Privacy Policy
Elm Park Labs (“we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains the types of personal data we collect when you use our website (elmparklabs.com), applications (referred to as Products), the LINK portal (elmparklink.com), and related services (collectively referred to as the “System”), how that data is used, and your rights regarding your personal information. For users located in the European Economic Area (EEA), this Privacy Policy complies with the General Data Protection Regulation (GDPR). For U.S. residents, this Privacy Policy also addresses applicable state privacy laws, including the California Consumer Privacy Act (CCPA/CPRA).
Last updated: September 16, 2025
1. Principles
Elm Park Labs processes personal data lawfully, fairly, and transparently. The data we collect is used for legitimate purposes and is relevant and limited to what is necessary. We ensure that personal data is retained only for as long as required and secured through appropriate safeguards. While we take commercially reasonable measures to protect your information from unauthorized access, disclosure, or modification, no method of electronic transmission or storage is completely secure.
2. Purpose of Data Collection
The primary purpose of collecting personal data is to provide and improve the System. Elm Park Labs acts as the data controller for personal data provided by users or collected during interactions with the System. This includes enabling access, delivering tailored user experiences, and offering training tools and analytics, ensuring system security, and complying with legal obligations.
3. Types of Personal Data
We collect the following categories of personal data when you use our website, portal, and products:
• Information you provide directly:
• Name, email address, phone number, physical address
• Profession, organization, and role
• Account credentials (username, password, or login details)
• Automatically collected information:
• Log data such as IP address, browser type and version, pages visited, time spent, and referral source
• Device data including device type, operating system, unique device identifiers, device settings, and approximate location
• Usage data such as interactions with training modules, completion records, or performance metrics (if applicable to your account)
• Cookies and tracking technologies:
• Used to remember preferences, improve functionality, analyze performance, and personalize user experiences
• You may manage or disable cookies through your browser settings, but some features of the System may not function properly if cookies are disabled
4. Legal Basis for Processing
Elm Park Labs processes personal data on the following legal grounds:
• Contractual necessity: To provide access to the System, deliver requested services, and perform obligations under our agreements with you.
• Consent: For specific purposes such as sending marketing communications. You may withdraw your consent at any time by contacting us at contact@elmparklabs.com. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
• Legitimate interests: To improve functionality, maintain security, analyze usage, and enhance user experience, provided that your rights and freedoms do not override these interests.
• Legal obligations: To comply with applicable laws, regulations, and lawful requests from public authorities.
• Research and development: To conduct internal testing, analytics, and product improvement, using anonymized or aggregated data where possible.
5. How We Use Your Personal Data
We use personal data to operate, improve, and personalize our System and services. Specifically, we may use your information to:
• Provide and maintain services: Enable access to the System, manage accounts, and ensure functionality.
• Deliver training tools and analytics: Support learning experiences, performance assessments, and reporting.
• Communicate with you: Send service updates, technical notices, and (with consent where required) promotional content.
• Conduct research and development: Improve functionality, test new features, and evaluate training effectiveness.
• Generate anonymized insights: Create aggregated data sets that cannot identify you, for research, product development, and business intelligence.
If assessments or analytics involve automated scoring, they are used only to support training objectives and system improvement. They are not used for automated decision-making with legal or similarly significant effects.
6. Sharing Your Personal Data
We may share personal data only as necessary to provide our services, comply with legal obligations, or support business operations. Specifically, your data may be shared with:
• Employers or sponsoring organizations: To track training progress, deliver assessments, and provide reporting where your use of the System is part of an organizational program.
• Service providers: Third-party vendors such as cloud hosting providers, IT infrastructure and support services, analytics platforms, and marketing providers. These providers process data only under contractual safeguards and are prohibited from using it for their own purposes.
• Regulatory and legal authorities: To comply with applicable laws, regulations, or lawful requests from public authorities.
• Business successors: In the event of mergers, acquisitions, restructuring, or similar transactions, where personal data may be transferred as part of business assets.
For users in the European Economic Area (EEA): Personal data may be transferred outside the EEA. In such cases, Elm Park Labs implements safeguards such as Standard Contractual Clauses or other legally approved mechanisms to protect your rights.
If you are outside the EEA, you acknowledge that third parties in your jurisdiction may not be subject to equivalent data protection laws, and your rights may differ accordingly.
Elm Park Labs does not sell your personal information.
7. Your Rights
By providing personal information to us, you acknowledge and agree that we may collect, hold, use, and disclose your personal information in accordance with this Privacy Policy and applicable laws. You do not have to provide personal information to us; however, if you choose not to, it may affect your ability to use the website, products, or services offered through it.
If we receive personal information about you from a third party, we will handle it as set out in this Privacy Policy. If you provide personal information about another individual, you confirm that you have the necessary authority or consent to do so.
Under GDPR (EEA Residents)
You have the right to:
• Access: Request information about the personal data we hold about you and obtain a copy.
• Correction: Request corrections to inaccurate or incomplete data.
• Deletion/Erasure: Request deletion of your personal data, subject to legal obligations.
• Restriction: Request that we restrict processing of your data under certain circumstances.
• Portability: Request a copy of your data in a machine-readable format and transfer it to another controller.
• Objection: Object to processing of your data for direct marketing or other purposes.
• Withdraw Consent: Withdraw consent for data processing, where applicable.
• File Complaints: Lodge a complaint with your local Data Protection Authority if you believe your rights have been violated.
Under U.S. State Privacy Laws (including CCPA/CPRA)
Residents of California and certain other U.S. states may have the right to:
• Access: Request to know what personal information we collect, use, and disclose.
• Correction: Request correction of inaccurate information.
• Deletion: Request deletion of your personal information, subject to legal obligations.
• Opt-Out: Opt-out of the sale or sharing of personal information (note: we do not sell personal data).
• Limit Use of Sensitive Information: Request limitations on the use of sensitive personal information, if collected.
• Non-Discrimination: Not be discriminated against for exercising your privacy rights.
You or your authorized agent may exercise these rights by contacting us at:
8. Children’s Privacy and Student Users
Our System is not directed to children under 13 in the United States or under 16 in the European Economic Area. We do not knowingly collect personal data from children.
If you are under the applicable age threshold, you may only use the System with the consent and supervision of your parent or legal guardian. By allowing a minor to use the System, the parent or guardian consents to the collection and use of the minor’s personal information in accordance with this Privacy Policy.
Student and Educational Users:
Our products may be made available through schools, universities, or training institutions. In these cases, your use of the System may be managed by your educational institution or sponsoring organization. They may provide us with limited personal information (such as your name, student ID, or contact details) to set up accounts, track training progress, or deliver assessments. We process this data only as necessary to provide the services requested by the institution and in accordance with applicable privacy laws.
If we learn that we have collected personal data from a child without verified parental or institutional consent, we will promptly delete it. Parents, guardians, or educational administrators who believe a student’s data has been provided to us improperly should contact us at contact@elmparklabs.com
9. Data Retention
Elm Park Labs retains personal data only for as long as necessary to fulfill the purposes outlined in this policy or to meet legal obligations. Retention periods may vary depending on the type and use of the data. Data no longer needed is securely deleted or anonymized.
10. Data Security
We employ technical and organizational measures to protect personal data against unauthorized access, loss, or misuse. While no system is entirely secure, Elm Park Labs strives to safeguard your information. Users are encouraged to use strong passwords and keep account credentials confidential.
11. Cookies
Cookies are used to enhance user experiences, track preferences, and analyze System performance. For web-based services, Users can manage or disable cookies through browser settings. Disabling cookies may limit certain features of the web-based services.
12. Business Transfers
In cases of mergers, acquisitions, or similar business transactions, personal data may be included in the transferred assets. Any new entity acquiring Elm Park Labs will continue to use personal data in accordance with this Privacy Policy.
13. External Links
Our System may include links to external websites. Elm Park Labs is not responsible for the content, policies, or practices of these external sites. We encourage users to review the privacy policies of third-party websites they visit.
14. Changes to This Privacy Policy
This Privacy Policy may be updated to reflect changes in practices or compliance requirements. Significant updates will be communicated through email or notifications within the System. Continued use of the System after updates constitutes acceptance of the revised policy.
Contact Us
If you have questions or concerns about this Privacy Policy or how your data is handled, please contact us:
Elm Park Labs, Inc.
contact@elmparklabs.com