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Responsible recruitment and tourism

  • Published: 7 November 2018
  • Author: Ruhi Mukherji

Rising disposable incomes and falling relative costs of travel worldwide have led to a boom for the tourism and hospitality sectors. Combined, they are one of the world’s largest economic sectors, accounting for a total of 10.4% of global GDP and 9.9% of total employment in 2017. This growth is evident across Asia, where rising middle classes particularly in China and Vietnam have contributed significantly to regional tourism. The APAC region accounted for 37% of the world’s tourism expenditure, and saw the fastest growth in international arrivals averaging a 7% annual increase. Tourism represents a significant source of GDP generation and employment across Asia, in particular for Thailandthe Philippines and the Maldives. The World Tourism Organization (UNWTO) strongly believes that the tourism and hospitality sectors can play a positive role in development and contribute to achieving the SDGs.

The growing tourism and hospitality sectors have cast a spotlight on sustainable tourism in terms of influencing the policies utilized by both companies and governments, and in guiding the behaviour of travellers. Sustainable tourism involves “tourism that takes full account of its current and future economic, social and environmental impacts, addressing the needs of visitors, the industry, the environment and host communities”. There is increasing recognition of the impacts of tourism and hospitality on the development of countries. For example, Thailand, Philippines and Bhutan have implemented strict regulation to mitigate the impacts of mass tourism. Discourse has centred around the environmental issues caused by mass tourism; however, there is also a significant social dimension stemming from the nature of employment within the hospitality and tourism sectors.

Tourism, Hospitality and Labour
The hospitality and tourism sectors are  labour-intensive, and allow women, migrant workers, and youth a viable means of entry into the workforce. Workers in this sector may be vulnerable due to:

  • Lack of employment security for the low barrier to entry categories of work in the sector, as temporary and seasonal workers often have lower bargaining power with their employers.
  • Fluctuations in seasonal demand for labour, flexible working hours and low-wages, have resulted in the use of short-term insecure contracts and a reliance on migrant labour.
  • Lack of access to fair and reliable grievance mechanisms, particularly for migrant workers. Migrants feel that using such a mechanism will result in the termination of their employment, or further abuse, and as such, are unlikely to lodge any complaints.
  • Issues of forced and bonded labour, together with workers incurring high recruitment related debt, have grown in prevalence. The Polaris Project’s study of labour trafficking found that this was prevalent in both the hospitality industry’s workforce, and its supply chain.

Companies in the travel and hospitality sectors are having to focus their attention on ethical employment practices, such as responsible recruitment, to mitigate these issues. Responsible recruitment policies aid in ensuring that best practices are integrated right at the onset of employment (or contractual work), and function along with other initiatives such as internal development and staff capacity building.

Industry Initiatives
Increasing recognition of ethical employment and responsible recruitment within the hospitality industry is demonstrated by the launch in 2018 of the Principles on Forced Labourby the International Tourism Partnership (ITP). Thirteen hotel groups have endorsed the Principles, which specify that employees should be entitled to freedom of movement, the removal of recruitment fees, and the elimination of indebted and coerced employment. The ITP Principles represent a foundational step towards ensuring responsible recruitment practices are implemented industry-wide, and allow members to prioritize actions.


Source: International Tourism Partnership, 2018

Madhu Rajesh, Director of the International Tourism Partnership said, “We know there are migration channels between Asian countries and from Asia to the Middle East which can contribute to the risk of trafficking and forced labour. Low skilled workers are particularly vulnerable. That’s why the work of our members and ITP, although global, is really targeting Asia to raise awareness and put programmes in place that help mitigate the risk. Our member hotel companies are working hard to train colleagues and to adopt the ITP Principles on Forced Labour, and we very much hope the wider industry will also adopt them as recruitment best practice. Across our membership, tens of thousands of hotel staff have been trained to recognise and act when they suspect trafficking might be taking place, and many children in Asia have been rescued from harm because of this training. It’s vital we continue to act to protect vulnerable workers, and our businesses from this awful crime.”

Another initiative by the International Organization for Migration (IOM) – the UN Migration Agency, called ‘CREST’ (Corporate Responsibility in Eliminating Slavery and Trafficking in Asia)CREST is a regional partnership initiative that aims to realize the potential of businesses and private sector actors to uphold human and labour rights of migrant workers in their operations and supply chains. Migrant workers are disproportionately exposed to risks of exploitation. IOM CREST partners with companies across Asia to work towards the elimination of modern slavery by assessing recruitment and employment practices of migrant workers and supporting businesses in adopting ethical recruitment standards and due diligence procedures. IOM utilizes the CREST initiative to advocate for responsible recruitment principles with both public and private sector actors. “Companies can be implicated in modern slavery both directly and indirectly – either in their own operations or supply chains. It is clear to IOM, that businesses have emerged as a key driver for the elimination of modern slavery. Once committed, companies can create sustainable solutions within their own operations and supply chains, and can also show leadership to inspire other stakeholders to take similar action,” said Maximillian Pottler, CREST Project Manager, IOM Vietnam.

Furthermore, to gain and share better understanding of the potential risks associated with modern slavery within businesses and supply chains in the Southeast Asian Hospitality sector, IOM is now conducting fact-finding interviews and surveys. We look forward to hearing more about these initiatives by IOM at CSR Asia’s inaugural Sustainable Tourism Asia.

It is likely that initiatives such as these will grow in prevalence across the hospitality and tourism sectors in Asia, as sustainable tourism takes on a larger focus in the region.

CSR Asia is hosting the Sustainable Tourism Asia Forum on 29 November 2018, at Marina Bay Sands Singapore. The forum will serve as a platform for leading companies in the hospitality and tourism sectors, together with government officials, and non-profits, and will catalyse opportunities and collaboration in the areas of: multi-stakeholder partnerships, responsible labour practices, and technological innovations, amongst many others. Sessions and workshops will be run by experts across industries and sectors, including the Global Sustainable Tourism Council (GSTC), Expedia Group, Intercontinental Hotels Group and Pacific Asia Travel Association (PATA).

We look forward to your participation in these engaging dialogues, and to welcoming you at Sustainable Tourism Asia.

We would like to sincerely thank both ITP and IOM for contributing to this article.

For more details on ITP’s Principles on Forced Labour and IOM’s CREST Initiative, please contact Madhu Rajesh, Director ITP, Madhu.Rajesh@bitc.org.uk, and Wiebke Flach, IOM CREST Private Sector Engagement Specialist, wflach@iom.int, respectively.


This article is part of a series of CSR Asia articles titled, “Sustainable Tourism Asia: Solutions for Tourism + Hospitality”
Other articles from this series include:


Privacy Policy

ELEVATE and its subsidiaries and affiliates (“we,” “us,” “our,” “company,” or “ELEVATE”) are committed to protecting the privacy of individuals who visit our website (“visitors”), individuals who register to use the services as defined below (“customers”), and individuals who register to attend events organized by us (“attendees”).

This privacy statement defines our privacy practices for ELEVATE in relation to the use of our websites and the related application and services we offer (collectively, the “services”), as well as individuals’ choices regarding use, access and correction of personal information.

Your use of ELEVATE services expressly indicates to ELEVATE that you have read and understood this Privacy Policy and that you agree to the aspects covered in this Policy as they pertain to the collection and use of any applicable personal data.

ELEVATE makes every practical effort to avoid excessive or irrelevant collection of data. If a visitor believes the site has collected excessive information, we encourage the visitor to contact us at privacy@elevatelimited.com to raise any concerns.

Websites covered

This privacy statement covers the information practices, including how the company collects, uses, shares and secures the personal information you provide, of websites that link to this privacy statement (collectively referred to as “ELEVATE’s websites” or “the company’s websites”).

ELEVATE’s websites may contain links to other websites. The information practices or the content of such other websites is governed by the privacy statements of such other websites. The company encourages you to review the privacy statements of other websites to understand their information practices.

Information collected

When expressing an interest in obtaining additional information about our services, or registering to use the websites or other services, or registering for an event, ELEVATE requires you to provide personal contact information, such as name, company name, address, phone number, and email address (“required contact information”). When purchasing the services or registering for an event, ELEVATE may also require you to provide financial qualification and billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the services (“billing information”). ELEVATE may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“optional information”). When visitors apply for a job with the company, ELEVATE may also require you to submit additional personal information as well as a resume (“applicant information”). Required contact information, billing information, applicant information, optional information and any other information you submit to ELEVATE to or through the services are referred to collectively as “data.”

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).

We collect and store the information and content that you store in ELEVATE solutions, including transactions you perform, actions you take in the applications, comments, etc. Your Content, date and time stamps, and all associated comments solutions may be available for viewing to other users (either from your firm, or to people in ELEVATE) along with your name.

When you communicate with us (via email, phone, through the ELEVATE websites or solutions, or otherwise), we may maintain a record of your communication.

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.

ELEVATE’s intention is not to seek any sensitive information through our website unless legally required for recruiting purposes. Sensitive information includes a number of types of data relating to: age, race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health; sexual life or criminal record. We suggest that you do not provide sensitive information of this nature. If you do wish to provide sensitive information for any reason, ELEVATE accepts your explicit consent to use that information in the ways described in this privacy statement or as described at the point where you choose to disclose this information.

Use of information collected

The company uses data about ELEVATE customers to perform the services requested. For example, if you fill out a “contact” webform, the company will use the information provided to contact you about your interest in the services.

The Company also uses data about ELEVATE attendees to plan and host corporate events, host online forums and social networks in which event attendees may participate, and to populate online profiles for attendees on the company’s websites. Additional information on the company’s privacy practices with respect to data about ELEVATE attendees may be found in additional privacy statements on the event websites, as the case may be.

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.

When a visitor provides personal information to us, we use it in connection with the purposes for which it was provided to us, as stated at the point of collection (or as obvious from the context of collection). This data is not shared with other entities in the network for secondary or unrelated purposes, or shared with a third-party other than as described in this statement or otherwise disclosed at the point of collection. If there is an instance where such information may be shared, the visitor will be asked for permission beforehand.

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.

Because required cookies are essential to operate the company’s websites and the services, there is no option to opt out of these cookies.

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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