Privacy Policy

Effective Date: 01/OCT/2026

1. WHO WE ARE

This Privacy Policy explains how MOCEANS Center for Independent Living (“MOCEANS,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information through the Elevate Labs platform (“Elevate Labs,” “the Platform,” “the App”). The Platform includes the Elevate Labs Student mobile application, the Elevate Labs Trainer mobile application, and the Elevate Labs Super Admin web portal.

MOCEANS Center for Independent Living is the data controller responsible for how personal information is handled within Elevate Labs. This policy applies to all users of the Platform, including students, trainers, and administrators.

Contact: [email protected]

2. WHAT THIS PLATFORM IS AND IS NOT

Elevate Labs is a centralized communication and program-access platform. It brings program information, messaging, and links to third-party systems into one mobile experience for MOCEANS program participants.

Elevate Labs does not replace, host, or administer:

  • Tavuti Learning Management System
  • Pathful career-planning platform
  • Google Classroom
  • Gusto payroll and time-tracking

Those third-party systems remain owned and operated by their respective providers. When you access those systems through Elevate Labs, their own privacy policies also apply to how they handle your information.

Elevate Labs does not process payments, does not process payroll, and does not record custom attendance. Where payroll and internship-hour information is displayed, it is retrieved from Gusto through supported integration methods. Gusto remains the source of truth for all payroll and time-tracking data.

3. HOW YOU GET AN ACCOUNT

Elevate Labs accounts are created and controlled by MOCEANS administrators. You do not sign up for Elevate Labs on your own.

A MOCEANS administrator initiates your account and sends you an email invitation. You activate the account through that invitation link, verify your email through a secure verification method, and complete the profile information the administrator has approved for your role.

Account activation, suspension, reactivation, and deactivation remain administrator-controlled at all times.

4. INFORMATION WE COLLECT

4.1 Information you provide directly

  • Profile information: Full name, contact number, profile photo (optional), and any additional profile fields the administrator has approved for the program.
  • Account credentials: Password (stored using industry-standard hashing; we never store your password in readable form).
  • Communication content: Text messages you exchange with your assigned trainer or assigned students within the Platform.
  • Support requests: Information you provide when contacting support through the app.

4.2 Information the administrator provides about you

  • Your email address
  • Your role (student, trainer, or administrator)
  • Program assignments (which trainer you are assigned to, or which students are assigned to you)
  • Enrollment status
  • Any internal identifiers the administrator uses to link your Elevate Labs account to your MOCEANS program record

4.3 Information collected automatically

  • Device information: Device model, operating system version, unique device identifiers (used for security and to deliver push notifications).
  • Log data: Login times, actions within the Platform, feature usage, error reports.
  • Approximate location: Only if you enable it for a specific feature and only at the coarse level needed for that feature.
  • Push notification tokens: Used only to deliver notifications you have permitted.

4.4 Information from third-party integrations

When you sign in to a third-party system through Elevate Labs, we receive limited information from that system to display within the Platform:

  • Tavuti LMS: Course information, assignment titles, deadlines, completion status, learning progress (where supported).
  • Pathful: Access confirmation and any supported career-planning information (where an approved integration method is available).
  • Google Classroom: Classroom links and available classroom information, assignments, and deadlines (where supported by Google’s APIs).
  • Gusto: Internship-hour records, attendance records, and payroll status (where supported by Gusto’s APIs).

The authentication tokens that allow this access are held securely and used only to fetch the specific information the Platform displays. We do not store your third-party account passwords.

5. WHY WE COLLECT THIS INFORMATION

We use your information for the following purposes:

  • To operate the Platform. Deliver messages between students and their assigned trainers, display your calendar, show program announcements, and provide the features you use inside the app.
  • To connect you to third-party systems. Authenticate you into Tavuti, Pathful, Google Classroom, and Gusto through approved integration methods.
  • To support the MOCEANS program. Give administrators the operational information they need to manage student enrollment, trainer assignments, program participation, and communication oversight.
  • To keep the Platform secure. Detect suspicious activity, protect against unauthorized access, and enforce our Terms & Conditions.
  • To meet legal obligations. Retain records where required by law, respond to lawful requests, and cooperate with legitimate legal processes.
  • To improve the Platform. Understand how features are used at an aggregate level and identify areas for improvement.

We do not use your information for advertising, ad targeting, or sale to third parties. Ever.

6. LEGAL BASIS FOR PROCESSING

Where applicable law requires a legal basis for processing personal information, we rely on:

  • Contract: Processing necessary to provide the Platform to you as part of your participation in a MOCEANS program.
  • Legitimate interest: Operating the Platform securely, preventing fraud, and improving the service, provided those interests do not override your rights.
  • Consent: For optional features such as push notifications or profile photos, which you can withdraw at any time through the app or by contacting support.
  • Legal obligation: Where retention or disclosure is required by law.

7. HOW WE SHARE INFORMATION

7.1 With MOCEANS staff

MOCEANS administrators have access to your account information, program activity, and communication metadata as needed to run the program. Your assigned trainer or assigned students can see the messages you exchange with them and the profile information the administrator has approved for their view.

7.2 With third-party integration providers

When you access Tavuti, Pathful, Google Classroom, or Gusto through Elevate Labs, we exchange authentication information and the specific data required for that integration with the third-party provider. Once your data is with those providers, their own privacy policies govern its handling.

7.3 With service providers

We work with vendors who help us operate the Platform (hosting, error monitoring, push-notification delivery, email delivery). These providers process personal information only on our instructions, only to the extent needed to perform their services, and under contractual confidentiality and data-protection obligations.

7.4 For legal reasons

We may disclose information if we believe in good faith that disclosure is required by law, court order, or valid legal process, or where necessary to protect the rights, property, or safety of MOCEANS, our users, or the public.

7.5 In organizational changes

If MOCEANS undergoes a merger, acquisition, restructuring, or transfer of assets, personal information may be transferred as part of that transaction. We will notify affected users where legally required and continue to protect the information consistent with this Privacy Policy.

We do not sell personal information. We do not rent it. We do not use it to target advertising to you.

8. THIRD-PARTY INTEGRATIONS: IMPORTANT NOTES

Elevate Labs integrates with Tavuti LMS, Pathful, Google Classroom, and Gusto. When you use those integrations:

  • Your access is subject to the terms of service and privacy policy of each third-party provider.
  • We are not responsible for the availability, accuracy, security, or data practices of those third-party systems.
  • Information you provide directly to a third-party system inside its own environment is governed by that provider’s policies, not this one.
  • If a third-party provider changes its API, permissions, licensing, or authentication methods, related features in Elevate Labs may change or become unavailable.

Links to each third-party provider’s privacy policy are available inside the Platform.

9. HOW LONG WE KEEP YOUR INFORMATION

We keep personal information only as long as needed for the purposes described in this policy, or as required by law.

  • Active accounts: For the duration of your MOCEANS program participation and your account’s active status in the Platform.
  • Communication history: Retained for future reference and operational tracking while your account is active. Retention periods for archived communications will follow MOCEANS records-retention rules.
  • Audit logs: Retained for the period MOCEANS requires for security, compliance, and operational review.
  • After account deactivation: Certain information may be retained for a reasonable period to meet legal, regulatory, records-retention, or program-integrity requirements.

You can request deletion of your information as described in Section 11.

10. DATA SECURITY

We use industry-standard security measures to protect personal information, including:

  • Encrypted communication (data in transit is protected using TLS)
  • Encrypted storage of credentials (passwords hashed and salted using accepted algorithms)
  • Role-based access control (users only see information appropriate to their role)
  • Secure session management
  • Audit logging for security-relevant administrative actions
  • Regular access reviews for administrators and privileged accounts

No system is completely secure. If a data incident occurs that materially affects your personal information, we will notify affected users and applicable authorities as required by law.

11. YOUR RIGHTS

Depending on where you live, you may have the following rights regarding your personal information:

  • Right to access. Request a copy of the personal information we hold about you.
  • Right to correct. Ask us to correct information that is inaccurate or incomplete.
  • Right to delete. Request deletion of your personal information, subject to legal and program-integrity retention requirements.
  • Right to restrict processing. Ask us to limit how we use your information in certain circumstances.
  • Right to object. Object to certain uses of your information based on legitimate interest.
  • Right to portability. Request a copy of certain information in a machine-readable format.
  • Right to withdraw consent. Where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, contact [email protected]. We may need to verify your identity before acting on a request. We will respond within the timelines required by applicable law.

If you believe your rights have not been respected, you may lodge a complaint with your local data protection authority.

12. CHILDREN

Elevate Labs is designed for MOCEANS program participants. Where the program includes minor participants (typically transition-age youth), accounts for minors are created and controlled by MOCEANS administrators with the involvement of parents, guardians, or authorized representatives as required by the program and by applicable law.

We do not knowingly collect personal information from children under 13 without appropriate authorization from a parent or guardian and MOCEANS staff. If you believe a minor has provided information to the Platform outside the program’s approved channels, contact us at [email protected] so we can investigate and take appropriate action.

13. ACCESSIBILITY

MOCEANS is committed to making the Platform usable by people with disabilities. Elevate Labs is developed following accessibility best practices, including:

  • Screen-reader compatibility for core content
  • Large touch-friendly controls
  • Scalable and readable typography
  • Strong color contrast
  • Clear labels and predictable navigation

If you experience an accessibility barrier in the Platform, contact [email protected] so we can work with you on an alternative access method.

14. INTERNATIONAL USERS

Elevate Labs is operated from the United States and hosted with providers that may store or process data in the United States or other countries. If you access the Platform from outside the United States, you understand that your information may be transferred to, stored in, and processed in countries whose data-protection laws may differ from those of your country. Where required, we apply appropriate safeguards for international transfers.

15. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, the Platform, or applicable law. When we make material changes, we will notify users through the Platform or by email and update the “Last Updated” date at the top of this policy.

Your continued use of the Platform after changes take effect means you accept the updated policy. If you do not agree with a change, contact us to discuss options for your account.

16. CONTACT US

For questions about this Privacy Policy or how we handle your personal information, reach out to:

MOCEANS Center for Independent Living
Email: [email protected]
Website: https://moceanscil.org

For accessibility support, use the same contact and mention that you need accessibility assistance.