Privacy
Policy.

01Who we are

Elevtir ("Elevtir," "we," "us") is Elevtir LLC, a Delaware limited liability company. We provide managed Google Ads, LinkedIn Ads and AI search optimization (AI SEO) for B2B companies, plus market research.

This policy covers personal information we handle through our website at elevtir.com, in our dealings with clients and prospective clients, and when we deliver services to clients. Questions go to calvin@elevtir.com.

02Information we collect

a. From website visitors

Information you submit in our forms. Our website has two forms:

• Market brief request: first name, work email, and any comments you choose to add.
• Consultation request: first name, last name, and work email.

Form submissions are received and stored by Netlify, our website host. They are not sent to any other system.

Technical information. When you visit the site, Netlify automatically processes standard request information, such as your IP address, browser type, the page requested, the referring page, and the time of the request, so it can deliver and secure the site.

Fonts. Our pages load fonts from Google Fonts. Your browser connects to Google's servers to fetch them, which sends Google your IP address and browser information.

What we don't use. Our website does not use analytics tools, advertising pixels (such as the LinkedIn Insight Tag, Google Ads tag, or Meta Pixel), session recording, or chat widgets, and it does not set cookies. See Section 5.

b. From clients and prospective clients

When you contact us, become a client, or work with us on behalf of a client, we collect business contact details (such as name, job title, company, work email, and phone number), the content of our emails, calls, and meetings, and the information needed to manage the engagement, such as contract and billing contacts.

c. Client advertising data

When a client grants us access, we access the client's Google Ads and LinkedIn Ads accounts, including through the official Google Ads API and LinkedIn Marketing APIs, to report on and manage the client's campaigns. This can include campaign settings, creative, budgets, and performance metrics, plus aggregated audience and demographic reporting that the platforms provide. Exactly what Google user data we access through the Google Ads API, and how we use, share, protect, retain and delete it, is described in Section 3.

• We act on the client's behalf, as their service provider (or "processor"). The client remains in control of its accounts and data.
• We use this data only to deliver our services to that client. We do not sell it, and we do not use one client's data for another client.
• Where we connect through APIs for reporting, we use read-only access.
• Our use of data from LinkedIn's APIs follows LinkedIn's API Terms of Use. Our use of information received from Google APIs is covered in Section 3.
• Clients can revoke our access at any time from the access settings in their Google Ads or LinkedIn Campaign Manager account.

d. Past email outreach campaigns

We no longer offer email outreach as a service. In the past, we ran B2B email outreach for some clients, on their behalf and at their direction, using business contact details about prospects (such as name, job title, company and work email address) obtained from the client and from B2B data providers such as Apollo, and sent through Smartlead. We keep any remaining prospect data from those campaigns only for the period described in Section 7. If you received an outreach email from us and want us to delete your details, contact us at calvin@elevtir.com.

03Google user data and the Elevtir Google Ads tool

a. What the app is

"Elevtir" is an internal reporting and keyword-research tool used only by Elevtir staff to manage and report on Google Ads accounts that our clients have linked to Elevtir's Google Ads manager account. It is not offered to the public, and no one signs in to it with a Google account. It connects to the Google Ads API using a Google Cloud service account that has read-only access to our manager account.

b. Google user data we access

Through the Google Ads API (scope https://www.googleapis.com/auth/adwords, used read-only), we access:

• Account details for client accounts linked to our manager account: account ID, name, currency, time zone and status.
• Advertising performance and configuration data: campaigns, ad groups, keywords, search terms, conversion actions and their settings, budgets, device and daily performance, and the account change history (which can include the email address of the user who made a change).
• Keyword planning data from Google Keyword Planner (keyword ideas, search volumes, competition and bid estimates) for research we run on a client's or prospect's behalf.

We do not access Gmail, Google Drive, Calendar, Contacts or any other Google service through this tool, and we never access end consumers' personal data.

c. How we use it

We use this data only to provide the services a client has engaged us for: performance reporting, account audits, identifying wasted spend, budget pacing, and keyword research and campaign planning. Each client's data is used only for that client's account.

d. Who we share it with

• The client who owns the Google Ads account, in the form of reports and recommendations.
• Elevtir staff and contractors working on that client's account, who are bound by confidentiality obligations.
• Anthropic (Claude), the AI assistant we use to analyze the data on request. It processes the data only to produce the analysis we ask for.
• Authorities, if required by law.

We do not sell Google user data. We do not use or transfer it for advertising, including targeted, personalized, retargeted or interest-based advertising. We do not transfer it to data brokers or information resellers, and we do not use it to determine creditworthiness or for lending purposes.

e. AI and machine learning

We do not use Google user data obtained through Google APIs to develop, improve or train generalized or non-personalized AI or machine-learning models.

f. Limited Use

Elevtir's use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

g. How we protect it

• Read-only access enforced by Google: the service account cannot create, change or delete anything in any Google Ads account.
• Key storage: the service-account private key is stored only in the operating system's encrypted keychain, never in source code, files or logs.
• Encryption in transit: data is encrypted in transit using HTTPS/TLS.
• Limited access: access is limited to the client accounts linked to our manager account and to authorized staff.

h. Retention and deletion

• Google Ads data is retrieved on demand for each request and is not stored in a database.
• Reports and analyses we deliver to a client are kept for the duration of the engagement and deleted within 6 months after it ends, unless the client asks us to delete them sooner or the law requires us to keep them longer.
• Our tool keeps a technical log of each request (time, tool used, account ID, date range, success or failure, and number of rows returned). The log contains no advertising data and is deleted after 6 months.
• Clients can remove our access at any time by unlinking their account from our manager account in Google Ads, and can request deletion of data we hold by emailing calvin@elevtir.com. We complete deletion requests within 30 days.

04How we use information

• To respond to your requests, such as preparing and delivering a market brief or scheduling a consultation. We do not add form submissions to automated email sequences.
• To deliver our services to clients: market and keyword research, campaign management, AI search optimization, and reporting. Google user data is used only as described in Section 3.
• To communicate with clients and prospects about our engagement.
• To operate, secure, and troubleshoot our website.
• To meet legal, tax, and accounting obligations, and to protect our rights.

We do not use client advertising data or outreach prospect data for our own marketing.

05Cookies and tracking technologies

Our website does not set cookies or use local storage, analytics, or advertising pixels. The only third parties involved when you load our pages are:

If we add any analytics or advertising technology in the future, we will update this policy first and, where the law requires it, ask for your consent before it runs.

06How we share information

We do not sell personal information, and we do not share it for cross-context behavioral advertising. We disclose personal information only:

• To service providers that operate on our behalf: Netlify (website hosting and forms), Google (web fonts), and Anthropic (the Claude AI assistant we use to analyze client data on request, as described in Section 3). For our past email outreach campaigns, we also used Smartlead (outreach sending) and Apollo and other B2B data vendors (prospect data).
• To advertising platforms (Google and LinkedIn), when we manage a client's campaigns in that client's own accounts on the client's behalf.
• To our clients, who receive the reporting and recommendations we produce for them.
• For legal reasons, when required by law, legal process, or to protect our rights, our clients, or others.
• In a business transfer, such as a merger or acquisition, subject to this policy.

Google user data obtained through the Google Ads API is shared only as described in Section 3.

07Data retention

We keep personal information for 6 months, as follows:

• Website form submissions: 6 months from receipt, unless you become a client.
• Client and engagement data, including reports and data we retrieve from client ad accounts: kept for the duration of the engagement and deleted within 6 months after it ends, or sooner if the client asks. Data inside a client's own Google Ads and LinkedIn accounts stays under the client's control.
• Google Ads API data and request logs: Google Ads data is retrieved on demand and not stored in a database; our tool's technical request logs are deleted after 6 months. See Section 3.
• Outreach prospect data from past campaigns: 6 months after the campaign ended, or sooner if the client instructs us.

We may keep information longer only where the law requires it (for example, tax and accounting records), and we keep a record of opt-out requests so that we can continue to honor them.

08Security

We use reasonable administrative and technical safeguards to protect personal information. Our website is served over HTTPS. Access to client accounts and data is limited to the people who need it to deliver the services, and we use read-only API access for reporting where it is available. The specific safeguards for Google user data accessed through our Google Ads tool are described in Section 3. We rely on established service providers that maintain their own security programs. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

09Your rights

Everyone

Wherever you live, you can ask us what personal information we hold about you, ask us to correct or delete it, or ask us to stop contacting you. Email calvin@elevtir.com. We may need to verify your identity before acting on a request.

If we process your information on behalf of a client (for example, in client ad accounts or past outreach campaigns), that client is responsible for your request. We will pass your request to the client and help them respond.

Clients can remove our access to their Google Ads account at any time by unlinking it from our manager account, and can ask us to delete Google Ads data we hold by emailing calvin@elevtir.com. We complete those deletion requests within 30 days.

California residents (CCPA/CPRA)

To the extent the California Consumer Privacy Act applies, California residents have the right to:

• Know the categories and specific pieces of personal information we collect, the sources, our purposes, and who we disclose it to.
• Request deletion of personal information.
• Request correction of inaccurate personal information.
• Opt out of the sale or sharing of personal information. We do not sell or share personal information, and we have not done so in the past 12 months.
• Not be discriminated against for exercising these rights.

In the past 12 months we have collected these categories: identifiers (such as name, email address, and IP address); professional or employment-related information (such as job title and company); and internet activity information (website request data processed by our host). Sources are described in Section 2, purposes in Sections 3 and 4, and recipients in Section 6. We do not collect sensitive personal information for the purpose of inferring characteristics about you.

To make a request, email calvin@elevtir.com. You may use an authorized agent; we may ask for proof of the agent's authority and verify your identity. We respond within 45 days.

EEA and UK residents (GDPR and UK GDPR)

For website visitors and for our own client and prospect relationships, Elevtir LLC is the controller. For client advertising data and outreach prospect data, our client is the controller and we are its processor.

Where we are the controller, our legal bases are:

• Contract: to take steps you request before entering an agreement and to perform our agreements with clients.
• Legitimate interests: to respond to business inquiries, deliver the market briefs you request, manage client relationships, and secure our website. We balance these interests against your rights.
• Legal obligation: to meet tax, accounting, and other legal requirements.

You have the right to access, correct, or delete your personal information; to restrict or object to our processing; to data portability; and, where we rely on consent, to withdraw it at any time. To exercise these rights, email calvin@elevtir.com. We respond within one month.

You can also complain to your local data protection authority. In the UK, that is the Information Commissioner's Office (ico.org.uk).

10International transfers

Elevtir is based in the United States, and we and our service providers process personal information in the United States and other countries where those providers operate. These countries may have data protection laws different from those where you live. When we transfer personal information from the EEA or the UK, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or a provider's certification under the EU-U.S. Data Privacy Framework and its UK Extension.

11Children's privacy

Our website and services are intended for businesses and are not directed to children under 16. We do not knowingly collect personal information from children under 16. If you believe a child has provided us with personal information, contact us and we will delete it.

12Changes to this policy

We may update this policy as our practices change. When we do, we will post the new version on this page and update the "Last updated" date at the top. If we make material changes, we will make that clear on this page before they take effect.

13Contact us

For privacy questions or requests, contact: