PRIVACY POLICY

Effective: November 24, 2025

The Elevate Prize Foundation, Inc. (“we,” “us,” “our”) works hard to build and maintain a relationship of trust with you. This Privacy Policy (the “Privacy Policy”) governs our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our websites on which this Privacy Policy is linked (collectively, “Sites”) and any transactions, interactions, or other engagements you might have with us (collectively, “Services”).

Please read this Privacy Policy carefully before using our Sites and/or Services. By accessing or using our Sites and/or Services you agree to our use of your information consistent with this Privacy Policy. If you do not agree with this Privacy Policy, you must refrain from using our Sites and/or Services.

This Privacy Policy does not address our privacy practices with regard to employees, contractors, job applicants, and persons associated with them such as emergency contacts. It also does not address our collection and use of information about nonprofit organizations, businesses, and other legal entities.

Information We Collect

Personal Information

We may collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:

Personal identifiers and contact information such as name, mailing address, email address, phone number, account login information;
Commercial information such as payment card or bank account information;
Professional/employment information such as occupation, employment status and history, education level, business/organization name, and job title;
Audio, electronic, visual, thermal, olfactory, or similar information such as call and written communication recordings; and
Internet & network information such as browsing/search history, IP address, data collected by cookies and similar technologies, device specifications such as device IDs, specifications, and operating system.

If you receive a prize award from us, we may also collect:

Social Security Number or other governmental identifiers which we categorize as personal identifiers and contact information
Information about your finances and use of the prize funds which we categorize as commercial information

The types of Personal Information we collect about you may vary based on how you use our Sites and/or Services and your relationship with us.

Usage Data and Site Activity

We automatically collect information in connection with the actions you take on our Sites (“Usage Data”). For example, each time you use our Sites, we may automatically collect the type of web browser you use, the type of device you use, your device ID, your operating system and version, your IP address, your internet service provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within our Sites, and the duration of your visits to our Sites. If the data we automatically collect is capable of being associated with you, directly or indirectly, we treat it as Personal Information. If this information is not capable of being individually associated with you, we treat it as anonymous Usage Data.

Communication Recordings

We may record calls and retain the content of written and electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.

How We Collect Information

Voluntary Disclosure

We may ask you to provide us with Personal Information when you communicate with us, including when you request information from us, sign up for our newsletter, or submit a nomination for one of our prize awards. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of our Sites or Services or we may not be able to fulfill your requested interaction. By submitting your Personal Information to us, you consent to our collection, use, disclosure, and retention in accordance with this Policy.

Third-Party Data Sources

We may collect Personal Information from third-party data sources such as other individuals who submit a nomination for one of our prize awards, due diligence vendors, marketing agencies or partners, and analytics firms.

Cookies

Cookies and Automated Tools

We use cookies (a small text file placed on your computer to identify your computer and browser) and other automated tools such as pixels to track your interaction with our Sites and to improve the experience of our Sites and Services, such as saving your preferences from visit to visit to present you with a customized version of the Website. We may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including details of your visits to our Sites, communication data, resources that you access and use on the Sites, IP address, operating system, and browser type.

Many web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of our Sites or Services may not work if you delete or disable cookies.

We use the following types of cookies and other automated tools:

Strictly Necessary: These tools are essential to operate the Sites or Services and provide you with services you have requested including to identify and repair errors in the Sites or Services.
Functional: These tools enable certain features or non-essential functionality on our Sites or Services. For example, we might use these tools to recognize you and remember your preferences or settings when you return to our Sites or Services.
Advertising: These tools allow us and third parties to learn more about you, including your use of our Sites, Services, and other websites, and advertise products or services that might interest you including our products and services.
Analytics: These tools help us and third parties understand how our Sites are working and who is visiting our Sites.

User activity information may be associated with additional information about a user’s session and Personal Information, if provided by the user.

We and third parties also use tools that enable us to track certain aspects of a user’s visit to our Sites. This technology helps us better manage content on our Sites by informing us what content is effective, how consumers engage with our Sites, and how consumers arrive at and/or depart from our Sites. The software typically uses two methods to track user activity: (1) “tracking pixels” and (2) “clear gifs.” Tracking pixels are pieces of executable code that are embedded in a web page that tracks usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether a user views a web page or email message. User activity information may be associated with additional information about a user’s session and Personal Information, if provided by the user.

If you arrive at our Sites by “clicking through” from another website, then certain information about you that you provided to that other website, such as the terms you searched that led you to our Sites, may be transmitted to us and we may use it. You should review the Privacy Policy of any website from which you reached our Sites to determine what information the operator collects and how it uses such information. We may retain information about you provided to us by other websites and will use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.

The following is a list of the cookies that may be used and installed on your computer or device depending on your engagement with our Sites or Services:

Cookie Name	First-Party or Third-Party?	If Third-Party, who?	If Cookie, how long does it reside on device?	Essential?	Purpose
_ga	Third Party	Google	2 years	No	Analytics
_fbp	Third Party	Facebook	3 months	No	Marketing
elfsight_viewed_recently	Third Party	core.service.elfsight.com	1 day	No	Marketing
YSC	Third Party	Youtube	Session	No	Marketing
_cf_bm	Third Party	Cloudflare	Session	Yes	Analytics

Google Analytics

One tool we use is Google Analytics. For more information about Google Analytics, including how it collects and processes Personal Information and Usage Data, please review Google’s Safeguarding Your Data disclosure.

Targeted and Cross-Context Behavioral Advertising

We may work with third-party advertisers, search providers, social media companies, and ad networks (collectively, “Ad Networks”) to learn more about you and show you ads or other content that we believe would be relevant to you. Advertisers may collect and use information about your use of our Sites or Services as well as other websites and services. These companies may use cookies and other online tracking technologies to collect and use your information. We and/or Ad Networks may also append other data to the data collected by Ad Networks to create an interest profile of individual users. Our Privacy Policy does not cover any use of information that an Ad Network may collect from you except when the Ad Network acts as our service provider.

Social Media Widgets

Our Sites may include social media features, such as the Facebook, YouTube, Instagram, LinkedIn and X widgets. These features may collect information about your IP address and the pages you visit on our Sites as well as other Personal Information. A Cookie may be set to ensure that these features properly function. These companies’ privacy policies govern your interactions with these features and you should review the relevant privacy policies before interacting with these features.

Information from Advertisements

If you arrive at our Sites via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date and time).

How We Use and Share Information

Generally

We may use Personal Information for business purposes, such as:

Prize awarding: to receive and evaluate applications for, and award and monitor usage of, prizes;
Fulfilling user requests and support: to address questions, concerns, and requests related to our events, prizes, and operations;
Marketing: to send communications and offers for our prizes, events, and other offerings;
Website use and analytics: to provide you with access to and use of our Sites and Services, analyze consumers’ use of our websites, including the use of third-party web analytics services, which may utilize automated technologies to collect data;
Service research: to conduct research and analysis for maintaining, protecting, and developing our services and programs;
Business operations: to evaluate, develop, and improve business operations, services and programs offered, perform business administration and other normal business activities;
Security and safety: to prevent fraud, theft, or violations of our security or the security of third parties; and
Compliance: to comply with applicable legal requirements, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights and the rights of others.

We will use and disclosure your Personal Information only for the purposes set out in this Privacy Policy and will obtain your consent for any other use not set out in this Privacy Policy unless otherwise permitted by law.

Service Providers

We may provide your Personal Information to other businesses (“Service Providers”) to provide services to us or on our behalf. Categories of Service Providers we use include:

Fulfillment and relationship servicing vendors, which help us provide services, programs, and information to you and service our relationship with you;
Payment processors, which help us to accept and process payments;
Marketing and communications vendors, which help us market our services and programs to you, show you advertisements, and conduct other outreach campaigns, including vendors providing email, telephone, and text message services;
Research and development vendors, which help us develop and improve our services and programs;
Data and analytics vendors, which help us collect, analyze, and improve the accuracy of our data (including Personal Information);
IT and network administration vendors, which provide services such as data storage and management, website hosting, and data security;
Professional service firms, which provide accounting, legal and other professional services; and
General service providers, which help us with day-to-day business operations such as office support services, courier services, facilities management, and document destruction.

Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure.

Our Service Providers may not be located in your jurisdiction. If you wish to learn more about the Service Providers we use, please contact us at [insert email].

Third-Party Disclosures

We do not sell your Personal Information. We may share (for targeted or cross-context behavioral advertising) Personal Information with third parties who are not our Service Providers (“Third Parties”). In the past twelve months, we have shared Personal Information as follows:

Category of Third Party

Sale or Share

Purpose of Sale or Share

Categories of Personal Information

Ad networks & ad technology providers

To facilitate advertising of our programs and services

· Personal identifiers and contact information

· Commercial information

· Internet & network information

We may occasionally disclose your Personal Information to Third Parties for purposes such as:

To advertising partners to facilitate transactions or interactions (e.g., marketing) requested by you.
To comply with the law.
To respond to legal requests (including court orders, investigative demands and subpoenas) if, in our discretion, we believe it is necessary or appropriate.
To prevent or stop any illegal, unethical, or legally actionable activity.
To protect the safety, property, or rights of ourselves, consumers, or any other third party.
If we are merged, acquired, or sold, or in the event of a divestiture, restructuring, reorganization, or transfer of some or all of our assets and the disclosure is necessary to complete the transaction.
To organizations controlling, controlled by, or under common control with us as permitted by law.
For additional purposes with your consent where such consent is required by law.

California Shine the Light Disclosure – Your Privacy Rights

We do not sell Personal Information to third parties for their own direct marketing purposes.

Other Important Privacy Provisions

Security

We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Sites or Services, you do so at your own risk.

Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.

International Transfers

Personal Information will be processed in the United States.

Persons located in the European Economic Area, Switzerland, or United Kingdom (collectively, “Europe”): Whenever we transfer Personal Information we ensure that we have your consent or adequate safeguards are in place as required by the GDPR or its national equivalent, as applicable, by either (i) transferring your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission or appropriate national data protection authority or (ii) using standard contractual clauses approved by the European Commission as supplemented by required terms promulgated by the appropriate national data protection authority which give Personal Information a similar amount of protection as it has in Europe, including additional safeguards as needed. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Information out of Europe.

Quebec residents: Your Personal Information may be disclosed outside Quebec. In such cases, we undertake to conduct a privacy impact assessment and to make the disclosure only if the Personal Information disclosed is adequately protected. In such cases, the disclosure of the Personal Information will be subject to a written agreement that considers the results of such assessment and any terms and conditions agreed to in order to mitigate the risks identified in such assessment.

By providing Personal Information to us, you consent to the transfer to and processing of your Personal Information in the United States.

Links and Other Websites

Our Sites may contain links to third party websites. Please be aware that if you access these links, you will be leaving our Site. We encourage users to read the privacy policies of those sites, as we are not responsible for their content, links, or privacy procedures.

Data Retention

We will only retain your Personal Information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation or regulatory inquiry in respect to our relationship with you.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

Updates

We may update this Privacy Policy in the future and will post any updates on our Sites. Updates are effective immediately upon posting. If you use our Sites or Services after the update, you agree to the updated Privacy Policy.

Children’s Privacy

Our Sites and Services are not intended for children under the age of 18 and we do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have inadvertently received Personal Information from a child under the age of 18, we will delete such information from our records.

Your Privacy Rights

Under certain circumstances, you have rights in relation to your Personal Information, including the right to:

Request access to your Personal Information. This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request deletion of your Personal Information. This enables you to ask us to delete or remove Personal Information when there is no legally valid reason for us to process it. You also have the right to ask us to delete or remove your Personal Information when you have successfully exercised your right to object to processing (see below), when we may have processed your information unlawfully, or when we are required to erase your Personal Information to comply with local law. However, please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your Personal Information when we are relying on a Legitimate Interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it infringes your fundamental rights and freedoms. You also have the right to object when we are processing your Personal Information for marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios:

o If you want us to establish the data’s accuracy.

o When our use of the data is unlawful, you do not want us to erase it.

o When you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.

o You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal Information to you or to a third party. We will provide your Personal Information in a structured, commonly used, machine-readable format. Please note that this right only applies to Personal Information that you provided to us.
Withdraw consent at any time when we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain sites or services to you. We will advise you if this is the case at the time you withdraw your consent.

Exercising Rights

If you wish to exercise any of the rights set out above, please contact us via email at Web@elevateprize.org or physical mail at 276 NW 27th Street, Miami, FL 33127.

Generally, you will not have to pay a fee to exercise any of the rights described herein. However, if your request is clearly unfounded, repetitive, or excessive, we may charge a reasonable fee or refuse to comply with your request. We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. If we decline your request, we will tell you why, subject to legal restrictions.

Complaints or Concerns

You have the right to make a complaint at any time to the supervisory authority for data protection issues in country in which you reside. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

California “Do Not Track” Disclosure

Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. Currently, our Sites and Services do not respond to “do not track” signals.

Notice to Persons in the European Economic Area, Switzerland, or the United Kingdom

This section applies only to individuals located in the European Economic Area, Switzerland, or the United Kingdom.

Personal Information

Any reference to “Personal Information” in this Privacy Policy is equivalent to “Personal Information” governed by European data protection laws (collectively, “European Laws”).

Controller

The Elevate Prize Foundation, Inc. is the controller of Personal Information covered by this Privacy Policy for purposes of European Laws.

Lawful Basis for Processing

We use your Personal Information for business purposes as outlined below and only as permitted by law.Our processing of your Personal Information may require sharing it with third parties in order to accomplish the stated purpose.

Purpose of Processing	Personal Information Processed	Lawful Basis
*Prize awarding:* to receive and evaluate applications for, and award and monitor usage of, prizes.
*Fulfilling user requests and support*: to address questions, concerns, and requests related to our events, prizes, and operations.	Personal identifiers and contact information; Commercial information;Audio, electronic, visual, thermal, olfactory, or similar information; and Internet & network information.	Processing necessary for performance of a contract or to take steps at the request of the data subject prior to entering into a contract; Legitimate Interest in providing our Services to you.
*Marketing*: to send communications and offers for our prizes, events, and other offerings.	Personal identifiers and contact information; Commercial information;Professional/employment information; and Internet & network information.	Consent.
*Website use and analytics*: to provide you with access to and use of our Sites and Services, analyze consumers’ use of our websites, including the use of third-party web analytics services, which may utilize automated technologies to collect data.	Personal identifiers and contact information; Commercial information; and Internet & network information.	Legitimate Interest in correcting errors in and improving our Services.
*Service research*: to conduct research and analysis for maintaining, protecting, and developing our services and programs.	Personal identifiers and contact information; Commercial information; and Internet & network information.	Legitimate Interest in correcting errors in and improving our Services.
*Business operations*: to evaluate, develop, and improve business operations, services and programs offered, perform business administration and other normal business activities.	Personal identifiers and contact information; Commercial information;Audio, electronic, visual, thermal, olfactory, or similar information; Professional/employment information; and Internet & network information.	Processing necessary for performance of a contract or to take steps at the request of the data subject prior to entering into a contract; Legitimate Interest in correcting errors in and improving our Services.
*Security and safety*: to prevent fraud, theft, or violations of our security or the security of third parties.	Personal identifiers and contact information; Commercial information; and Internet & network information.	Legitimate Interest in preventing harm to ourselves and others from malicious activity.
*Compliance*: to comply with applicable legal requirements, industry standards, contractual obligations, our policies, and take actions that we deem necessary to preserve and enforce our rights and the rights of others.	Personal identifiers and contact information; Commercial information; Professional/employment information; and Internet & network information.	Compliance with legal obligations; Legitimate Interest in protecting our legal rights and the legal rights of others.

“Legitimate Interest”, means the interests of our organization in conducting and managing our organization to enable us to give you the best Sites and Services possible and protect our reasonable organizational concerns. We consider and balance any potential impact on you (positive and negative) and your rights under European Laws before we process Personal Information for our Legitimate Interest. We do not process Personal Information for our Legitimate Interests if we determine that our interests are overridden by the impact on your rights (unless we have consent, or the processing is otherwise permitted by law). You may contact us if you would like more information about how we assess our Legitimate Interests.

If consent is our lawful basis for processing your Personal Information, we will obtain consent from you prior to processing your Personal Information for the purpose for which consent is required and you may revoke your consent at any time by contacting us using the contact information below.

Change of Purpose

We may use your Personal Information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your Personal Information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Special Categories of Personal Information

We ask that you not provide us with any special categories of Personal Information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Site or Service, or otherwise to us.

If you provide any special categories of Personal Information to us when you use the Site or Service, you must consent to our processing and use of such special categories of Personal Information in accordance with this Privacy Policy. If you do not consent to our processing and use of special categories of Personal Information, you must not submit such special categories of Personal Information through our Site or Service.

Contact Us

Our Privacy Officer is responsible for overseeing what we do with your information and for monitoring compliance with this Privacy Policy and data protection laws. If you have any questions, concerns, or complaints about this Privacy Policy or the practices described herein, please contact us via email at Web@elevateprize.org or physical mail at 276 NW 27th Street,Miami, FL 33127.