, page views, date and time of your visit, and other information about your use of the ELEVATE websites or solutions. We also collect and may store information that your computer or mobile device provides to us in connection with your use of the ELEVATE properties such as your browser type, type of computer or mobile device, browser language, IP address, mobile carrier, unique device identifier, location, and requested and referring URLs.

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Use of information collected

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The Company may also use data about ELEVATE customers and attendees for marketing purposes. For example, the company may use information you provide to contact you to further discuss your interest in the services and to send you information regarding the company, its affiliates, and its partners, such as information about promotions or events.

The Company may also use and share aggregated, depersonalized or de-identified information either internally or with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

ELEVATE uses credit card information solely to check the financial qualifications and collect payment from prospective customers and attendees.

ELEVATE uses website navigational information to operate and improve the company’s websites. The company may also use website navigational information alone or in combination with data about ELEVATE customers and data about ELEVATE attendees to provide personalized information about the company.

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Except for the mailing list initiative described above, where visitors explicitly choose to receive specific ELEVATE marketing or other materials, ELEVATE will not use personal data collected from our websites to facilitate unsolicited marketing activities.

Website navigational information

Cookies, web beacons and IP addresses

ELEVATE uses commonly-used information-gathering tools, such as cookies and web beacons, to collect information as you navigate the company’s websites (“website navigational information”). As described more fully below, we and our partners use these cookies or similar technologies to analyze trends, administer websites and services, track users’ movements around our websites and services, serve targeted advertisements and gather demographic information about our user base as a whole. This section describes the types of website navigational information used on the company’s websites and services, and how this information may be used.

Cookies

ELEVATE uses cookies to make interactions with the company’s websites easy and meaningful. When you visit one of the company’s websites, ELEVATE’s servers send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your web browser. Unless you choose to identify yourself to ELEVATE, either by responding to a promotional offer, opening an account, or filling out a web form (such as a “contact” webform), you remain anonymous to the company.

ELEVATE uses cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our websites or services.

The following sets out how ELEVATE.com uses different categories of cookies and your options for managing cookies’ settings:

Required cookies

Required cookies enable you to navigate the company’s websites and use its features, such as accessing secure areas of the Websites and using ELEVATE Services.

If you have chosen to identify yourself to ELEVATE, the company may place on your browser cookies containing an encrypted, unique identifier. These cookies allow the company to uniquely identify you when you are logged into the websites and services and to process your online transactions and requests.

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Performance cookies

These cookies collect information about how visitors use our websites and services, including which pages visitors go to most often and if they receive error messages from certain pages. It is only used to improve how the company’s websites and services function and perform.

From time-to-time, ELEVATE engages third-parties to track and analyze usage and volume statistical information from individuals who visit the company’s websites and services, and to track the performance of the company’s advertisements. ELEVATE and its third-party partners may also utilize HTML5 local storage or Flash cookies for these purposes. Flash cookies and HTML local storage are different from browser cookies because of the amount of, type of, and how data is stored.

Various browsers may offer their own management tools for removing HTML5 local storage.

Functionality cookies

Functionality cookies allow the company’s websites and services to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of ELEVATE’s websites and services after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.

ELEVATE uses local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on our websites and services to personalize your visit.

To learn how to opt out of functionality cookies using your browser settings click here. Note that opting out may impact the functionality you receive when using ELEVATE’s Websites and Services.

To learn how to manage privacy and storage settings for Flash cookies click here.

Targeting or Advertising cookies

ELEVATE sometimes uses cookies delivered by third-parties to show you ads for ELEVATE products and services that we think may interest you on any devices you may use and to track the performance of company advertisements. For example, in these cases, cookies remember information such as which browsers have visited the company’s websites. The information provided to third-parties does not include personal information, but this information may be re-associated with personal information after the company receives it.

ELEVATE also contracts with third-party advertising networks that collect IP addresses and other information from web beacons (see below) on the company’s websites and services, from emails, and on third-party websites. Ad networks follow your online activities over time and across different sites or other online services by collecting website navigational information through automated means, including through the use of cookies. These technologies may recognize you across the different devices you use, such as a desktop or laptop computer, smartphone or tablet. Third-parties use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other websites or mobile applications on any of your devices. This process also helps us manage and track the effectiveness of our marketing efforts. Third-parties, with whom the company partners to provide certain features on our websites or to display advertising based upon your web browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.

To learn more about these and other advertising networks and your ability to opt out of collection, please visit the opt-out pages of the Network Advertising Initiative, here, and the Digital Advertising Alliance, here.

To learn how to manage privacy and storage settings for Flash cookies click here. Various browsers may offer their own management tools for removing HTML5 local data.

Web beacons

ELEVATE may use web beacons alone or in conjunction with cookies to compile information about customers and visitors’ usage of the company’s websites and interaction with emails from the company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website or service tied to the web beacon, and a description of a website or service tied to the web beacon. For example, ELEVATE may place web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the company’s websites. ELEVATE uses web beacons to operate and improve the company’s websites, services and email communications.

Log Files, IP Addresses, URLs and Other Data

As is true of most websites, we gather certain information automatically to analyze trends in the aggregate and administer our websites and services. This information may include your internet protocol (IP) address (or the proxy server you use to access the world wide web), device and application identification numbers, your location, your browser type, your internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. Due to internet communications standards, when you visit or use the company’s websites and services, we automatically receive the URL of the website from which you came and the website to which you go when you leave our website. This information is used to analyze overall trends, to help us improve our websites and services, to track and aggregate non-personal information, and to provide the websites and services. For example, ELEVATE uses IP addresses to monitor the regions from which customers and visitors navigate the company’s websites. ELEVATE also collects IP addresses from customers when they log into the services as part of the company’s “identity confirmation” and “IP range restrictions” security features.

Social Media Features and Single Sign-on

The company’s websites may use social media features, such as the Facebook “like” button (“social media features”). These features may collect your IP address and which page you are visiting on the company’s website, and may set a cookie to enable the feature to function properly. You may be given the option by such social media features to post information about your activities on the company’s website to a profile page of yours that is provided by a third-party social media network in order to share with others within your network. Social media features are either hosted by a third-party or hosted directly on the Company’s website. Your interactions with these features are governed by the privacy policy of the company providing the relevant social media features. ELEVATE may also allow you to log in to certain of our websites and services using sign-in services such as Facebook Connect. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form.

Do Not Track

Currently, various browsers — including Internet Explorer, Firefox, and Safari — offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to websites’ visited by the user about the user’s browser DNT preference setting. ELEVATE does not currently commit to responding to browsers’ DNT signals with respect to the company’s websites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. ELEVATE takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

Public forums, refer a contact, and customer testimonials

ELEVATE may provide bulletin boards, blogs, or chat rooms on the company’s websites. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. ELEVATE is not responsible for the personal information you choose to submit in these forums.

Customers and visitors may elect to use the company’s referral program to inform contacts about the company’s websites and services. When using the referral program, the company requests the contact’s name and email address. ELEVATE will automatically send the contact a one–time email inviting him or her to visit the company’s websites. ELEVATE does not store this information.

ELEVATE posts a list of customers and testimonials on the company’s websites that contain information such as customer names and titles. ELEVATE obtains the consent of each customer prior to posting any information on such a list or posting testimonials.

Sharing of information collected

Service Providers

ELEVATE may share data about ELEVATE visitors, customers and attendees with the company’s contracted service providers so that these service providers can provide services on our behalf. These service providers are authorized to use your personal information only as necessary to provide the requested services to us. Without limiting the foregoing, ELEVATE may also share data about ELEVATE visitors, customers and attendees with the company’s service providers to ensure the quality of information provided, and with third–party social networking and media websites, such as Facebook, for marketing and advertising on those web sites. Unless described in this privacy statement, ELEVATE does not share, sell, rent, or trade any information with third-parties for their promotional purposes.

ELEVATE affiliates

The Company may share data about ELEVATE customers with other companies to work with them, including other companies owned by ELEVATE. For example, the company may need to share data about ELEVATE customers with other ELEVATE-owned companies for customer support, marketing, analytics, technical operations and account management purposes.

Business partners

ELEVATE does not share data about ELEVATE attendees with business partners unless: (1) you specifically opt in to such sharing via an event registration form; or (2) you attend a company event and allow ELEVATE or any of its business partners to scan your attendee badge. If you do not wish for your information to be shared in this manner, you may choose not to opt in via event registration forms and elect not to have your badge scanned at company events. If you choose to share your information with business partners in the manners described above, your information will be subject to the business partners’ respective privacy statements.

Third-parties

The section on website navigational information, specifically addresses the information we or third-parties collect through cookies and web beacons, and how you can control cookies through your web browsers. We may also disclose your personal information to any third-party with your prior consent.

Billing

ELEVATE uses a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use billing information except for the sole purpose of credit card processing on the company’s behalf.

Compelled disclosure

ELEVATE reserves the right to use or disclose information provided if required by law or if the company reasonably believes that use or disclosure is necessary to protect the company’s rights and/or to comply with a judicial proceeding, court order, or legal process.

International transfer of information collected

ELEVATE is headquartered in Hong Kong, and has operations, entities and service providers throughout the world. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it. A list of the company’s global offices is available on our web site. This privacy statement shall apply even if ELEVATE transfers data about ELEVATE customers or data about ELEVATE attendees to other countries.

Managing your preferences

ELEVATE offers visitors, customers, and attendees who provide contact information a means to choose how the company uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of the company’s marketing emails.

If you or the firm you work for (as applicable, on our websites) decides to deactivate or delete your account on ELEVATE websites, then you will no longer receive any communications from us, and other users will not be able to interact with you; however Your Content will remain in ELEVATE’s databases.

You may, of course, decline to submit information through the ELEVATE websites, in which case we may not be able to provide certain services to you. You may also control the types of notifications and communications we send, and otherwise amend certain privacy settings.

Correcting and updating your information

ELEVATE may retain your information for a period of time consistent with the original purpose of collection. For instance, we may retain your information during the time in which you have an account to use our websites or services and for a reasonable period of time afterward. We also may retain your information during the period of time needed for ELEVATE to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

You may request to review, correct, delete or otherwise modify any of the personal information that you have previously provided to us through the company’s websites and services. If you have registered for an account with ELEVATE, you may generally update your user settings, profile, organization’s settings or event registration by logging into the applicable website or service with your username and password and editing your settings or profile. To update your billing information, discontinue your account, and/or request return or deletion of your data associated with your account, please contact your account representative. Requests to access, change, or delete your information will be addressed within a reasonable timeframe.

Customer data

ELEVATE’s customers may electronically submit data or information to the services for hosting and processing purposes (“customer data”). ELEVATE will not review, share, distribute, or reference any such customer data except as provided in ELEVATE’s terms of service, or as may be required by law. In accordance with ELEVATE’s terms of service, ELEVATE may access customer data for the purpose of providing the services or preventing or addressing service or technical problems or as may be required by law.

ELEVATE acknowledges that you have the right to access your personal information. If personal information pertaining to you as an individual has been submitted to us by an ELEVATE customer and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please inquire with our customer directly, because ELEVATE personnel have limited ability to access data our customers submit to our services.

Security

ELEVATE has implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction. ELEVATE’s policy is to use secure socket layer technology for the protection of credit card information submitted through web forms. This policy is also required for any fulfilment agents of our firms.

The security of your information is important to us. ELEVATE has implemented safeguards to protect the information we collect. However, no website or Internet transmission is completely secure. We urge you to take steps to keep your personal information safe, such as choosing a strong password and keeping it private, as well as logging out of your user account, and closing your web browser when finished using ELEVATE websites on a shared or unsecured device.

Children

ELEVATE understands the importance of protecting children’s privacy especially in an online environment. This website is not intentionally designed for or directed at children 13 years of age or younger. It is ELEVATE’s policy never to knowingly collect or maintain information about anyone under the age of 13.

Mobile applications

Without limiting the generality of this privacy statement, in addition to information gathered through its websites or submitted to its services, ELEVATE may obtain information through applications (“mobile applications”) that customers or their authorized individuals (“users”) download to, and run on, their mobile devices (“devices”). Mobile Applications provided by ELEVATE may obtain information from, or access data stored on, Users’ Devices to provide services related to the relevant Mobile Application. For example, a Mobile Application may: access a camera on a User’s Device to enable the User to upload photographs to the Services; access the call history on a User’s Device to enable the User to upload that information to the Services; access calendar information on a User’s Device to enable the User to match meeting attendees with contacts submitted by the User to the Services; access the geographic location of a User’s Device to enable the User to identify contacts submitted by the User the Services who are nearby; or access contact information on a User’s Device to enable the User to sync contact information between the information that is stored on the User’s Device and the information that is submitted to the Services. Information obtained to provide Mobile Application services may include information obtained in preparation for anticipated updates to those services. Mobile Applications may transmit information to and from Devices to provide the Mobile Application services.

Mobile Applications may provide ELEVATE with information related to Users’ use of the Mobile Application services, information regarding Users’ computer systems, and information regarding Users’ interaction with Mobile Applications, which ELEVATE may use to provide and improve the Mobile Application services. For example, all actions taken in a Mobile Application may be logged, along with associated information (such as the time of day when each action was taken). ELEVATE may also share anonymous data about these actions with third party providers of analytics services. In addition, if a User downloads a ELEVATE Mobile Application after clicking on a third-party mobile advertisement for the Mobile Application or for ELEVATE, the third-party advertiser may provide ELEVATE with certain information, such as the User’s Device identification information, which ELEVATE may use to track the performance of its advertising campaigns.

Customers may configure ELEVATE Mobile Application services, and the information accessed or obtained by the Mobile Application on a User’s Device may be affected by the Customer’s configuration. In addition, if a Customer purchases more than one Service from ELEVATE and its affiliates, a Mobile Application may be designed to interoperate with those Services; for instance, to provide a User with access to information from any or all of those Services or to provide information from a User’s Device to any or all of those Services. Information accessed or obtained by the Mobile Application on a User’s Device may be accessible to the Customer and its organization, depending on the intended functionality of the Mobile Application. ELEVATE may provide updated versions of its Mobile Applications. If your mobile device’s settings permit, those updates will be downloaded and installed automatically on your mobile device. By installing a ELEVATE Mobile Application on your mobile device, you consent to the downloading and updating of that Mobile Application.

In addition to Mobile Applications offered by ELEVATE, the Company may offer platforms for the creation of third-party Mobile Applications, including but not limited to the ELEVATE platform. Third-parties may obtain information from, or access data stored on, Users’ Devices to provide services associated with any third-party Mobile Applications that Users download, install, use, or otherwise interact with over a ELEVATE platform. ELEVATE’s Mobile Applications may also contain links or integrations to other Mobile Applications provided by third-parties. Third-parties’ use of information collected through third-party Mobile Applications is governed by the privacy statements of such third-parties. The Company encourages you to review the privacy statements of third-party providers of Mobile Applications to understand their information practices.

Notices and contractual terms related to a particular Mobile Application may be found in the End User License Agreement or relevant terms of service for that application. The Company encourages you to review the End User License Agreement or relevant terms of service related to any Mobile Applications you download, install, use, or otherwise interact with to understand that Mobile Application’s information practices. The Mobile Application’s access to information through a User’s Device does not cause that information to be “Customer Data” under ELEVATE’s terms of services or under this Privacy Statement, except as follows: To the extent that a User uses a Mobile Application to submit electronic data and information to a Customer account on our Services pursuant to the Customer’s Master Subscription Agreement with ELEVATE (or a similar agreement that governs the Customer’s subscription(s) to ELEVATE’s Services), that information constitutes “Customer Data” as defined in such agreement, and the provisions of that agreement with respect to privacy and security of such data will apply. Additional information about the Company’s privacy and security practices with respect to Customer Data is available here.

Changes to this Privacy Statement

ELEVATE reserves the right to modify or amend this Statement at any time by publishing an updated version here. The current version of the statement will be accessible on this website. If we make any changes to this Privacy Policy that materially change how we treat your personal information, we will endeavor to provide you with reasonable notice of such changes, such as via prominent notice on the relevant ELEVATE website or to your email address of record, and where required by law, we will obtain your consent or give you the opportunity to opt out of such changes.

This Privacy Policy was last modified on 24 May 2018 and goes into effect immediately.

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