Privacy Policies

Information Security Policy

Last updated: 9/6/2024

1. Introduction

The goal of the Elephas Information Security Program is to protect the Confidentiality, Integrity, and Availability of the data employed within the organization while providing value to the way we conduct business. Protection of the Confidentiality, Integrity, and Availability are basic principles of information security, and can be defined as:

• Confidentiality – Ensuring that information is accessible only to those entities that are authorized to have access, many times enforced by the classic “need to know” principle.
• Integrity – Protecting the accuracy and completeness of information and the methods that are used to process and manage it.
• Availability – Ensuring that information assets (information, systems, facilities, networks, and computers) are accessible and usable when needed by an authorized entity.

Elephas has recognized that our business information is a critical asset and as such our ability to manage, control, and protect this asset will have a direct and significant impact on our future success.

This document establishes the framework from which other information security policies may be developed to ensure that the enterprise can efficiently and effectively manage, control and protect its business information assets and those information assets entrusted to Elephas by its stakeholders, partners, customers and other third parties.

The Elephas Information Security Program is built around the information contained within this policy and its supporting policies. For additional information regarding our Information Security
program, please visit https://trustcenter.elephas.com. 

2. Purpose

The purpose of the Elephas Information Security Policy is to describe the actions and behaviors required to ensure that due care is taken to avoid inappropriate risks to Elephas, its business partners, and its stakeholders.

3. Audience

The Elephas Information Security Policy applies equally to any individual, entity, or process that interacts with any Elephas Information Resource.

4. Responsibilities

Executive Management

• Ensure that an appropriate risk-based Information Security Program is implemented to protect the confidentiality, integrity, and availability of all Information Resources collected or maintained by or on behalf of Elephas.
• Ensure that information security processes are integrated with strategic and operational planning processes to secure the organization’s mission.
• Ensure adequate information security financial and personnel resources are included in the budgeting and/or financial planning process.

Information Security Team

• Manage compliance with all relevant statutory, regulatory, and contractual requirements.
• Participate in security related forums, associations and special interest groups.
• Assess risks to the confidentiality, integrity, and availability of all Information Resources collected or maintained by or on behalf of Elephas.
• Facilitate development and adoption of supporting policies, procedures, standards, and guidelines for providing adequate information security and continuity of operations.
• Ensure that Elephas has trained all personnel to support compliance with information security policies, processes, standards, and guidelines. Train and oversee personnel with significant responsibilities for information security with respect to such responsibilities.
• Ensure that appropriate information security awareness training is provided to company personnel, including contractors.
• Implement and maintain a process for planning, implementing, evaluating, and documenting remedial action to address any deficiencies in the information security policies, procedures, and practices of Elephas.
• Develop and implement procedures for testing and evaluating the effectiveness of the Elephas Information Security Program in accordance with stated objectives.
• Develop and implement a process for evaluating risks related to vendors and managing vendor relationships.
• Report annually, in coordination with the Information Security Team, to Executive Management on the effectiveness of the Elephas Information Security Program, including progress of remedial actions.
• Ensure compliance with applicable information security requirements.
• Formulate, review and recommend information security policies.
• Approve supporting procedures, standards, and guidelines related to information security.
• Assess the adequacy and effectiveness of the information security policies and coordinate the implementation of information security controls.
• Review and manage the information security policy waiver request process.
• Identify and recommend how to handle non-compliance.
• Provide clear direction and visible management support for information security initiatives.
• Promote information security education, training, and awareness throughout Elephas, and initiate plans and programs to maintain information security awareness.
• Educate the team and staff on ongoing legal, regulatory and compliance changes as well as industry news and trends.
• Identify significant threat changes and vulnerabilities.
• Evaluate information received from monitoring processes.
• Review information security incident information and recommend follow-up actions.

All Employees, Contractors, and Other Third-Party Personnel

• Understand their responsibilities for complying with the Elephas Information Security Program.
• Formally sign off and agree to abide by all applicable policies, standards, and guidelines that have been established.
• Use Elephas Information Resources in compliance with all Elephas Information Security Policies.
• Seek guidance from the Information Security Team for questions or issues related to information security.

Policy

Elephas maintains and communicates an Information Security Program consisting of topic-specific policies, standards, procedures and guidelines that:

• Serve to protect the Confidentiality, Integrity, and Availability of the Information Resources maintained within the organization using administrative, physical and technical controls.
• Provide value to the way we conduct business and support institutional objectives.
• Comply with all regulatory and legal requirements, including:
  • All applicable federal, state, and local laws or requirements.

The information security program is reviewed no less than annually or upon significant changes to the information security environment.

5. Enforcement

Personnel found to have violated this policy may be subject to disciplinary action, up to and including termination of employment, and related civil or criminal penalties.

Any vendor, consultant, or contractor found to have violated this policy may be subject to sanctions up to and including removal of access rights, termination of contract(s), and related civil or criminal penalties.

Cookie Policy

Last updated: 9/25/2023

1. Introduction

This Cookie Policy outlines how cookies and similar technologies are used by Elephas when you visit our website. This policy provides information on the types of cookies we use, their purpose, and how you can manage your cookie preferences.

2. What Are Cookies?

Cookies are small text files that are placed on your computer or mobile device when you visit a website. They are widely used to make websites work efficiently and to provide information to website owners. Cookies can be used for various purposes, including remembering user preferences, analyzing website traffic, and delivering targeted advertising.

3. Types of Cookies We Use

3.1. Essential Cookies

These cookies are necessary for the proper functioning of our website. They enable you to navigate our website and use its essential features. Without these cookies, certain services and functionalities may not be available.

3.2. Performance Cookies

Performance cookies collect information about how visitors use our website, such as which pages are visited most often and if they encounter error messages. These cookies do not collect personally identifiable information (PII), and the data they collect is used to improve the performance and user experience of our website.

3.3. Functional Cookies

Functional cookies allow our website to remember choices you make, such as your language preference, and provide enhanced, personalized features. These cookies may also be used to provide services you have requested, such as commenting on a blog post or remembering login details.

4. How We Use Cookies

We use cookies for the following purposes:

• To ensure the proper functioning of our website.
• To analyze website traffic and improve our website's performance.
• To remember your preferences and provide personalized content.

5. Information We Collect

Personal Information:

• Name
• Email address
• Phone number
• Organization
• Any other information you voluntarily provide

Non-Personal Information:

• Usage data (e.g., pages visited, time spent on the Website)
• Device information (e.g., IP address, browser type, operating system)
• Cookies and tracking technologies

6. Managing Your Cookie Preferences

You have the option to manage your cookie preferences. You can typically do this through your web browser settings. Please note that if you choose to disable cookies, certain parts of our website may not function correctly, and your user experience may be impacted.

6.1. Browser Settings

Most web browsers allow you to control and manage cookies through their settings. You can typically find these settings in the "Options" or "Preferences" menu of your browser. The exact steps for managing cookies may vary depending on your browser.

6.2. Cookie Consent Tools

When you visit our website, you may be presented with a cookie consent banner or pop-up that provides you with options to accept or decline cookies. You can adjust your preferences through these tools.

7. Changes to this Cookie Policy

We may update this Cookie Policy to reflect changes in our use of cookies or in response to regulatory changes. Any updates to this policy will be posted on our website with a revised effective date.

8. Contact Information

If you have any questions or concerns about our Cookie Policy or the use of cookies on our website, please contact us at any means listed below. By using our website, you consent to the use of Cookies described in this policy.

• Email: customersupport@elephas.com
• Phone: (608) 622-7954
• Mailing Address: 1 Erdman Place Suite 100, Madison, WI 53717