Eldera (“Eldera,” “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy describes how we collect, use, and disclose your information across the websites we operate and the services we provide. This Privacy Policy explains:

We also include specific disclosures for residents of California and Nevada, as well as for individuals located in the European Economic Area, Switzerland, and the United Kingdom.[C1]

This Policy applies to Eldera and our website, available at www.eldera.ai, and services (the “Services”). Sometimes we link to other websites or mobile applications (“apps”) that are not Eldera- this policy does not apply to those. Sometimes other websites or apps link through to Eldera, (such as when you Google our website). This policy does not apply to those either. Every organization, website, and app has its own privacy policy, and it may vary from ours. We advise that you review the policies on those websites and apps directly to understand their practices.

1.Information We Collect

Information You Provide

Like any website where a user navigates onto a page or signs up for a service, we sometimes collect, process, and retain information you enter.

Here are some examples of the kind of information we collect:

If you are a mentor:

If you are a parent or guardian of a student:

Information We Collect Automatically

When you interact with our website and Services, certain information about your use is automatically collected. This information is collected through cookies, web beacons, and other tracking technologies, as well as through your web browser or device. We have included an explanation of cookies and web beacons at the end of our policy. They are used throughout the internet, so it’s a good idea to know what they are and when you are or are not happy for them to be used.

At Eldera we might use cookies to collect the following:

Most web browsers automatically accept cookies but if you would rather not do so, you can usually modify your browser settings to disable or reject them. If you delete your cookies or if you set your browser to decline them, some features of our services may not be available or work as designed. But we will not block you from our website or services, so you can still use Eldera without enabling cookies.

Information collected about you from a particular browser or device may be linked to information collected from another computer or device that our system assumes relates to you. So for example you might use your smartphone to chat with a mentor one week, but use your laptop the next week. Our website will understand that both devices belong to you, and so combine information.

Your browser or device may include “Do Not Track” functionality. Where required by applicable law, we treat recognized opt-out preference signals, such as the Global Privacy Control (GPC), as a valid request to opt out of the sale or sharing of personal information sent from that browser or device.

2.How We Use Your Information

We use the information we collect from you for the following purposes:

3.How We Secure Your Information

We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Websites and Services. Because we collect personal information from children, we maintain a written information security program, with assigned responsibility, that is designed to protect the confidentiality, security, and integrity of that information. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

4.How We Share Your Information

Outside Vendors:

We engage the following types of vendors to perform functions on our behalf: our background check provider; our vendor confirming verifiable parental consent; professional services consultants; security vendors; email service providers; website hosting services; and IT vendors; payment processors; and providers of the technology that supports the AI Chaperone. We may also share information with academic research partners for research purposes, using de-identified or aggregated data where reasonably practicable. We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We do not disclose a child’s personal information to third parties except as described in this Policy and with verifiable parental consent where required.

Social Media Platforms:

Where you choose to interact with us through social media, your interaction with these programs typically allows the social media company to collect some information about you through cookies they place on your device and other tracking mechanisms. In some cases, the social media company may recognize you through its digital cookies even when you do not interact with their application. Please visit the social media companies’ respective privacy policies to better understand their data collection practices and controls they make available to you.

Change of Ownership; Perpetual Stewardship:

We designed Eldera so that the value created here is held for the people who make it possible, not sold off. The Repository of Human Wisdom is held in a trust intended to keep it protected and dedicated to our mission rather than transferable as an ordinary business asset, and our public benefit corporation structure and golden share are designed to prevent a forced sale or a change in mission. If Eldera is ever part of a merger, acquisition, financing, or sale of assets, any successor will be required to maintain the protections in this Policy. We will notify you of any change to who controls your information and provide choices as required by law.

Law Enforcement, Legal Process, and Emergency Situations:

We also use or disclose your personal information if required to do so by law or on the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or our sites; (b) protect and defend our rights or property, the websites or our users; or (c) act to protect the personal safety of us, users of our websites, or the public.

5.Data Retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, including to provide and safeguard the Services, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. We do not retain a child’s personal information for longer than is reasonably necessary for the purpose for which it was collected, after which we delete it. The purposes for which we collect children’s personal information, the business need for retaining it, and our general timeframes for deletion are as follows:

6.Children’s Information

Before collecting information, as described above, about a child under 13 years old, we will obtain verifiable parental consent. We will not require children to disclose more information than is reasonably necessary to participate in an activity. We obtain verifiable parental consent using methods permitted under the Children’s Online Privacy Protection Act (“COPPA”) and its implementing regulations. We obtain separate verifiable parental consent before disclosing a child’s personal information to any third party where such consent is required, and we do not condition a child’s participation on the disclosure of more information than is reasonably necessary. The categories of children’s personal information we collect, the purposes for which we collect them, and the third parties (if any) to whom we disclose them are described in this Policy, including the “Information We Collect,” “How We Use Your Information,” “How We Share Your Information,” and “Data Retention” sections. Children’s personal information may include biometric identifiers (such as voiceprints or faceprints) contained in session recordings, which we handle as described above.

Parents may review their children’s personal information, direct us to delete that personal information, or refuse to allow any further collection or use of their children’s personal information at any time. Parents also may agree to the collection and use of their children’s personal information, but still not allow disclosure to third parties. If you are a parent seeking to exercise these rights, please contact us at hello@Eldera.ai.

7.Users Outside of the United States

If you use our website or Services outside of the United States, you understand that we collect, process, and store your information in the United States. The laws in the United States regarding personal information may be different from the laws of your jurisdiction. Any such transfers will comply with safeguards as required by relevant law. By using the website or Services, you consent to the collection, international transfer, storage, and processing of your data, where permitted by law.

8.Rights of Individuals Located in the EEA, Switzerland, or the UK

This is a note for anyone interacting with us from outside of the United States. We process “Personal Data,” as the term is defined in the EU General Data Protection Regulation, on the following legal basis:

(1) with your consent;

(2) as necessary to perform our agreement to provide services;

(3) as necessary for our legitimate interests in providing the services where those interests do not override your fundamental rights and freedom related to data privacy.

Information we collect may be transferred to the United States, and stored and processed in the United States, or any other country in which we or our collaborators or subcontractors have facilities, as described above.

Individuals who live in the European Economic Area (“EEA”), Switzerland, or the United Kingdom have the right to lodge a complaint about our data collection and processing activities with the supervisory authority concerned.

If you are a resident of the EEA, Switzerland, or the United Kingdom, you are entitled to certain rights. (Please note: in order to verify your identity, you may be required to provide us with information before accessing any records containing information about you). These rights include the ability:

To submit a request to exercise your rights, please contact us at hello@eldera.ai We may have a reason under the law why we are unable to comply with your request, or may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

9.Your California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”), provides you with the rights described below. In the preceding twelve months, we have collected the categories of personal information described in the “Information We Collect” section, which may include identifiers (such as name, email, and phone number), customer records, internet or network activity, general geolocation, audio and visual information (session recordings), and inferences. We may collect “sensitive personal information,” such as government-issued identification and any biometric information used for safeguarding, which we use only for the purposes permitted by law and do not use to infer characteristics. We collect this information from you, your browser or device, and our service providers, and we use and disclose it for the business and commercial purposes described in this Policy.

We do not sell your personal information and do not share it for cross-context behavioral advertising. We do not knowingly sell or share the personal information of consumers under 16 years of age. Subject to certain exceptions, California residents have the right to: know and access the personal information we have collected; delete personal information; correct inaccurate personal information; opt out of any sale or sharing of personal information; limit the use and disclosure of sensitive personal information; and not receive discriminatory treatment for exercising these rights.

To exercise these rights, contact us at hello@Eldera.ai or through any “Do Not Sell or Share My Personal Information” or “Limit the Use of My Sensitive Personal Information” link we make available. We will verify your request and may ask for information to confirm your identity. You may use an authorized agent to submit a request on your behalf, subject to verification. We will not discriminate against you for exercising your rights.

10.Other U.S. State Privacy Rights

If you are a resident of a U.S. state with a comprehensive consumer privacy law (such as Virginia, Colorado, Connecticut, Texas, Oregon, and other states), you may have rights to confirm whether we process your personal data; to access, correct, or delete it; to obtain a portable copy; and to opt out of the sale of personal data, targeted advertising, and certain profiling. We obtain consent before processing sensitive data where required, and we honor recognized universal opt-out preference signals where required by law. To exercise these rights, contact us at hello@Eldera.ai. You may appeal a decision regarding your request by replying to our response; if we deny your appeal, you may contact your state attorney general.

11.Contact Us

If you have questions or concerns related to this policy, please email us at hello@Eldera.ai. To submit a privacy-rights request, you may also email hello@Eldera.ai with the nature of your request. We will respond within the timeframes required by applicable law, and we may need to verify your identity before fulfilling your request.

12.Note about cookies, web beacons & other tracking technologies

“Tracking technologies”, is an umbrella term that can be applied to any activity that websites or mobile apps use to collect, store and share information about your activity on the internet. Let’s take a look at two specific examples: cookies & web beacons.

Cookies are like super intelligent name tags. They start off remembering your name and then go on to remember lots and lots of things about you, like what websites you visit and what you do on each website. When you visit a website, it sends a cookie to your computer which downloads and stores it on your hard drive. The next time you visit that website, your computer checks to see if it has a cookie from there and sends the information contained in that cookie back to the website. The website then ’knows’ that you have been there before and often knows what you did on that visit.

Cookies are used for a variety of things. They help Eldera improve your experience on our website and in our Services. An example of this is with our “Member Login.” Once you’ve signed into Eldera once on your computer or other device, the system will remember you on that same device in the future. This means you don’t have to provide a password every time you visit the Eldera member section. Cookies are frequently used for advertising. Companies who include advertising on their site use cookies to make advertisements more relevant to you.

Cookies are not the only way to recognize visitors on a website. Other, similar technologies may be used from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). Web beacons are tiny graphics files that contain a unique identifier that enables us to recognize when someone has visited our website or opened an e-mail that we have sent them.

Web beacons allows us, for example, to see how people move around our website from one page to another, or to understand how you arrived at our website, e.g. whether through an email message or an Instagram post. They help us to do things like improve our website navigation or to measure the success of e-mail marketing campaigns.

Often web beacons and other tracking technologies are reliant on cookies to function properly, and so declining cookies will reduce their effectiveness.

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