Privacy Policy

Effective Date: September 8, 2026

Overview and Scope of Notice

Escalate USA, Inc. (collectively “Escalate”, “we”, “us” or “our”) is committed to respecting the privacy of our users. We strive to provide a safe, secure online experience. This Privacy Notice describes how we may collect, use, share, and store your personal data when individuals visit our website, escalateusa.com, access our e-learning services, participate in our e-learning community, register to attend our events and webinars (online), participate in surveys, and contact us through various communication methods (the “Services”). This Notice also describes the choices you have with respect to your personal information, in connection with our Services as related to your personal data.

This Notice also applies to the Escalate Support mobile application for iOS and Android (the “App”). The App is available to employees of employers that participate in an Escalate program and is included in the “Services” as used in this Notice.

We will only process your personal data in accordance with this Privacy Notice unless otherwise required by applicable law. We take steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.

Links to Other Websites. This Notice does not apply to websites we do not own or control. We are not responsible nor liable for how third parties manage their own sites. Please refer to the privacy notices posted on those sites for more information.

Personal Data. Personal data refers to information relating to an identified or identifiable individual including name, phone number, company name, job, email, and postal address. In the provision of e-learning services, we do not knowingly collect sensitive personal data such as precise geolocation data, racial or ethnic origin, political opinions, religious or philosophical beliefs, data concerning health or data concerning a natural person’s sexual orientation.

Usage Data. Passively or automatically collected data (referred to as “Usage Data”) is collected as you use our websites or access our services. We, our affiliated entities, our service providers, and our marketing partners may use automated means to collect various types of information about you, your computer or other device used to access the sites and Services. This information is based on your usage of our sites and services and may be based on your visitation to other websites.

Data Controller. We act as the data “Controller” for the personal data you provide directly to us. Examples include when you fill out “Contact Us” form, create an account, participate in surveys, participate in our e-learning community, attend events, apply to one of our jobs, or contact us via other methods.

What Types of Information Do We Collect?

When you visit our Site and use our Services we may receive personal information relating to you. “Personal Information” is information that can directly or indirectly identify you or could reasonably be linked with you or your household, such as your first name, last name, business email address, social media handles, telephone number or payment information (if you register for a paid event that we run).

We may also receive other information relating to you or your device used to access our Site or Services which may also be considered Personal Information, such as your IP address, device type, operating system, browser type, and other technical information.

Types of Personal Data Collected

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
• Work history and other relevant experience including information contained in a resume, cover letter, or job application.
• Education information including degrees awarded, transcripts, and other information provided in support of your application.
• Details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits.
• Information provided by third parties.
• Information related to previous employment history
• Account information you provide when registering in the App: name, email address, mobile phone number, preferred language, and the client code issued by your employer.
• Support communications: messages you send through the App’s support chat to Escalate staff, and messages you send to the App’s AI assistant, together with the responses.
• Technical and diagnostic data from the App, such as device type, operating system version, App version, and crash reports.

How We Collect Personal Data

Information You Provide to Us

We collect personal data directly from you such as when you make an inquiry through our “Contact Us” web page and other contact methods, and when you request that we send you emails. Depending on where you reside, you may have the option to provide your consent before we collect your personal data to send you marketing emails. You may unsubscribe to our marketing emails by using an opt-out link containing non-transactional email or by updating your marketing preferences on your account page. We also store the files or other information that you upload or provide to us as part of your subscription.

Collection and Storage of Slack Communication Data

As part of our commitment to providing a secure and effective educational experience, we may request and store backups of communications and content within our Slack workspace. This data collection is intended for maintaining the integrity of our program, complying with legal obligations, and addressing any operational issues. We are committed to ensuring the privacy and security of your data and will take all necessary measures to protect it from unauthorized access or disclosure.

How We Use Personal Data

We may use the information we collect about you for a variety of purposes, including to:

Operate our services

We use the information we collect about you to provide, operate, maintain, and improve our Services. We also use this information to help you use the Services, including uploading, downloading, collaborating on, and sharing content, delivering e-learning content to learners, as well as delivering emails.

We also use information about you to provide and deliver the Services and features you request, to process and complete transactions, and to send you related information, including purchase confirmations and invoices.

Communicate with you

We also use the information we collect about you to send you technical notices, updates, security alerts, and support and administrative messages. We’ll also use that information to communicate with you about Services, features, surveys, newsletters, offers, and events, as well as provide other news or information about us and our select partners.

Of course, we’ll also use your information to respond to your comments, questions, and requests, provide customer service and support, and deliver contest entries and rewards.

Protect our services

We also use information about our users to investigate and prevent fraudulent transactions, unauthorized access to our services, and other illegal activities.

​Service Providers for the Escalate Support App

To operate the App we use the following service providers, each of which processes personal data only on our instructions and for the purpose stated:

How Long We Keep Personal Data

We will not retain your personal data for longer than required. This means that we will keep your personal data for any or a combination of time periods described as follows: (i) for as long as required by law, (ii) until we no longer have a valid reason for keeping it, (iii) until you request us to stop using it, or (iv) for so long as our customer for which you are an authorized user remains a customer. In addition, we retain your personal data to preserve history in the e-learning community and to provide the ongoing ability to participate. When we delete your personal data from our databases, it will remain in our backup system until it cycles out.

Deleting Your Account

Deleting your account. You can delete your App account at any time from the Account screen in the App (Account → Delete account), or by following the steps at https://support.escalateusa.com/delete-account if you no longer have the App installed. When you delete your account, your login is permanently disabled, all active sessions are ended, and you will no longer be able to access the App or the Services.

What we retain after deletion. Escalate provides support to you as part of a program sponsored by your employer. Records of the support provided under that program are retained by Escalate for as long as required to administer and account for the program with your employer, to comply with legal obligations, and to resolve disputes, in line with the retention periods described above. Data may remain in backup systems until it cycles out.

Cookies and Similar Technologies

We use cookies and similar technologies to help us see what pages you view on our site and any actions you take. That helps us develop helpful content and serve you customized web content and communication that best meets your needs. Please review the Cookies and Similar Technologies section for more information.

We may automatically collect Usage Data through the use of persistent or session cookies, javascripts, pixels, web beacons, local storage (HTML5), and similar technologies, which we jointly refer to here as “cookies.” Cookies are small text files or a piece of code a website uses to recognize repeat users, facilitate the user’s ongoing access to the site, and facilitate the use of the site. Cookies also allow a site to track usage behavior and compile site-usage information that will allow for the improvement of content. You may reject cookies by activating the setting on your internet browser. However, if you select this setting you may be unable to access certain parts of our sites. Unless you have adjusted your browser setting so that it will reject cookies, our system will issue cookies when you log on to our site.

You can also use the Global Privacy Control (“GPC”) to opt-out of tracking through cookies or similar technology. To learn more about the GPC, please visit https://globalprivacycontrol.org. If you delete cookies or reset your device, you may need to set your preference again to ensure we continue to honor your preferred choice.

Analytics

We engage third party analytics partners to monitor and analyze our web traffic and to keep track of user behavior on our sites. The providers we use are named below, together with what each one does and whether it requires your consent.

• Fathom Analytics measures page views and the sites visitors arrive from. Fathom does not set cookies and does not store any information on your device, and it does not run until you accept analytics cookies. See the Fathom Analytics privacy policy.
• Google Analytics measures page views, the sites visitors arrive from, and how visitors move through this site. Google Analytics sets cookies and does not run until you accept analytics cookies. See the Google privacy policy.
• HubSpot is our customer relationship management and marketing platform. It records the pages you visit and associates them with any enquiry you send us, so that we can respond to you with context. HubSpot sets cookies and does not run until you accept analytics cookies. See the HubSpot privacy policy.

You may change or withdraw your choice at any time using the Cookie settings link in the footer of every page on this site. Withdrawing consent stops Google Analytics and HubSpot from running on your next page view.

Legal Basis of Processing

We collect and use your personal data based on the following legal grounds:

Consent. In these situations, you have given us consent to process your personal data. For example, when you register for one of our webinars by filling out a web form containing your name and email address.

Legitimate Interest. We process personal data when we have a legitimate interest to do so. Some examples are to maintain and improve our services, inform you of changes to our services, secure our services, and analyze your use of our services and potential sales leads.

Performance of a Contract. This is where we process your personal data to fulfill our contractual obligations to you. For example, we use your personal data to deliver e-learning services you have requested.

Other Legal Bases. There may be times where we are legally obligated to process or share your personal data, such as in response to a subpoena or court order, to protect the vital interests of others, or to defend against legal claims asserted against us.

UPDATE April 29, 2026: SMS COMMUNICATIONS AND MOBILE DATA

1. Collection of SMS and Mobile Contact Data

In addition to the personal information described above, Escalate may collect and process information related to SMS (text message) communications, including:

• Mobile phone number provided by the user or their employer
• Consent and opt-in records, including: Date and time of consent
• Method of consent (e.g., app registration, web form, employer enrollment, or written agreement)
• Preferences related to receiving SMS messages
• Messaging interaction data, including delivery status, timestamps, and user responses (e.g., replies such as “STOP” or “HELP”)

This information is collected only where required to provide SMS-based communications and where appropriate consent has been obtained in accordance with applicable laws.

2. Use of SMS and Consent Data

Escalate uses mobile phone numbers and associated consent data for the following purposes:

• To send transactional or service-related SMS messages, including account notifications, support communications, reminders, and updates related to Escalate services
• To deliver user support interactions, including responding to inquiries or providing coaching support via SMS where applicable
• To manage and maintain consent preferences, including honoring opt-in and opt-out requests
• To improve service delivery, including analyzing message delivery performance and engagement
• To comply with legal and regulatory requirements, including maintaining records of consent and communication history

Escalate does not use SMS data for unauthorized marketing purposes without explicit consent where required by law.

3. Sharing of SMS Data

Escalate may share SMS-related data with limited third parties strictly as necessary to provide SMS services and operate its platform, including:

• Telecommunications providers and messaging platforms (e.g., SMS gateways, carriers) for message delivery
• Service providers and technology vendors that support messaging infrastructure, analytics, or customer support systems
• Employers or organizational partners (such as program sponsors) where the user is participating in an employer-sponsored program, and where such sharing is consistent with applicable agreements and privacy laws
• Regulatory or legal authorities, if required to comply with applicable laws, regulations, or legal processes

All third parties are required to use such data solely for the purpose of providing services to Escalate and are contractually obligated to maintain appropriate confidentiality and security safeguards.

Escalate does not sell SMS-related personal information to third parties.

4. User Choices and Opt-Out

Users may opt out of receiving SMS messages at any time by:

• Replying “STOP” to any SMS message
• Adjusting communication preferences within the Escalate platform (where available)
• Contacting Escalate support

Opting out may limit certain service features that rely on SMS communication.

5. Data Retention and Security

SMS data, including phone numbers and consent records, is retained only as long as necessary to:

• Fulfill the purposes outlined above
• Maintain compliance with legal obligations
• Resolve disputes and enforce agreements

Escalate implements appropriate technical and organizational safeguards to protect SMS data from unauthorized access, disclosure, or misuse, consistent with its broader data protection practices.

Contact Us

If you have any questions or complaints about our use of your personal data as related to our Services, please email us at info@escalateusa.com.