Privacy Policy · Elative Solutions OÜ
Elative Solutions OÜ

Privacy Policy

Last updated: 1 May 2026 · Effective Date: 1 May 2026

This Privacy Policy applies to all websites, applications, mobile apps, subdomains, memberships, services, and products operated by Elative Solutions OÜ, including but not limited to the following brands and domains:

  • CoachSuite Pro · coachsuite.pro and all associated subdomains
  • Altitude Club · go.altitude.club, goaltitude.club, and all associated subdomains
  • Altitude Pulse · altitudepulse.app, the Altitude Pulse iOS app, the Altitude Pulse Android app, and all associated subdomains
  • Elative Solutions · elative.solutions, elative.io, elative.one
  • Any other brands, websites, and applications operated by Elative Solutions OÜ, now or in the future

All of the above are collectively referred to as the "Sites" and "Apps" throughout this document.

Elative Solutions OÜ is committed to protecting your privacy and ensuring the security of your personal information. By using the Sites or Apps, you acknowledge that you have read and accepted this Privacy Policy. If you do not agree, please discontinue use immediately.

1. Who We Are

Elative Solutions OÜ, a company registered in Estonia, acts as the Data Controller for personal data collected through our Sites and Apps. We are committed to compliance with GDPR (General Data Protection Regulation), CCPA (California Consumer Privacy Act), CPRA (California Privacy Rights Act), and PIPEDA (Personal Information Protection and Electronic Documents Act, Canada).

If you have any questions regarding your privacy, you may contact us at:

  • Legal Entity: Elative Solutions OÜ
  • Email: [email protected]
  • Postal Address: Ahtri tn 12, Kesklinna linnaosa, Harju maakond, 10151 Tallinn, Estonia, EU

2. Mobile Apps Scope

This section describes data handling specific to the Altitude Pulse mobile app (iOS and Android) and the Altitude Club mobile experience.

What we collect in the mobile apps

  • Account data: email and name when you create an account
  • Phone number (optional): used for CRM enrichment and account recovery if you provide it
  • Your written content: reflections, notes, and CoPilot prompt responses you write inside the app are stored privately on your account and accessible only to you. We do not analyse, train models on, or share these freeform entries.
  • Engagement events: which Pulses and screens you opened, when, and basic interaction counts. Used to personalise the daily arc and measure platform health.
  • Push notification token: a device-level identifier issued by Apple or Google when you allow notifications. Linked to your account so we can send the right notification to the right device.
  • Anonymised session interactions: taps, scrolls, and screen views (see section 6).
  • Crash and performance metrics: anonymous diagnostic data (see section 8).

What we do not collect in the mobile apps

  • Contacts, calendars, photos, microphone, or location, unless a feature explicitly requests permission and you grant it
  • Health, biometric, or sensitive personal data
  • Content of sensitive form fields such as passwords or payment details (these are masked in session analytics)

Mobile app data processors

Mobile app data is processed by Supabase (database and authentication), OneSignal (push notifications), Microsoft Clarity (anonymised session analytics), and GoHighLevel (CRM enrichment). The full subprocessor list is in section 12.

3. Data Collection and Processing

We collect personal data including but not limited to contact information, customer transaction details, user data, technical data, and marketing preferences. We gather this data through direct interactions (such as when you sign up, purchase, or contact support), automated tracking (cookies and analytics), third-party service integrations, and publicly available sources.

Under GDPR, we process data based on contractual necessity, legitimate interest, consent, and legal obligations. Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data:

Communication Data

Any communication you send to us through contact forms, email, text, social media messaging, or any other channel. We process this data to respond to enquiries, maintain records, and comply with legal obligations.

User Content

Reflections, journal notes, CoPilot prompt responses, and other freeform content you write inside Altitude Pulse, Altitude Club, or CoPilot. Stored on your account and accessible only to you. Not used for model training, not shared, and not analysed by humans except where you explicitly request support involving that content.

Customer Data

Details related to purchases including your name, billing address, delivery address, email address, phone number, and payment details. We process this to supply the goods and services you have purchased and to maintain transaction records.

User Data

Data about how you use our Sites and Apps including interactions with content, session history, and engagement levels. We process this to improve user experience and platform functionality.

Business Infrastructure Data

Where members use our platforms to manage their own coaching or consulting business, we may process data relating to their client contact records, funnel configurations, CRM settings, and automation sequences stored within the platform. This data is processed solely to provide the contracted service. Members retain full ownership of their own client data at all times.

Technical Data

IP addresses, login data, browser details, session lengths, device information, and analytics tracking. This helps us optimise our Sites and Apps and detect security threats.

Marketing Data

Preferences regarding marketing communications, promotions, and advertising.

Phone Numbers and AI Communications

If you provide your phone number, we may use it to send SMS messages, WhatsApp messages, or AI-generated outbound communications based on your stated preferences.

We do not collect sensitive personal data including race, ethnicity, religious beliefs, biometric data, or criminal records.

4. How We Collect Your Personal Data

We collect data in the following ways:

  • Direct interactions: account registration, purchases, newsletter sign-ups, mobile app onboarding, or contacting customer support
  • Automated tracking: cookies, tracking pixels, analytics tools, and mobile SDKs when you interact with our Sites or Apps
  • Third-party sources: if you connect third-party platforms such as Google or Facebook, we may receive relevant user data
  • Publicly available sources: such as business directories or professional records

5. Use of Cookies and Tracking Technologies

Our Sites use cookies and other tracking technologies to enhance functionality, improve user experience, and support marketing and analytics. When you first visit, a cookie consent banner allows you to accept or reject non-essential cookies. You can also manage cookie preferences through your browser settings.

a. What Are Cookies

Cookies are small text files stored on your device when you visit a website. They help websites remember your preferences, enhance your browsing experience, and improve functionality. Cookies may be first-party (set by our Sites) or third-party (set by advertising or analytics providers).

b. Types of Cookies We Use

  • Essential Cookies: necessary for the operation of the Sites, enabling basic functions like page navigation, secure logins, and fraud prevention
  • Performance Cookies: collect information about how visitors use our Sites to optimise performance and improve user experience
  • Functional Cookies: allow our Sites to remember choices you make, such as language preferences or login details
  • Marketing and Advertising Cookies: track your online activity to deliver targeted advertisements relevant to your interests

c. Third-Party Cookies

Some cookies on our Sites are placed by third-party service providers including Google Analytics, Facebook Pixel, and payment providers. These third parties may use cookies in accordance with their own privacy policies, which we recommend reviewing.

d. Managing Cookies

You may adjust your browser settings to block or delete cookies, opt out of third-party tracking through https://optout.aboutads.info, or use our cookie consent banner to manage non-essential cookie preferences. If you disable certain cookies, some parts of our Sites may not function correctly.

6. Session Analytics (Microsoft Clarity)

We use Microsoft Clarity to record anonymised session interactions across our websites and mobile apps. Clarity captures taps, scrolls, screen views, page paths, and similar interaction signals, and produces session replays and heatmaps that help us identify confusing flows and broken interface elements.

Clarity does not capture the content of sensitive form fields such as passwords or payment information. We do not use Clarity to identify individual users by name, email, or other direct identifier.

For more information, see the Microsoft Privacy Statement.

7. Push Notifications (OneSignal)

We use OneSignal to deliver push notifications to the Altitude Pulse and Altitude Club mobile apps. When you allow notifications, OneSignal stores a device-level push token issued by Apple Push Notification service or Firebase Cloud Messaging. That token is linked to your account so we can deliver the right notification to the right device, and is removed when you uninstall the app or revoke notification permission in your device settings.

Push tokens are treated as personal identifiers under GDPR and Apple App Privacy guidance. For more information, see the OneSignal Privacy Policy.

8. Crash and Performance Data

Anonymous crash logs and app performance metrics are collected by iOS and Android system services to help us diagnose stability issues and prioritise performance work. This data includes information such as the type of device, operating system version, app version, and the technical context of a crash.

This crash and performance data is not linked to your identity and is treated as Diagnostic Data under Apple App Privacy disclosures.

9. Marketing Communications and Consent

We only send marketing communications with your explicit consent. We use double opt-in for email subscriptions. You may opt out at any time by clicking the unsubscribe link in any email or contacting us at [email protected].

SMS Opt-In: by opting in, you agree to receive text messages from us. You may unsubscribe at any time by replying STOP. Opting out of marketing communications will not affect essential service-related communications.

10. Third-Party Advertising and Marketing

We use third-party advertising services including Meta (Facebook and Instagram Ads) and Google Ads to promote our products and services. These platforms may collect and process user data through technologies such as Facebook Pixel and Google Analytics.

If you prefer not to receive personalised advertising, you may opt out through:

For California Residents: submit a CCPA Opt-Out Request to [email protected] with your full name and account email. We will process your request within 30 days.

11. GoHighLevel CRM · Third-Party Infrastructure

Elative Solutions OÜ uses GoHighLevel as the underlying CRM and technical infrastructure for CoachSuite Pro and Altitude Club. GoHighLevel is a third-party software-as-a-service platform that processes certain member and contact data on our behalf as a data processor.

Data processed within GoHighLevel infrastructure may include contact records, CRM entries, automation sequences, funnel configurations, email communications, and SMS messages. GoHighLevel operates servers in the United States. Data transfers from the EU to GoHighLevel are governed by Standard Contractual Clauses (SCCs) in compliance with GDPR and Schrems II requirements.

Members who store their own client data within the platform remain the data controller for that client data. Elative Solutions OÜ processes that data solely as a data processor acting on the member's instruction. Members are responsible for ensuring they have obtained appropriate consent from their own clients before uploading or storing client data within the platform.

12. Subprocessors

We engage the following third-party service providers (subprocessors) to operate our Sites and Apps. Each subprocessor is bound by a Data Processing Agreement and processes data solely on our documented instructions.

  • Supabase · authentication and database for the Altitude Pulse, Altitude Club, and admin platforms · United States
  • OneSignal · push notification delivery for mobile apps · United States
  • Microsoft Clarity · anonymised session analytics and heatmaps · United States and European Union
  • GoHighLevel · CRM, marketing automation, and Altitude Club mobile app host · United States
  • Vercel · web hosting for Altitude Pulse, Altitude Club, CoPilot, and admin dashboards · United States
  • Apple · App Store distribution, push notification service, and crash reporting for iOS · United States
  • Google · Play Store distribution, Firebase Cloud Messaging, and crash reporting for Android · United States
  • Stripe · payment processing for web checkout · United States
  • Google Analytics · website analytics · United States
  • Meta Platforms · advertising analytics (Facebook Pixel) and WhatsApp messaging · United States

Where data is transferred outside the European Economic Area, transfers are governed by Standard Contractual Clauses and supplementary safeguards.

13. Data Security and Retention

We implement industry-standard security measures including data encryption, controlled access, and routine security audits. We retain personal data for the following periods:

  • Account and Transaction Data: 6 years for tax and legal compliance
  • Marketing Data: retained until you unsubscribe or withdraw consent
  • Analytics and Behavioural Data: 12 months unless removed earlier
  • Inactive Accounts: deleted after 2 years of inactivity unless required for legal reasons
  • Support and Enquiry Data: 12 months after last contact
  • Security Logs: 6 months for security monitoring
  • AI Logs: 6 months unless required for security or fraud prevention
  • Email Logs: up to 2 years for legal compliance

14. Account Deletion

Self-service deletion in the mobile app. You can permanently delete your account at any time from within the Altitude Pulse mobile app: Settings → Delete my account. Deletion is immediate and includes all profile data, daily reflections, gamification state, and session history stored against your account.

CRM contact records may be retained for legal and compliance reasons up to the periods listed in section 13. If you would like the CRM record deleted in addition to the app account, email [email protected] from the address associated with your account and we will action the request within one month.

You can also request deletion of any account or data record by emailing [email protected] at any time.

15. International Data Transfers

We operate globally and your data may be transferred outside the European Economic Area (EEA) to countries including the United States, Canada, Australia, and the United Kingdom. We ensure data protection through Standard Contractual Clauses (SCCs) under GDPR, and where applicable, additional safeguards such as encryption, pseudonymisation, and access controls. We have Data Processing Agreements in place with key third-party service providers.

16. CCPA Notice for California Residents

California residents have the following rights under CCPA and CPRA:

  • The right to know what personal data is collected
  • The right to request deletion of collected personal data
  • The right to opt out of data selling or sharing

We do not sell personal data. However, third-party analytics and advertising services may collect data as defined under CCPA. To exercise your rights, email [email protected] with the subject line CCPA Opt-Out Request. We will process your request within 30 days.

17. PIPEDA Notice for Canadian Residents

Under PIPEDA, Canadian residents have the following rights:

  • The right to request access to their personal data
  • The right to challenge the accuracy of collected information
  • The right to file a complaint with the Office of the Privacy Commissioner of Canada

To exercise your rights under PIPEDA, contact us at [email protected].

18. SMS, WhatsApp, and AI-Generated Communications

We may use SMS, WhatsApp, and AI-generated outbound messages to provide service notifications, reminders, marketing promotions, and platform updates. By providing your phone number and opting in, you expressly consent to receive such messages. You may opt out at any time by replying STOP, updating your account preferences, or contacting [email protected].

WhatsApp messages may be processed by Meta Platforms, Inc. Data transfers are governed by Standard Contractual Clauses under GDPR. We do not sell or share your WhatsApp number with third-party advertisers. Compliance framework: GDPR (EU and UK), CCPA (California), TCPA (United States), CASL (Canada).

19. Use of AI and Automated Processing

We use Artificial Intelligence and automated technologies to enhance our services, including:

  • AI-powered tools for customer support, enquiry handling, and service recommendations
  • Automated SMS, email, and WhatsApp responses based on user queries
  • The Altitude AI CoPilot, which uses aggregated and anonymised coaching business data drawn from platform usage to generate targeted business intelligence for members. Individual member data is not shared with other members.
  • Personalisation and automated content recommendations based on platform activity

AI does not make decisions with significant legal or financial consequences unless explicitly stated. Under GDPR Article 22 and CCPA/CPRA, you have the right to be informed about AI-driven decisions, to request human intervention, and to object to AI-based profiling. To exercise these rights, contact [email protected].

20. Children's Privacy

Altitude Pulse and Altitude Club are not directed at children under 13 (or under 16 in jurisdictions where the higher age applies under GDPR). We do not knowingly collect personal data from children under these ages.

If you are a parent or guardian and you believe a child has provided us with personal data, please contact [email protected] and we will delete the relevant account and associated data without undue delay.

21. Your Legal Rights

Under global data protection laws, you have the right to:

  • Access your personal data
  • Correct or update inaccurate data
  • Request deletion of personal data
  • Restrict or object to certain types of data processing
  • Request data portability
  • Withdraw consent where processing is based on consent

To exercise any of these rights, contact us at [email protected]. We will respond to all legitimate requests within one month. There is no fee to exercise your rights unless a request is clearly unfounded, repetitive, or excessive. We may need to verify your identity before processing certain requests.

Right to lodge a complaint. Under GDPR Article 77, you have the right to lodge a complaint with your local data protection authority. In Estonia, the supervisory authority is the Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate), https://www.aki.ee/en. EU residents can also use the European Data Protection Board portal at https://edpb.europa.eu.

22. Third-Party Links

Our Sites and Apps may contain links to third-party websites, plug-ins, or applications. These third parties may collect personal data independently. We are not responsible for their data handling practices and encourage you to read their respective privacy policies.

23. Third-Party Data Sharing

We share personal data with trusted third-party service providers for payment processing, analytics, push notifications, and marketing. The full subprocessor list is in section 12. We have Data Processing Agreements with these providers to ensure compliance with GDPR, CCPA, and PIPEDA. We do not sell personal data to third parties for advertising purposes.

24. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Updates will be reflected in the Effective Date at the top of this document. Continued use of our Sites or Apps after such modifications constitutes acceptance of the revised terms. We will make reasonable efforts to notify users of material changes via email or a notice on the relevant Site or App.

25. Contact Us

If you have any questions about this Privacy Policy or wish to make a complaint, contact us at:

Elative Solutions OÜ
Ahtri tn 12, Kesklinna linnaosa
Harju maakond, 10151 Tallinn
Estonia, EU
Email: [email protected]