Privacy Policy

This Privacy Policy applies to personal data processed when you:

• create or use an Elovolve account;
• browse coach profiles or other Platform content;
• book or provide coaching sessions;
• make or receive payments;
• communicate with other users through Elovolve;
• submit reviews, ratings or other content;
• contact Elovolve Support;
• participate in disputes or investigations;
• interact with our website or marketing;
• apply to become a coach; or
• otherwise interact with Elovolve.

This Privacy Policy does not govern the privacy practices of third-party services that you may access through Elovolve. Those services may have their own privacy policies.

The personal data we collect depends on how you use Elovolve.

2.1 Account information

When you create an account, we may collect:

• name or display name;
• username;
• email address;
• profile picture;
• password or authentication information;
• country or region;
• date of birth or age information where necessary;
• account preferences;
• account status and verification information.

You may also provide additional profile information voluntarily.

2.2 Coach information

If you apply to or operate as a Coach, we may collect additional information necessary to operate the marketplace and facilitate payments, including:

• legal name;
• date of birth;
• residential address;
• country of residence;
• nationality where required;
• contact information;
• gaming usernames and profiles;
• gaming ranks and achievements;
• coaching experience;
• profile biography;
• social media profiles;
• videos, photographs and other profile content;
• availability;
• pricing;
• payout information;
• tax-related information where required;
• identity and verification information;
• information required by payment providers for onboarding and verification.

Some identity and financial information may be collected directly by third-party payment providers such as Stripe rather than by Elovolve.

2.3 Player information

When you use Elovolve as a Player, we may collect:

• account information;
• profile information;
• gaming usernames;
• selected games and preferences;
• booking history;
• coaching preferences;
• payment and transaction information;
• reviews and ratings;
• communications with Coaches and Elovolve.

2.4 Booking and transaction information

When you book or provide a coaching session, we may process:

• booking details;
• Coach and Player identifiers;
• game and service information;
• session date and time;
• price;
• service fees;
• applicable taxes;
• payment status;
• refund information;
• payout information;
• cancellation information;
• dispute information;
• transaction identifiers;
• fraud and security information.

Payment card information is generally processed by our payment service providers rather than stored directly by Elovolve.

2.5 Communications

When you communicate through Elovolve, we may process:

• messages;
• attachments;
• timestamps;
• sender and recipient information;
• reports concerning communications;
• information necessary to investigate disputes, fraud, abuse, safety concerns or violations of our policies.

Elovolve may access or review communications where reasonably necessary for platform operation, customer support, fraud prevention, dispute resolution, safety, security or enforcement of our Terms of Service and Community Guidelines.

We do not use private communications for unrelated purposes.

2.6 Reviews and user-generated content

We may collect and display:

• reviews;
• ratings;
• written feedback;
• profile information associated with reviews;
• uploaded photographs;
• videos;
• achievements;
• social links;
• other content you submit to Elovolve.

Reviews submitted through Elovolve may remain visible after an account is closed where necessary for marketplace integrity, historical accuracy, fraud prevention or legitimate business purposes.

Imported reviews from external platforms may also be displayed where permitted. Such reviews may be labelled as imported reviews.

2.7 Technical and usage information

When you use Elovolve, we may automatically collect information such as:

• IP address;
• browser type;
• device type;
• operating system;
• approximate location derived from IP address;
• device identifiers;
• login information;
• timestamps;
• pages and features used;
• referring URLs;
• crash reports;
• security events;
• performance information;
• cookies and similar technologies.

We use this information to operate, secure, analyse and improve the Platform.

2.8 Information obtained from third parties

We may receive information from third parties, including:

• payment providers;
• identity verification providers;
• authentication providers;
• gaming or social platforms where you choose to connect them;
• fraud prevention providers;
• analytics providers;
• publicly available sources;
• other users who submit reports or reviews.

Where required by GDPR, we will provide appropriate information about the source of personal data obtained from third parties.

We use personal data for the following purposes.

3.1 Providing the Platform

We process personal data to:

• create and manage accounts;
• provide user profiles;
• facilitate Coach discovery;
• facilitate bookings;
• facilitate communication;
• manage calendars and availability;
• process payments;
• process refunds;
• facilitate Coach payouts;
• maintain transaction records;
• provide customer support;
• operate the Platform.

3.2 Payments and financial administration

We process information necessary to:

• initiate and confirm payments;
• calculate service fees;
• calculate applicable taxes;
• process refunds;
• manage Coach balances;
• process Coach payouts;
• prevent payment fraud;
• investigate payment disputes;
• comply with accounting and financial obligations.

Where required, payment providers may separately process personal data under their own privacy policies.

3.3 Identity verification and fraud prevention

We may process personal data to:

• verify Coaches;
• prevent impersonation;
• detect fraudulent accounts;
• detect payment fraud;
• detect abuse of refunds or chargebacks;
• investigate suspicious transactions;
• protect users and the Platform;
• enforce account restrictions or bans.

Payment and identity verification providers may independently process information for these purposes.

3.4 Dispute resolution

Where a dispute occurs, we may process information relevant to the dispute, including:

• booking information;
• payment information;
• messages;
• screenshots;
• recordings where provided;
• reviews;
• reports;
• other evidence submitted by the parties.

This information may be used to investigate and resolve disputes and determine appropriate action under our Terms of Service.

3.5 Safety and moderation

We may process personal data to:

• investigate harassment;
• investigate threats or abuse;
• investigate scams or fraud;
• investigate inappropriate conduct;
• protect minors;
• enforce Community Guidelines;
• suspend or terminate accounts;
• prevent users from circumventing Platform restrictions.

3.6 Platform improvement

We may use aggregated, statistical or appropriately de-identified information to:

• understand Platform usage;
• improve functionality;
• identify technical problems;
• improve user experience;
• analyse marketplace performance;
• develop new features.

Where information is genuinely anonymised so that individuals can no longer be identified, it is no longer personal data under the GDPR.

3.7 Marketing

Subject to applicable law, we may use personal data to:

• send service-related communications;
• send marketing communications;
• promote Elovolve;
• advertise Coaches and coaching services;
• measure marketing performance;
• personalise marketing.

Where consent is required, we will obtain it before sending the relevant marketing communications.

You may withdraw marketing consent or opt out of marketing communications at any time.

Depending on the circumstances, we rely on one or more of the following legal bases under the GDPR.

Contract

We process personal data where necessary to provide the Platform and perform our agreement with you, including:

• account creation;
• bookings;
• payments;
• communication;
• Coach payouts;
• customer support.

Legal obligation

We process personal data where necessary to comply with legal obligations, including:

• accounting;
• tax;
• financial recordkeeping;
• fraud prevention;
• lawful requests from authorities.

Legitimate interests

We may process personal data where necessary for our legitimate interests, provided those interests are not overridden by your rights and freedoms.

Examples include:

• Platform security;
• fraud prevention;
• moderation;
• dispute resolution;
• improving the Platform;
• protecting users;
• preventing abuse;
• enforcing our Terms;
• defending legal claims.

Consent

Where required, we process personal data based on your consent, including certain marketing activities and certain optional technologies.

You may withdraw consent at any time. Withdrawal does not affect processing that was lawfully carried out before withdrawal.

Elovolve may use cookies, pixels, local storage and similar technologies.

These technologies may be used for:

• essential Platform functionality;
• authentication;
• security;
• remembering preferences;
• analytics;
• performance measurement;
• marketing.

Strictly necessary technologies may be used where permitted without consent.

Where applicable law requires consent for analytics, advertising or other non-essential technologies, we will request consent before using them.

You may manage certain cookie preferences through our cookie settings or your browser settings.

Disabling certain cookies may affect Platform functionality.

We may share personal data with service providers and other parties where necessary to operate Elovolve.

These may include:

Payment providers

For example:

• Stripe;
• Stripe Connect;
• cryptocurrency payment providers;
• other payment providers used by Elovolve.

Payment providers may process payment, identity and financial information according to their own terms and privacy policies.

Technology and infrastructure providers

We may use third-party providers for:

• hosting;
• databases;
• authentication;
• analytics;
• email;
• communications;
• security;
• monitoring;
• backups;
• customer support.

Identity and verification providers

We may share information necessary for identity verification and payment onboarding.

Professional advisers

We may share information with:

• lawyers;
• accountants;
• auditors;
• insurers;
• financial advisers;

where reasonably necessary for their professional services.

Authorities and legal parties

We may disclose personal data where required by law or where reasonably necessary to:

• comply with legal obligations;
• respond to lawful requests;
• protect users;
• investigate fraud;
• protect our rights;
• establish, exercise or defend legal claims.

Business transfers

If Elovolve or substantially all of its assets are acquired, merged or transferred, personal data may be transferred as part of that transaction, subject to applicable law.

We do not sell personal data to data brokers.

Elovolve is a marketplace.

When you interact with another user, certain information may be visible to that user.

Depending on your role and the functionality used, this may include:

• display name;
• username;
• profile photograph;
• gaming information;
• rank;
• achievements;
• Coach biography;
• reviews;
• availability;
• relevant booking information;
• information you voluntarily disclose through communications.

Do not provide sensitive or unnecessary personal information to other users.

You may choose to exchange external contact details such as Discord or Steam information. Information you voluntarily provide directly to another user may then be processed by that third party independently of Elovolve.

Coach profiles may contain publicly visible information such as:

• name or display name;
• profile picture;
• gaming rank;
• achievements;
• biography;
• videos;
• social links;
• reviews;
• other professional or gaming-related information.

By submitting content for a Coach profile, you acknowledge that relevant content may be displayed on Elovolve and may be used to promote the Platform.

Subject to applicable law and the rights granted under our Terms of Service, Elovolve may use Coach profile content in:

• the Elovolve website;
• social media;
• advertising;
• search engine results;
• promotional materials;
• other Platform marketing.

We may crop, resize, format or otherwise adapt submitted content for these purposes.

Coaches and Players may choose to record coaching sessions.

Elovolve does not automatically assume ownership of recordings created by users.

Users are responsible for ensuring that their recording and publication of sessions complies with applicable privacy, data protection, copyright and recording laws.

If a recording is uploaded to Elovolve, we may process it for the purposes for which it was submitted, including Platform operation, moderation, dispute resolution and content display.

Elovolve allows Players aged 16 and 17 to use the Platform with appropriate parent or legal guardian permission.

Coaches must be at least 18 years old.

We do not knowingly permit Coaches to engage in inappropriate or sexual interactions with minors.

Where we become aware of conduct that may place a minor at risk, we may take appropriate action, including restricting or terminating accounts and, where legally required or appropriate, contacting relevant authorities.

If you believe a minor's safety may be at risk on Elovolve, contact us immediately at:

support@elovolve.com

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods may depend on:

• the nature of the information;
• why it was collected;
• whether you continue to use the Platform;
• legal and accounting obligations;
• dispute or fraud investigations;
• limitation periods for legal claims.

For example, transaction and accounting records may need to be retained for longer than ordinary account information.

When personal data is no longer required, we will delete it, anonymise it or otherwise securely dispose of it where appropriate.

Some of our service providers may process personal data outside the European Economic Area ("EEA").

Where personal data is transferred outside the EEA, we will use an appropriate legal mechanism where required by GDPR, such as:

• an adequacy decision;
• Standard Contractual Clauses;
• another lawful transfer mechanism.

Because Elovolve relies on third-party service providers, the location of processing may vary depending on the provider and service used.

We take reasonable technical and organisational measures designed to protect personal data against:

• unauthorised access;
• accidental loss;
• destruction;
• alteration;
• disclosure;
• unlawful processing.

Security measures may include access controls, authentication, encryption where appropriate, monitoring and other technical safeguards.

However, no internet-based service can guarantee absolute security.

If we become aware of a personal data breach requiring notification under applicable law, we will take the required steps to investigate, mitigate and notify affected parties and/or authorities where legally required.

Depending on the circumstances, you have rights under the GDPR including:

• the right to access your personal data;
• the right to correct inaccurate or incomplete personal data;
• the right to request deletion;
• the right to restrict processing;
• the right to object to certain processing;
• the right to data portability;
• the right to withdraw consent where processing is based on consent;
• rights relating to automated decision-making and profiling where applicable.

These rights are not absolute and may be subject to legal exceptions.

For example, we may retain certain information where necessary to comply with a legal obligation, establish or defend legal claims, prevent fraud or maintain legally required records.

The GDPR provides individuals with rights including access, rectification, erasure, restriction, portability and objection, subject to applicable conditions.

To exercise your rights, contact us at:

support@elovolve.com

Please provide enough information for us to identify your account and understand your request.

For security reasons, we may ask you to verify your identity before completing certain requests.

We generally respond to valid GDPR requests within one month, although this period may be extended where permitted by law for complex or numerous requests.

If you believe that we have processed your personal data unlawfully or have not adequately addressed your request, you have the right to lodge a complaint with a supervisory authority.

As ExcaliburHQ B.V. is established in the Netherlands, you may contact the:

Autoriteit Persoonsgegevens The Dutch Data Protection Authority

You may also contact the data protection authority in the EU/EEA country where you live, work or believe that an infringement occurred.

We encourage you to contact us first so that we have an opportunity to address your concern, but you are not required to do so.

Elovolve may use automated systems for purposes such as:

• fraud detection;
• security monitoring;
• ranking or sorting marketplace content;
• recommendations;
• identifying potentially suspicious activity.

Where applicable, these systems may result in additional verification, restrictions or other actions.

We do not intend to make decisions based solely on automated processing that produce legal or similarly significant effects on you unless permitted by applicable law and appropriate safeguards are provided.

Where GDPR gives you rights in relation to automated decision-making, you may exercise those rights by contacting us.

Elovolve may contain links, integrations or functionality provided by third parties.

These may include gaming platforms, social networks, payment providers and other services.

When you interact with a third-party service, that service may process your personal data independently.

We recommend reviewing the relevant third party's privacy policy before providing personal data.

Elovolve is not responsible for the privacy practices of independent third parties.

We may update this Privacy Policy from time to time.

If we make material changes, we may notify users through the Platform, email or another appropriate method.

The updated Privacy Policy will indicate its effective date.

Your continued use of Elovolve after the effective date of an updated Privacy Policy constitutes acknowledgement of the updated policy to the extent permitted by law.

If you have questions about this Privacy Policy or how Elovolve processes personal data, contact:

Elovolve collects and processes personal data primarily to operate its gaming coaching marketplace, facilitate bookings and payments, protect users, prevent fraud, resolve disputes and improve the Platform.

We aim to collect only the information reasonably necessary for these purposes, retain it only for as long as necessary or legally required, and respect the rights granted to individuals under applicable data protection law.

This Privacy Policy should be read together with the Elovolve Terms of Service, Refund & Cancellation Policy, Coach Terms and Community Guidelines.