RECITALS

WHEREAS, Elevate Crew Academy (PTY) LTD (“Company,” “we,” “us,” “our”) operates an online educational platform and provides digital learning resources, mentorship programs, and related services (“Services”);

WHEREAS, the Company collects and processes certain data from Users (“you,” “your”) to enhance website performance, user experience, and advertising relevance;

WHEREAS, the Company acknowledges the importance of protecting Users’ privacy and is committed to ensuring transparency in its data processing activities, including the use of cookies and tracking technologies;

WHEREAS, the Company seeks to ensure compliance with applicable data protection laws, including but not limited to:

• General Data Protection Regulation (GDPR) (EU Regulation 2016/679)
• California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
• Protection of Personal Information Act (POPIA) of South Africa

NOW, THEREFORE, in consideration of the foregoing, the Company and the User agree to be legally bound by this Cookie Policy:

• DEFINITIONS

1. “Cookies” – Small text files or digital identifiers that are transmitted by a website and stored on a User’s device (computer, tablet, smartphone, or other internet-enabled device) when the User
   

visits the Website. These files store session data, authentication tokens, user preferences, browsing history, and tracking information to facilitate website functionality and enhance User experience.

1. “First-Party Cookies” – Cookies that are set directly by the Company and stored on a User’s device while using the Website. These cookies are exclusively controlled by the Company and serve essential purposes, such as security authentication, fraud prevention, content personalization, and preference retention.

1. “Third-Party Cookies” – Cookies placed by external service providers (e.g., Google Analytics, Facebook Pixel, LinkedIn Insight Tag) for various purposes, including advertising, behavioral analytics, audience segmentation, and marketing automation. These cookies allow third-party entities to track User interactions across multiple websites and tailor personalized advertisements based on browsing behavior.

1. “Session Cookies” – Temporary cookies that are stored only for the duration of a User’s session and are automatically deleted once the User closes their browser. These cookies are commonly used for login authentication, shopping cart functionalities, and real-time service adjustments.

1. “Persistent Cookies” – Cookies that remain stored on a User’s device for a predetermined retention period (ranging from several days to multiple years) or until manually deleted by the User. These cookies enable returning Users to have a seamless browsing experience by remembering settings, login credentials, and personalized content preferences.

1. “Tracking Technologies” – Digital tools and identifiers, including but not limited to cookies, web beacons, pixels, fingerprinting technologies, local storage objects, and script-based trackers, that are used for analyzing User behavior, measuring ad conversions, and refining website performance. These technologies allow for granular data collection and enable behavioral advertising, audience retargeting, and real-time content adaptation.
   

• PURPOSE AND LEGAL BASIS FOR COOKIE USAGE

Pursuant to Article 6 of the General Data Protection Regulation (GDPR), Section 1798.140 of the California Consumer Privacy Act (CCPA), and Section 11 of the Protection of Personal Information Act (POPIA), the Company utilizes cookies and tracking technologies for the following legitimate and lawful purposes:

• User Consent and Opt-Out Rights

• Users have the right to accept, decline, or customize cookie preferences upon first visiting the Website.
• Users may withdraw their consent at any time by adjusting their cookie settings via:
  • The Website’s Cookie Management Tool (visible as a banner/pop-up during initial visit).
  • Browser settings (explained in Section 5).
  • Opt-out mechanisms for third-party tracking technologies (explained in Section 4).
• Essential cookies, which are necessary for Website operation, do not require User consent, as they are classified under “Legitimate Interest” under GDPR and “Necessary for Service Performance” under POPIA.
  

• CATEGORIES OF COOKIES USED

The following categories of cookies may be utilized on the Website:

• Essential Cookies

Purpose: Required for critical security mechanisms, fraud prevention, user authentication, and session management.

• Data Processed: User login status, session identifiers, encrypted authentication tokens.
• Retention Period: Session-based (deleted upon browser closure) or persistently stored for up to 1 year.
• User Control: Cannot be disabled, as they are fundamental to the Website’s functionality.

• Functional Cookies

• Purpose: Improve usability, content personalization, and interactive features.
• Data Processed: Language preferences, saved settings, theme customizations, autofill credentials.
• Retention Period: Stored for 3 to 6 months, unless manually deleted by the User.
• User Control: Users may opt out via browser settings or the Website’s Cookie Management Tool.

• Analytics Cookies

• Purpose: Measure page traffic, audience demographics, content engagement, and behavioral trends.
• Data Processed: Page views, navigation flow, click interactions, geolocation (anonymized).
• Retention Period: Typically stored for 6 to 14 months (in compliance with Google Analytics policies).
• User Control: Users may opt out via browser settings or through Google Analytics’ opt- out tool.
  

• Advertising Cookies

• Purpose: Enable interest-based advertisements, audience segmentation, and marketing automation.
• Data Processed: Ad click behavior, product interest tracking, remarketing identifiers.
• Retention Period: Stored for up to 12 months, unless the User withdraws consent earlier.
• User Control: Explicit opt-in required; Users may withdraw consent at any time.

• THIRD-PARTY COOKIES AND DATA SHARING

The Company collaborates with third-party service providers to deliver advanced analytics, advertising solutions, and security enhancements. These providers may set cookies to collect data for the following purposes:

• Website Performance Analytics: Google Analytics, Microsoft Clarity, Hotjar.
• Behavioral Advertising and Remarketing: Facebook Pixel, Google Ads, LinkedIn Insight Tag.
• Security & Authentication Enhancements: reCAPTCHA, Cloudflare.

• Opt-Out Mechanisms for Third-Party Cookies

Users may opt out of third-party tracking by:

• Google Ads Preferences Manager
• Network Advertising Initiative (NAI) Opt-Out
• Facebook Ad Settings

The Company does not sell User data to third parties for monetary compensation.

• COOKIE MANAGEMENT AND USER CONTROL

• Managing Cookie Preferences

Users may adjust, accept, or reject cookie settings through:

• The Website’s Cookie Banner (GDPR-compliant opt-in tool).
• Browser settings (manual cookie deletion and blocking).

• Browser-Specific Cookie Management

To disable cookies, Users may follow these steps:

• Google Chrome: Settings → Privacy & Security → Cookies.
• Mozilla Firefox: Preferences → Privacy & Security → Cookies.
• Safari: Preferences → Privacy → Cookies & Website Data.
• Microsoft Edge: Settings → Cookies & Permissions.

• DATA RETENTION AND STORAGE PERIOD

• Retention Periods for Different Categories of Cookies

The Company retains cookies and related tracking data for the following durations:

• Essential Cookies: Stored until session expiration or up to 12 months, unless required for prolonged security or fraud prevention purposes.
• Functional Cookies: Retained for a maximum duration of 6 months to store User preferences and enhance accessibility.
• Analytics Cookies: Retained for up to 14 months, in compliance with the default Google Analytics data retention policy.
• Advertising Cookies: Stored for a period of up to 12 months, unless the User withdraws consent or exercises their right to opt out prior to that period.

• User-Requested Deletion and Manual Removal of Cookies

Users have the right to request immediate deletion of all stored cookies via:

• Browser settings (manual deletion and blocking) (See Section 5 for instructions).
• Opting out of third-party tracking via industry-standard privacy tools (See Section 4).
  
• Submitting a formal request to the Company’s Data Protection Officer (DPO) for deletion of any persistent cookies associated with their account.

Upon receiving a verified deletion request, the Company shall ensure prompt compliance by:

• Deleting Company-controlled cookies within 30 days of the request.
• Providing guidance to Users on how to manage third-party cookies via external platforms.

• DO NOT TRACK (DNT) REQUESTS

• Recognition and Enforcement of Do Not Track (DNT) Signals

The Company honors Do Not Track (DNT) requests where legally required, in compliance with GDPR, CCPA, and global privacy regulations.

• Users must manually activate DNT settings in their browser to request that their activity is not tracked across third-party websites.
• If a User has enabled DNT, the Company shall:
  • Restrict the use of behavioral tracking cookies on their session.
  • Disable targeted advertising and third-party remarketing features.
  • Ensure compliance with opt-out preferences regarding marketing analytics.

• Third-Party Compliance with DNT Requests

While the Company adheres to DNT requests, third-party service providers (e.g., Google, Facebook, LinkedIn) may have separate policies regarding DNT enforcement.

• Users are encouraged to review the privacy policies of external analytics and advertising partners to determine their compliance with DNT requests.
• The Company provides external opt-out links (e.g., Google Ads, Network Advertising Initiative) for Users who wish to enforce DNT across multiple platforms.
  

• POLICY UPDATES AND NOTIFICATIONS

• Right to Modify and Update the Cookie Policy

The Company reserves the unilateral right to update, modify, or amend this Cookie Policy at any time, to:

• Ensure continued compliance with new data protection laws, regulatory frameworks, and industry best practices.
• Implement technological modifications, upgrades, or enhancements in tracking mechanisms.
• Address changes in business operations, marketing strategies, or external vendor relationships.

• Notification and User Acknowledgment of Policy Updates

Users will be notified of material changes to this Policy via:

• Website pop-ups, banners, or dashboard notifications, informing them of modifications to data tracking practices.
• Email notifications (for registered Users), detailing the scope and implications of any substantive changes.

If a User continues to access or use the Website after receiving a policy update notice, they shall be deemed to have accepted the revised Cookie Policy and its updated terms.

• User Rights Regarding Policy Updates

Users have the right to:

• Request further clarification regarding policy modifications.
• Exercise opt-out rights or withdraw consent if the updates introduce new categories of cookies or tracking technologies.
  
• Submit objections or complaints if they believe the updated Policy infringes on their privacy rights under GDPR, CCPA, or POPIA.

• CONTACT INFORMATION

For inquiries, privacy requests, or legal concerns, Users may contact:

Email: support@elevatecrewacademy

Registered Address:

For privacy-related concerns, data deletion requests, or GDPR/POPIA/CCPA compliance, please contact our Data Protection Officer (DPO):

DPO Email:

Privacy Compliance Address: