Privacy Policy

1. Introduction

Elbowsmove ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website elbowsmove.world and use our services.

This policy complies with applicable United States federal and state privacy laws, including the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), and the Connecticut Data Privacy Act (CTDPA), as well as the General Data Protection Regulation (GDPR) for visitors from the European Economic Area. By using our website, you consent to the data practices described in this policy.

2. Data Controller Information

The data controller responsible for your personal data is:

Elbowsmove
232 Norwood Ave, Providence, RI 02905, United States
Phone: +1 401 781 0099
Email: contactuse@elbowsmove.world

3. Information We Collect

We may collect the following types of personal information:

Contact Information: Name, email address, phone number, and mailing address when you contact us or sign up for our services.
Communication Data: Messages, inquiries, and feedback you send to us through our contact forms or email.
Technical Data: IP address, browser type, operating system, referring URLs, and information about how you interact with our website.
Cookie Data: Information collected through cookies and similar tracking technologies as described in our Cookie Policy.

4. Legal Basis for Processing

We process your personal data based on the following legal grounds:

Consent: When you have given explicit consent for specific purposes.
Contract Performance: When processing is necessary to fulfill our contractual obligations to you.
Legitimate Interests: When processing is necessary for our legitimate business interests, provided these do not override your rights.
Legal Obligation: When we are required to process data to comply with legal requirements.

5. How We Use Your Information

We use your personal information for the following purposes:

To respond to your inquiries and provide customer support
To deliver our consultation services and programs
To send administrative information and service updates
To improve our website and services
To analyze website usage and optimize user experience
To comply with legal obligations

6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including:

Contact form submissions: 3 years from the date of submission
Client records: 7 years after the end of the business relationship
Analytics data: 26 months
Cookie consent records: 12 months

After these periods, your data will be securely deleted or anonymized.

7. Data Sharing and Disclosure

We do not sell your personal information. We may share your data with:

Service Providers: Third-party vendors who assist us in operating our website and providing services (e.g., hosting providers, analytics services)
Legal Requirements: When required by law, court order, or governmental authority
Business Transfers: In connection with a merger, acquisition, or sale of assets

All third-party service providers are contractually obligated to protect your data and use it only for specified purposes.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. When we transfer data outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

9. Your Rights

Under GDPR and applicable data protection laws, you have the following rights:

Right of Access: Request a copy of your personal data
Right to Rectification: Request correction of inaccurate data
Right to Erasure: Request deletion of your personal data
Right to Restrict Processing: Request limitation of data processing
Right to Data Portability: Receive your data in a structured, machine-readable format
Right to Object: Object to processing based on legitimate interests
Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent

To exercise these rights, please contact us using the information provided below.

10. US State Privacy Rights

If you are a resident of California, Virginia, Colorado, Connecticut, or another US state with comprehensive privacy legislation, you have the following rights regarding your personal information:

Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you
Right to Delete: Request deletion of your personal information, subject to certain exceptions
Right to Correct: Request correction of inaccurate personal information
Right to Opt Out of Sale or Sharing: Direct us not to sell or share your personal information with third parties for cross-context behavioral advertising
Right to Limit Use of Sensitive Personal Information: Restrict the use and disclosure of sensitive personal information to purposes necessary to provide our services
Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights
Right to Data Portability: Obtain a copy of your personal information in a portable and readily usable format
Right to Appeal: If we deny your request, you have the right to appeal our decision within a reasonable timeframe

To exercise these rights, please contact us using the information provided below. We will verify your identity before processing your request and will respond within the timeframes required by applicable law.

11. Categories of Personal Information Collected (California Residents)

In the preceding 12 months, we may have collected the following categories of personal information from consumers, depending on your interactions with our website:

Identifiers: Name, email address, phone number, IP address
Commercial Information: Records of services purchased or considered
Internet Activity: Browsing history, search history, and information regarding your interaction with our website
Geolocation Data: General geographic location derived from your IP address
Professional or Employment Information: Job title or employer if provided

We collect this information directly from you, automatically through cookies and analytics tools, and from third-party service providers. We do not sell personal information as defined by the CCPA. We may share personal information with service providers for business purposes as described in this policy.

12. Do Not Sell or Share My Personal Information

Elbowsmove does not sell personal information to third parties for monetary consideration. We do not engage in cross-context behavioral advertising that would constitute "sharing" under the CPRA.

If our practices change in the future, we will update this Privacy Policy and provide a clear mechanism to opt out of the sale or sharing of your personal information, including a "Do Not Sell or Share My Personal Information" link on our homepage as required by law.

13. Do Not Track

Some browsers have a "Do Not Track" feature that signals to websites you visit that you do not want to have your online activity tracked. Our website does not currently respond to "Do Not Track" signals because there is no uniform industry standard for how to interpret them. However, you can opt out of certain tracking by adjusting your cookie preferences through our cookie banner or by managing your browser settings.

14. Shine the Light (California Civil Code Section 1798.83)

California residents who have an established business relationship with us may request information about our disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please contact us using the information below. This request may be made no more than once per calendar year.

15. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

SSL/TLS encryption for data transmission
Secure server infrastructure
Access controls and authentication
Regular security assessments

16. Children's Privacy (COPPA Compliance)

Our services are not directed to individuals under the age of 16. We do not knowingly collect personal information from children under 13 in compliance with the Children's Online Privacy Protection Act (COPPA). If you are a parent or guardian and believe that your child under 13 has provided us with personal information, please contact us immediately. If we become aware that we have collected personal information from a child under 13 without verification of parental consent, we will take steps to delete that information.

For California residents, we do not knowingly collect, sell, or share the personal information of consumers under 16 years of age.

17. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date. We encourage you to review this policy periodically.

18. Complaints and Contacting Regulatory Authorities

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the relevant supervisory authority. In the United States, you may contact:

Federal Trade Commission (FTC): www.ftc.gov or by phone at 1-877-FTC-HELP
California Attorney General: For California residents, complaints may be filed at oag.ca.gov
State Attorney General: Residents of other states may contact their respective state Attorney General's office

For EU residents, you may contact your local Data Protection Authority.

19. Authorized Agents

You may designate an authorized agent to make a request on your behalf under applicable US state privacy laws. To do so, you must provide the agent with written permission signed by you, and the agent must verify their identity with us. We may require you to verify your own identity directly with us before processing a request submitted by an authorized agent.