1. Who We Are
This Privacy Notice explains how Elevator21 Inc. and the relevant Elevator21 group entities (“elevator21”, “we”, “us”) process personal data in connection with elevator21.com, website enquiries, demo requests, marketing communications, business relationships and access to elevator21 online platforms.
Elevator21 Inc. is the Delaware parent company and global headquarters. The group operates through wholly owned entities including Elevator21 Luxembourg S.à r.l. and Elevator21 HK Limited. The entity responsible for a particular processing activity may depend on the nature of the interaction, the service involved and the applicable jurisdiction.
| Entity | Jurisdiction / identification | Registered office |
|---|---|---|
| Elevator21 Inc. | Delaware, USA · State File No. 10136305 | 16192 Coastal Highway, Lewes, Delaware 19958, USA |
| Elevator21 Luxembourg S.à r.l. | Luxembourg · RCS B312023 | 9, rue du Laboratoire, L-1911 Luxembourg, Grand-Duchy of Luxembourg |
| Elevator21 HK Limited | Hong Kong · Company Registration No. 79886807 | Lee Garden Two, 28th Floor, 28 Yun Ping Road, Causeway Bay, Hong Kong |
For privacy enquiries, data-subject requests and other matters concerning this Notice, contact website@elevator21.com. If a particular service or engagement has a separate privacy contact, that contact may also be identified in the applicable agreement or notice.
2. Personal Data We Collect
- identification and professional contact data, such as name, job title, employer, email, telephone number, business address, country and professional profile;
- information submitted through demo, contact or other enquiry forms, including the contents of an enquiry and services of interest;
- information necessary to establish and manage relationships with clients, prospects, investors, counterparties, suppliers, professional advisers and introducers or Finders;
- information received from employers, organisations, clients, professional advisers, service providers, introducers or Finders, public sources, regulators and other lawful third parties; and
- technical and online information such as IP address, browser/device information, logs, security information and cookie or similar identifiers, subject to the Cookie Notice.
3. Purposes and Legal Bases
Depending on the applicable jurisdiction, elevator21 processes personal data to respond to enquiries and demo requests; assess and onboard prospective clients; provide services; manage relationships; maintain security; prevent fraud and misuse; comply with legal, regulatory, tax, accounting, AML/KYC and sanctions obligations; communicate about elevator21 services; improve products and Website functionality; and establish, exercise or defend legal claims.
For processing subject to GDPR, elevator21 relies on the legal bases applicable to the processing, including performance of a contract or steps before contract, compliance with a legal obligation, legitimate interests and consent where required. elevator21 does not rely on consent where another lawful basis is more appropriate.
For Hong Kong users, elevator21 also applies the Personal Data (Privacy) Ordinance and its Data Protection Principles. Personal data is collected only by lawful and fair means, for purposes related to elevator21's functions or activities, and should be adequate but not excessive.
For US users, applicable state privacy laws may provide additional rights and requirements. elevator21 will apply those requirements where they apply to the relevant processing.
4. Marketing
elevator21 may send professional marketing communications where permitted by applicable law. Recipients may opt out using the unsubscribe mechanism or by contacting website@elevator21.com.
elevator21 does not sell personal data for money. Where applicable law treats certain targeted advertising, sharing or similar activity as a regulated disclosure, elevator21 will provide the rights and controls required by that law.
5. AI and Automated Processing
elevator21 is an AI-native technology business and may use AI-assisted tools in operating the Website, managing enquiries, improving products, analysing information and delivering contracted services.
Where personal data is processed through AI or machine-learning systems, elevator21 will apply appropriate technical and organisational safeguards and use the information only for lawful purposes.
elevator21 does not make decisions producing legal or similarly significant effects about individuals solely through automated processing unless permitted by applicable law and subject to required safeguards and rights.
Users should not submit sensitive or confidential information through public Website forms unless specifically requested and an appropriate secure channel is provided.
6. Sharing Personal Data
elevator21 may share personal data with service providers acting on its behalf, including hosting, cloud, IT, cybersecurity, communications, CRM, analytics, professional and administrative providers.
elevator21 may share information with clients, counterparties, professional advisers, auditors, insurers, regulators, courts, law-enforcement authorities and governmental bodies where necessary or legally required.
In connection with client engagements, elevator21 may share relevant personal data with fund administrators, AIFMs, depositaries, banks, legal advisers and other professional service providers where necessary and lawful.
elevator21 may also disclose information in connection with a merger, restructuring, financing, acquisition or sale of all or part of the business, subject to applicable confidentiality and data-protection requirements.
7. International Transfers
Because elevator21 operates globally, personal data may be processed in the United States, Luxembourg, Hong Kong and other jurisdictions where elevator21 or its service providers operate.
Where GDPR Chapter V applies, elevator21 will use an applicable lawful transfer mechanism, such as an adequacy decision or appropriate safeguards including Standard Contractual Clauses, together with supplementary measures where required.
For Hong Kong and US users, elevator21 will apply applicable local requirements governing transfers and disclosures of personal data.
8. Retention
elevator21 retains personal data only for as long as reasonably necessary for the purposes for which it was collected, including legal, regulatory, accounting, security and dispute-resolution requirements. Retention periods depend on the nature of the information and applicable legal obligations.
9. Security
elevator21 applies appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, alteration, disclosure and destruction. No internet transmission or storage system can be guaranteed to be completely secure.
10. Your Rights
10.1 European Economic Area / GDPR
Where GDPR applies, individuals may, subject to applicable conditions and limitations, request access, rectification, erasure, restriction of processing and data portability, and may object to processing. Where processing is based on consent, consent may be withdrawn at any time.
Individuals may complain to the Luxembourg Commission nationale pour la protection des données (CNPD) or another competent EU supervisory authority.
10.2 Hong Kong
Under the Personal Data (Privacy) Ordinance, individuals have rights to request access to personal data held about them and correction of inaccurate personal data, subject to the Ordinance. Requests may be addressed to website@elevator21.com. elevator21 may need to verify identity before responding.
10.3 United States
Depending on the individual's state of residence and the applicability of local privacy law, additional rights may include access, correction, deletion, portability, opt-out rights and the right to appeal a decision concerning a privacy request. Requests may be submitted to website@elevator21.com. elevator21 will verify requests as required by applicable law.
11. Hong Kong Personal Information Collection Statement
For individuals whose personal data is collected in Hong Kong, this section is intended to provide the core information normally given at or before collection. The purposes of collection include responding to enquiries and demo requests, establishing and managing business relationships, providing services, security, compliance, administration and other directly related business purposes. Personal data may be transferred to elevator21 group entities and service providers described in this Notice, regulators and authorities where required or permitted by law.
The supply of personal data through a Website form is generally voluntary, but information marked as required may be necessary for elevator21 to respond to the enquiry or provide the requested service. Individuals may request access to or correction of their personal data by contacting website@elevator21.com.
12. Cookies
Cookies and similar technologies are governed by the separate Global Cookie Notice at elevator21.com/cookies.
13. Third-Party Websites
The Website may contain links to third-party websites. elevator21 is not responsible for their privacy practices. Users should review the applicable third-party notices.
14. Changes to this Notice
elevator21 may update this Privacy Notice when its processing activities, group structure, Website or legal requirements change. The current version and effective date will be published on the Website.
15. Contact
Elevator21 Inc., 16192 Coastal Highway, Lewes, Delaware 19958, United States · website@elevator21.com