Privacy Policy

1. Who We Are

Elevated Environments LLC ("Elevated Environments," "we," "our," or "us") operates an AI-enabled college advising, student development, and growth planning platform. Our platform serves independent college advisors, students, parents, and families by providing tools for student intake and profiling, academic and personal growth planning, behavioral observations for guidance purposes, document drafting, meeting management, and related advisory support. Our platform is designed to help advisors and students navigate college planning, college applications, and future professional and personal development.

Our services are advisory and guidance in nature. We do not provide clinical diagnoses or definitive assessments of any individual. All insights, observations, and recommendations generated by our platform are intended to support, not replace, professional advisor judgment.

Our principal place of business is in Utah. For privacy-related questions, please contact us at:

2. Scope of This Policy

This Privacy Policy explains how we collect, use, store, share, and protect personal information when you access or use the Elevated Environments platform and website (collectively, the "Services"). It applies to:

• College advisors and their staff members ("Advisors") who subscribe to the platform;
• Students (ages 13 and above), parents, and legal guardians whose information is entered into the platform by Advisors, or who use the platform directly as subscribers or authorized users;
• Visitors to our website at www.elevatedenvironments.ai.

Our platform currently serves college advisors as the primary subscribing customers, with students and families as the subjects of the advising relationship. We are building toward a future in which parents and individual students may subscribe directly and authorize advisors to access and use their information within the platform. This Policy is written to address both current and anticipated use cases.

Important Note on Advisor Responsibility: Advisors who use our platform to process the personal information of their clients (students and parents) act as independent data controllers with respect to that data. Elevated Environments acts as a data processor on behalf of Advisors for that purpose. Advisors are responsible for ensuring they have appropriate legal authority to share student and family information with our platform and for complying with applicable privacy laws in their own practice.

3. Information We Collect

3.1 Account Registration and Profile Information

When an Advisor, parent, or individual student creates an account and uses the platform, we collect registration and profile information, which may include:

• Name, email address, phone number, business name (for Advisors), and mailing address;
• Date of birth, gender, high school name and address, graduation year, and other profile details entered at registration or during platform use;
• Professional credentials and certifications (for Advisors);
• Payment and billing information, processed through our payment provider (we do not store full credit card numbers).

The specific fields collected at registration depend on the user's role (Advisor, parent, or student) and may vary as we expand the platform to support direct parent and student subscriptions.

3.2 Student and Family Information

Student, parent, and family information may be entered into the platform by Advisors on behalf of their clients, or directly by students and parents who use the platform. This information may include:

• Academic records: GPA, grade transcripts, class rank, school name and address, graduation year;
• Standardized test scores and score reports (SAT, ACT, AP, IB, and similar);
• Extracurricular activities, achievements, awards, and leadership experience;
• Assessments and surveys: personality assessments, emotional intelligence (EQ) assessments, executive function assessments, interest inventories, psychographic profiles, and other personal assessments and surveys entered or uploaded into the platform;
• College planning information: college list, application preferences, target schools, financial aid considerations, and related planning documents;
• Personal statements, essays, and application materials;
• Advisory records: intake call transcripts, update call transcripts, meeting transcripts and session summaries, meeting notes, action items, and milestone tracking;
• Communications and documents submitted by parents or students in connection with the advising process;
• Any other personal and planning documents relating to the student's college advising, growth, or development process.

3.3 Voice Session Data

Our platform includes an optional voice session feature. This section applies only to Advisors and stakeholders who use the voice session functionality. Not all Advisors use this feature.

When voice sessions are conducted through or in connection with the platform:

• Audio recordings may be created with the prior written consent of all participants (see Section 6 on Recording Consent);
• Transcripts and summaries may be generated from recordings for use in the platform;
• For voice sessions facilitated through the Elevated Environments platform, we provide an automated in-session notification at the start of the session that the session is being recorded;
• For recordings initiated or provided by the Advisor outside of our platform infrastructure (such as uploaded recordings from a third-party tool), the Advisor is responsible for obtaining participant consent and providing appropriate recording notification;
• The stakeholder who is the Elevated customer, whether an Advisor, parent, or individual subscriber, determines how long voice transcripts and summaries are retained beyond any automatic deletion periods (see Section 7).

Advisors are responsible for obtaining and documenting recording consent from all session participants in accordance with applicable state law.

3.4 Platform Interaction and AI Agent Data

When you use our platform or visit our website, we automatically collect or receive:

• Log data: IP address, browser type and version, operating system, pages visited, time and date of access, and referring URL;
• Device information: device type and unique device identifiers;
• Usage data: features used, session duration, and click and navigation patterns;
• AI agent interactions: when users interact with our AI agent or chatbot functionality, questions asked, information provided, requests made, and any data the user enters or submits during the interaction may be captured and may become part of the applicable customer data record;
• Cookies and similar tracking technologies (see Section 10 and our Cookie Policy for details).

3.5 Information from Third-Party Sources

We may receive limited information from:

• Authentication providers (e.g., Google) if you use single sign-on to access the platform;
• Our advisor outreach platform for advisor lead generation and marketing, subject to applicable opt-out rights.

4. How We Use Personal Information

We use personal information for the following purposes:

4.1 Platform Operation

• Creating and managing Advisor, parent, and student accounts;
• Processing student intake information and generating student profiles;
• Generating reports, insights, and recommendations from stakeholder information to support the advising, planning, and development process;
• Facilitating AI-assisted advising recommendations, behavioral observations for guidance purposes, and document drafting;
• Obtaining meeting and call transcripts, intake documents, and session summaries;
• Enabling voice sessions and generating transcripts and summaries (where the voice feature is used);
• Supporting AI agent interactions in which users ask questions, provide information, or request reports through the platform;
• Providing customer support and responding to inquiries;
• Sending transactional communications (account confirmations, billing notices, policy updates).

4.2 Service Improvement (De-identified Data Only)

We may use de-identified and aggregated data to improve our AI models, platform features, and service quality. We do not use identifiable student or family personal information to train AI models or improve our products without the explicit written consent of the Advisor (or, if the customer is a parent or individual, their consent) and the applicable student or family.

"De-identified" means that information has been processed in a manner such that it cannot reasonably be used to identify a natural person, and we maintain appropriate technical and administrative safeguards against re-identification.

4.3 Safety and Legal Compliance

We may use personal information to the extent necessary for the following purposes:

• Detecting and preventing fraud, security incidents, and unauthorized access;
• Complying with applicable laws, regulations, and legal process;
• Enforcing our Terms and Conditions and other agreements;
• Protecting the rights, property, and safety of Elevated Environments, our users, and the public.

4.4 Advisory Insights and Behavioral Observations

As part of providing the Services, our platform generates data-derived analytical indicators, including advisory insights and behavioral observations, to support the advising, guidance, and development process for students, parents, and advisors. These outputs are derived from information entered into the platform and are intended to support professional advisor judgment. They may include indicators related to academic readiness, personality and learning characteristics, goal alignment, growth areas, and other characteristics relevant to college planning and personal development. AI-generated outputs may contain errors or omissions and are reviewed by your advisor before being applied to your individual circumstances.

These advisory insights and behavioral observations are:

• Proprietary analytical outputs generated by our platform, used solely to deliver and improve the advisory services;
• Advisory and guidance in nature, and they do not constitute clinical diagnoses, definitive assessments, or determinations about any individual;
• Surfaced through the platform experience to support advisor and stakeholder decision-making;
• Not shared with any third party, not used for advertising, not used for employment, credit, or insurance decisions, and not used for any purpose unrelated to the college advising and development services.

See Section 9.1 for information on your rights regarding these outputs.

5. How We Share Personal Information

5.1 We Do Not Sell or Share Personal Information

We do not sell, share, rent, or trade personal information to any third party for monetary consideration or for any other valuable consideration. This prohibition applies to student and family information, Advisor information, and website visitor data, and applies regardless of whether any consideration is exchanged.

5.2 Service Providers and Subprocessors

We share personal information with third-party service providers ("Subprocessors") who process data on our behalf to help us deliver the Services. All Subprocessors are subject to written data processing agreements and are prohibited from using the data for any purpose other than providing services to us.

Our current Subprocessors are listed in Section 11 of this Policy.

5.3 Advisors as Independent Data Controllers

Advisors who use our platform are independent data controllers for the student and family data they enter. We process that data as a service provider/data processor on the Advisor's behalf and at the Advisor's direction. We do not share student or family information between different Advisor accounts.

5.4 Business Transfers

If Elevated Environments is involved in a merger, acquisition, asset sale, or similar transaction, personal information may be transferred as part of that transaction. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.

5.5 Legal Requirements

We may disclose personal information if we believe in good faith that disclosure is necessary to: (a) comply with a legal obligation or valid legal process; (b) protect the safety of any person; (c) prevent fraud or security threats; or (d) protect our legal rights.

6. Recording Consent

Our platform supports voice session functionality. This section applies to Advisors and stakeholders who use the voice recording feature. Advisors who do not use the voice feature are not subject to the obligations in this section.

Recording laws vary by state. Eleven states require the consent of all parties to a conversation before recording: California, Illinois, Washington, Florida, Pennsylvania, Maryland, Connecticut, Michigan, Nevada, New Hampshire, and Oregon. Federal law requires the consent of at least one party.

Two types of recordings may occur in connection with the platform:

• Elevated Environments platform recordings: Where a voice session is facilitated through the Elevated Environments platform infrastructure, Elevated Environments will provide an automated in-session notification at the start of the session informing participants that the session is being recorded.
• Advisor-provided recordings: Where an Advisor initiates, conducts, or uploads a recording outside of Elevated Environments platform infrastructure (including through third-party tools), the Advisor is responsible for obtaining prior informed consent from all participants and for providing appropriate recording notification consistent with applicable state and federal law.

Advisors who use the voice recording feature must:

• Obtain prior written consent from all session participants before recording;
• Document that consent in their client engagement agreement or a separate consent record;
• Comply with applicable state and federal recording consent laws.

Elevated Environments collects Advisor acknowledgment of these recording consent obligations as part of the platform onboarding process. Advisors who conduct recordings without appropriate consent bear sole responsibility for any resulting legal liability.

7. Data Retention

Retention of personal information is generally determined by the applicable customer, meaning the Advisor, parent, or individual subscriber who is the Elevated Environments account holder. The target retention periods below represent general guidelines for how long we retain different categories of data in the absence of specific customer instruction. Customers may configure shorter retention periods or request deletion at any time, subject to legal retention obligations.

Upon account termination, the applicable customer has 30 days to export their data. Following that window, data is securely deleted from our active systems. We may retain de-identified, aggregated information indefinitely for service improvement purposes.

8. Data Security

We implement industry-standard administrative, technical, and physical safeguards to protect personal information against unauthorized access, disclosure, alteration, and destruction, including:

• Multi-factor authentication (MFA) required for all platform access;
• Encryption in transit using TLS 1.2 or higher for all data transmission;
• Encryption at rest using AES-256 for stored data;
• Role-based access controls limiting data access to authorized personnel;
• Secure deletion procedures for data at end of applicable retention period;
• Annual security policy review and written acknowledgment by all personnel with access to personal data;
• Security monitoring maintained through our cloud infrastructure providers.

In the event of a security incident involving personal information, we will notify affected customers within 72 hours of discovery, as required by applicable law. Advisors are responsible for notifying their affected clients in accordance with applicable breach notification laws.

9. Your Rights and Choices

9.1 Rights for All Users

You have the right to:

• Access the personal information we hold about you;
• Request correction of inaccurate information;
• Request deletion of your information, subject to legal retention obligations;
• Opt out of marketing communications at any time by using the unsubscribe link in any email or contacting us at privacy@elevatedenvironments.ai.

Advisory Insights and Behavioral Observations: As described in Section 4.4, our platform generates advisory insights and behavioral observations as proprietary analytical outputs in the course of providing the Services. These outputs are delivered through the platform experience and are not separately provided as raw data exports. You may request access to your underlying personal information — including assessment responses, transcripts, academic records, and other source data you or your Advisor have entered — and we will provide it upon a valid request. Requesting deletion of underlying source data will be honored and will functionally remove the basis for any derived insights associated with that data.

9.2 California Residents (CCPA/CPRA)

California residents have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including:

• Right to Know: to request disclosure of the categories and specific pieces of personal information we have collected about you, the sources of that information, the business or commercial purposes for collecting it, and the categories of third parties with whom it is shared;
• Right to Delete: to request deletion of personal information we have collected from you, subject to exceptions;
• Right to Correct: to request correction of inaccurate personal information;
• Right to Opt Out of Sale/Sharing: we do not sell or share personal information; this right does not apply to our practices;
• Right to Limit Use of Sensitive Personal Information: we use sensitive personal information only as necessary to provide the Services;
• Right to Non-Discrimination: we will not discriminate against you for exercising your privacy rights.

Because we do not sell or share personal information, the Global Privacy Control (GPC) opt-out signal has no effect on our data practices.

To exercise your California rights, contact us at privacy@elevatedenvironments.ai. We will respond within 45 days and may extend by an additional 45 days with notice.

9.3 Rights Regarding Student and Family Data

How you exercise rights over student and family data depends on your relationship with Elevated Environments:

• If an Advisor is the Elevated Environments customer: The Advisor is the data controller for student and family information. Requests from students and parents to access, correct, or delete their personal information should be directed to their Advisor. Advisors can exercise those requests within the platform, or may submit requests on their clients' behalf to us at privacy@elevatedenvironments.ai.
• If a parent or individual is the direct Elevated Environments customer: Parents and individual subscribers who hold their own Elevated Environments account may exercise access, correction, and deletion rights directly with us at privacy@elevatedenvironments.ai.

If you are a student or parent who cannot reach your Advisor, you may contact us directly at privacy@elevatedenvironments.ai and we will assist to the extent possible.

10. Cookies and Tracking Technologies

We use cookies and similar technologies on our website and platform. Some are essential for the site and platform to function, including things like maintaining your session and security. We also use cookies to understand how our site is used, to support scheduling tools, and to measure the effectiveness of our outreach to prospective advisors. We do not use cookies to collect personally identifiable information or to sell data.

You can manage or delete cookies through your browser settings. For more detail on the cookies we use, see our Cookie Policy at elevatedenvironments.ai/cookie-policy.

11. Third-Party Subprocessors

We use the following third-party service providers to help operate our platform. All Subprocessors are bound by data processing agreements and may only process personal information as directed by us and for the purposes described below:

Note on Workflow Automation (n8n): n8n GmbH is a German company whose cloud infrastructure is located in the European Union. Personal information processed through n8n's workflow automation services may be transferred to and processed in the European Union in the course of platform operations. We have executed a Data Processing Agreement with n8n that incorporates appropriate safeguards for such transfers. We minimize the personal information transmitted through n8n to what is reasonably necessary for the applicable workflow function.

Note on Argentina-Based Development Personnel: Our software development partner SCVsoft employs developers located in Argentina who are part of the ongoing Elevated Environments development team. Certain personal information — specifically, data associated with Advisors and their students for whom the Advisor has executed our Beta Program Development Data Addendum — may be accessed by Argentina-based developers for platform development and testing purposes. Additionally, Argentina-based developers may access production data on a limited, as-needed basis solely to investigate and resolve operational issues affecting the platform. Argentina maintains a comprehensive personal data protection framework (Law 25.326) recognized as providing adequate protection. All Argentina-based personnel are individually bound by non-disclosure agreements and are required to comply with the same data security standards as US-based personnel. Advisors who do not participate in the Beta Program should note that their clients' data is not used for Argentina-based development purposes. For more information, see the Beta Program Development Data Addendum, or contact privacy@elevatedenvironments.ai.

We will notify customers of any material additions to this Subprocessor list by posting an updated policy on our website with at least 30 days' notice before the new Subprocessor begins processing.

12. International Users

Elevated Environments is based in the United States and our services are directed primarily at users in the United States. If you are accessing our services from outside the United States, please be aware that your personal information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country.

We do not currently offer our services to users subject to the European Union's General Data Protection Regulation (GDPR) as a primary market. If you are a resident of the European Union or European Economic Area and have questions about your privacy rights, please contact us at privacy@elevatedenvironments.ai. For information about international transfers related to Argentina-based processing, see Section 11.

13. Educational Records and FERPA

The Family Educational Rights and Privacy Act (FERPA) primarily governs the privacy of educational records held by schools and educational institutions. Elevated Environments operates as a tool used by independent college advisors and directly by students and families, not as a school or educational institution, and does not typically hold "education records" as defined by FERPA.

However, Advisors may use our platform to process information derived from or related to students' educational records. Advisors who have received such information from schools are responsible for ensuring their use of our platform complies with any applicable FERPA requirements and limitations on their use of that information.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the revised policy on our website with an updated effective date. For material changes, we will provide additional notice by:

• Sending an email to the email address associated with your account; and
• Displaying a prominent notice on our platform for at least 30 days following the change.

Your continued use of the Services after the effective date of a revised policy constitutes your acceptance of the changes. If you do not agree to the changes, you must stop using the Services.

15. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

This Privacy Policy was prepared in accordance with applicable U.S. federal and state privacy laws including the Children's Online Privacy Protection Act (COPPA), the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), California AB 1949, and applicable state recording consent laws.