Elevate Healthcare’s Privacy Statement

(“Privacy Statement”)

Last Updated on May 15, 2024

Elevate Healthcare, Inc. (formerly CAE Healthcare, Inc.) and its affiliates (collectively “Elevate”, “we” or “our”) take privacy seriously. We are committed to conducting business and providing services in a way that complies with applicable privacy and data protection laws and regulations in every country in which Elevate operates. This Privacy Statement describes how we process personal information and personal data (collectively “Personal Information”) in the context of our operations. It also provides information about your rights and how you can contact us if you have questions about how we handle your Personal Information.

1. Scope of application of this Privacy Statement

This Privacy Statement applies when Elevate processes Personal Information in the context of its operations as a data controller (or the equivalent terminology under applicable law). As such, Personal Information may be processed in the following circumstances, namely:

a. When you interact with us as customer, supplier, contractor or business partner;

b. When you apply for a job at Elevate;

c. When you visit the sites managed by us or under our control, including websites, portals, software applications, social media sites and learning management systems (“Elevate Sites”)

d. When you attend an Elevate event or webcast or when you communicate with us, whether by telephone, electronically or otherwise.

Please do not provide us with any Personal Information if you do not agree with this Privacy Statement.

Elevate’s Sites may contain links to the sites of third parties or parts of their sites. However, Elevate has no control over the content or operation of these sites, nor does it control the confidentiality or privacy practices of the site operators. Consequently, any personal information you submit through such sites is governed by the privacy policies of the sites in question. It is therefore your responsibility to find out about their policies in order to protect information that concerns you.

2. What Personal Information we collect

Elevate may collect the following Personal Information depending on the nature of our interactions:

  • Basic contact information such as name, mailing and email addresses and telephone numbers;
  • Compliance-related information such as nationality, residency, date/place of birth, passport details and/or driver’s license details or alternatively details from similar identification documents;
  • Information related to the delivery of our services and solutions such as information provided to us by or on behalf of our clients or generated by us in the course of providing our training services and operational support solutions;
  • Recruitment-related information such as education, academic results, experience, curriculum vitae, references, and skill checks, where applicable;
  • Financial information such as payment related information, bank account details or credit card information;
  • Photos, video and audio information including video recording through video surveillance systems when accessing Elevate Sites and certain controlled areas and video and audio recording through training debriefing systems;
  • Login user credentials such as usernames, passwords, and password hints;
  • Website usage and other technical information such as computer internet protocol (IP) address, unique device identifier and other information linked to a device, information about usage of our sites collected through cookies or other tracking technologies;
  • Other personal information you provide to us such as when you submit feedback, make inquiries, contact us for support or complete surveys.

In some circumstances and as permitted by law, we also collect Personal Information that may be considered “sensitive” under applicable laws, such as medical certificates and, if applicable, other health or biometric data (for example, usage of facial recognition technology for identity checks in Elevate Sites).

We collect your Personal Information from you, from your employer, from our customers, from third parties or through cookies and other tracking technologies (please refer to our Cookie Policy as referenced on our home page). We do not knowingly collect Personal Information from anyone under the age of 16.

3. Why we collect your Personal Information and our lawful basis for processing it

We process your Personal Information only where we are satisfied that we have a business purpose and a lawful basis for doing so. Depending on the jurisdictions in which we operate, the legal bases justifying our processing of your Personal Information may include:

  • Legal obligation: where using your Personal Information is necessary to comply with applicable laws and regulations.
  • Contract performance: where using your Personal Information is necessary to establish and perform a contract with you.
  • Legitimate interests: where using your Personal Information is necessary to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
  • Consent: where you have given consent, as required by law, to process your Personal Information.

Type of personal informationBusiness purpose for processingLawful bases
Basic contact informationWe collect this information to verify your identity and communicate with you in the context of our services, for example, when you create a customer account or when we enter into an agreement with you or with your employer.
  • Legal obligation
  • Contract performance
  • Legitimate interest
  • Consent
Compliance-related informationWe collect this information to verify your identity in compliance with our statutory and regulatory obligations, such as licensing, security, export control and other requirements, as required.
  • Legal obligation
  • Consent
Information related to the delivery of our services and solutionsWe collect this information to perform our services under our contract with you or your employer.
  • Legal obligation
  • Contract performance
  • Legitimate interest
  • Consent
Recruitment-related informationWe collect this information to enable us to process applications for employment submitted via our website and to assess your suitability for any position.
  • Contract performance
  • Consent
Financial informationWe collect this information to process payment transactions in connection with the purchase of our products and services.
  • Legal obligation
  • Contract performance
  • Legitimate interest
  • Consent
Photos, video and audio informationWe collect this information to keep Elevate Sites safe and for the support of debriefing of training sessions (video & audio).
  • Legal obligation
  • Legitimate interest
  • Consent
Login user credentialsWe collect this information to give you a secure access to our Elevate Sites, including websites, portals, applications and systems.
  • Contract performance
  • Consent
Website usage and other technical informationWe collect this information to ensure network and information security, monitor the performance of our websites, applications and systems or improve your user experience.
  • Contract performance
  • Legitimate interest
  • Consent
Other Personal InformationWe collect this information to respond to any inquiry or complaint made by you or your employer
  • Legal obligation
  • Contract performance
  • Legitimate interest
  • Consent

4. How we transfer and share your Personal Information

Because we are a global business, we may process your Personal Information within the Elevate group of companies (including our controlled subsidiaries and joint ventures) which are located in different geographic locations.

We may also share your Personal Information with various categories of third parties, for example:

  • the regulators that govern certain of our activities, such as the competent authorities in civil aviation;
  • our professional advisors, including our legal counsel and auditors;
  • financial institutions that process payment transactions, such as Bank of America;
  • our service providers (e.g., Salesforce, Microsoft, Oracle, SAP, Workday, payment service providers and others) that help us run our business, including for the management of our technology assets and cloud services.

We may disclose your Personal Information to other third parties to comply with legal or regulatory requirements (e.g., audits, inspections or investigations by competent authorities), fulfil our contractual obligations, enforce our corporate policies, respond to claims, or protect anyone's vital interests. We may also disclose your Personal Information to a third party in connection with a sale or transfer of business or assets, a merger or consolidation, re-organization or financing of parts of our business. In the event the transaction is completed, your Personal Information will remain protected by applicable data protection laws. However, in the event the transaction is not completed, Elevate will require the other party not to use or disclose your Personal Information in any manner whatsoever and to delete it. Such disclosures will be in accordance with applicable laws.

We only transfer Personal Information to third parties in a jurisdiction recognized as providing an adequate data protection level or that have signed a contract with Elevate for processing personal information in compliance with applicable laws.

Except as otherwise mentioned herein, Elevate will not transfer, sell or disclose your Personal Information to any third party without your consent.

5. How we protect and secure your Personal Information

Elevate is committed to ensure, that your Personal Information is processed securely and accessible only by authorized persons. We have internal policies and controls in place to prevent your Personal Information from being lost, accidentally destroyed, misused, unintentionally disclosed, or accessed other than by our employees or third parties hired by Elevate. We also provide mandatory training to Elevate employees to raise awareness on our policies and procedures designed to manage information security threats. Elevate has in place a cybersecurity incident response plan.

Nonetheless, some third parties may try to access our systems or intercept transmissions or communications unlawfully. Elevate continuously uses reasonable measures in line with recognized security standards to protect your Personal Information, but we cannot absolutely guarantee that unlawful actions will not occur.

6. How we protect and secure your Personal Information

The longer that Personal Information is retained, the higher the likelihood is of accidental disclosure, loss, theft and/or information growing stale (rendering it inaccurate). At Elevate, your Personal Information is retained for no longer than necessary to support the business purpose for which it was collected or to comply with applicable laws. Afterwards all Personal Information will be deleted or anonymized as applicable. Elevate periodically reviews the need for certain Personal Information processed.

7. Your data protection rights

Under certain circumstances and in accordance with applicable laws, you may have the right to require us to:

  • provide you with further details on the use we make of your information;
  • provide you with a copy of information that we hold about you;
  • update any inaccuracies in the Personal Information we hold;
  • delete any Personal Information that we no longer have a lawful ground to use;
  • where processing is based on consent, to withdraw your consent so that we stop that particular processing;
  • object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
  • restrict how we use your information whilst a complaint is being investigated.

If you believe that the processing of your Personal Information is not compliant with applicable laws or if Elevate does not respond to your requests in a timely or adequate manner and in compliance with applicable laws, you have the right to lodge a complaint with the data protection authority or court. We ask that you attempt to resolve any issues with us before lodging a complaint with any data protection authority. Please refer to “How to contact Elevate” for more details.

8. What the resident of California should know

California residents may annually request and obtain information that is shared with other businesses for their own direct marketing use within the prior calendar year. Elevate does not share your Personal Information with other businesses for their own direct marketing use.

California residents have the right to direct a company not to sell their data. As Elevate does not sell your Personal Information, this does not apply.

9. How to contact Elevate

If you have any questions about this Privacy Statement or if you have questions or enquiries about how we handle your Personal Information, please contact us at:

By MailBy PhoneBy Email

Elevate Healthcare, Inc.
Attn: Legal
6300 Edgelake Drive
Sarasota, FL 34240

+ 1 (941) 377-5562[email protected]

When you e-mail us please remember that the content of your e-mail is not secure and could be intercepted. Accordingly, please keep the amount of confidential or Personal Information to a minimum and we will do likewise when we reply.

The laws and regulations governing personal information are frequently changing. Elevate may update and amend this Privacy Statement from time to time.

End of Elevate Healthcare Privacy Policy