Privacy Policy

Effective 2026-05-18

Introduction.
This Privacy Policy applies to all of the products, services, websites, and applications, including, but not limited to, Proximity, offered by Elmer Holdings LLC and its affiliates, except where otherwise noted. We refer to those products, services, websites, and applications collectively as the “Services” in this Privacy Policy. Unless otherwise noted, Services are provided by Elmer Holdings LLC (the “Company”).

The Company respects the privacy of every individual and is committed to protecting your privacy. This Privacy Policy provides information on the manner in which your personal information obtained through your purchase, download, installation, or use of, or registration for, the Services is processed and used with respect to the Services. The Company uses your personal information only in ways that are compatible with this Privacy Policy. In addition to reviewing this Privacy Policy, please read our Master Subscription Agreement. Your use of the Services constitutes your agreement to be bound by the Master Subscription Agreement and this Privacy Policy. If you do not agree to the Master Subscription Agreement and this Privacy Policy, you should not use the Services.

Information Collected and Used.
The Company may collect personal information from you (for example, your name, postal address, e-mail address, and other data) when you provide personal data in conjunction with creating an account for the Services or using the Services – for example when you contact us, sign up to the Service and create your individual profile, or sign up to an event that we host, organize or sponsor, you provide us with personal data. This would typically include your name, workplace and position, contact details (such as e-mail, phone and address), account login details (e-mail address and other authenticators are automatically hashed), as well as any other data you choose to provide when you use our Service, contact us, or interact with others via our Service. You may also provide us with your profile photo, calendar integration, time-zone, skills, device, general location, and activity logs and data, as well as your preferences, characteristics and objectives for using the Service. You may also send us a “Contact Us” or support requests, initiate a support chat, or provide us with feedback, reviews, or responses to our surveys or promotions, including by submitting an online form on our Service or social media channels, by posting on any of our online public forums or communities, by sending an e-mail to any of our designated addresses, or any other form of communication. Such data may include details on an issue you are experiencing, contact information and any other documentation, screen recording, screenshots or other information. The Company also generally collects personally identifying information with your specific knowledge and consent.

The Company reserves the right to use information gathered by it for any and all purposes. The Company may share e-mail addresses and all other information with our affiliates and with other companies. If you do not wish to have your information shared, write to us at [email protected]. If you do not wish to receive future marketing or promotional communications from us by e-mail, simply follow the unsubscribe instructions contained within the e-mail. You will not be able to unsubscribe from all types of communications from us by e-mail while you have an active, valid account because the Company must be able to send operational communications to you via e-mail.

Co-Collaborator Access.
You recognize that, when using the Services, there may be instances where there are multiple users from one or more organizations that access a collaboration space. In such instances, you recognize that all users authorized to access such collaboration spaces will have access to information that you upload to, or share within, the collaboration spaces. The Company has no control over how authorized users in a collaboration space may use information that is uploaded to the collaboration spaces, but all authorized users in a collaboration space are required to abide by the Company’s Master Subscription Agreement and this Privacy Policy.

Third-Party Access.
The Company allows access to its database by third parties that provide the Company with services, such as technical maintenance, but only for the purpose of, and to the extent necessary, to provide those services. The Company may provide subcontractors that have a need for such access to facilitate the Services and who are subject to a reasonable written agreement governing the use and security of customer data with access to customer data solely for the purposes of providing the Services. However, the Company does not bear any responsibility for any actions or policies of third parties.

If you choose to purchase Services, the Company may forward your information to third parties for services such as e-mail and postal communications, credit card processing and order fulfillment.

If you provide information about yourself to the Company in areas of its website that are managed or participated in by third parties, then the information may be used by the Company and by such third parties, each pursuant to its own policies. Depending on your uses of the Services, you may be using third party services provided by Google, Microsoft, Zoom, Amazon Web Services, and others. For details, please see the Third-Party Services Addendum attached hereto.

There also may be occasions when the Company is legally required to provide access to its database in order to cooperate with police investigations or other legal proceedings. In those instances, the information is provided only for that purpose. While your individual information is protected as outlined above, the Company reserves the right to use, transfer, sell, and share aggregated, anonymous data about its users as a group for any business purpose, such as analyzing usage trends and seeking compatible advertisers and partners.

Use of Information.
Your information is stored in a secured database and is used for purposes of providing you with information requested by you, providing for a follow up with you in connection with materials you request, and as part of our mailings and solicitations to prospective customers, allowing us to contact you for administrative purposes, for example, to tell you about changes to our Privacy Policy, carrying out our obligations and enforcing our rights arising from contracts entered into between you and the Company, including for billing and collection, providing you with notice about your account, and fulfilling any other purpose for which you provide your information. The information you provide also may be utilized for market research purposes, for project planning, or for development of prospect lists for marketing. If you have agreed to receive marketing communications, you may always opt out at a later date. You have the right at any time to stop the Company from contacting you for marketing purposes or giving your data to its affiliates. If you no longer with to be contacted for marketing purposes, please send us an e-mail stating the same to [email protected]. Please note that all e-mail that originates from the Company will either display the proximity.live domain name or an affiliated domain name. If you receive an unsolicited e-mail that you believe is connected with us in any way, please forward the e-mail (as an attachment) to [email protected].

Disclosure of Personal Information.
Except as set forth in this Privacy Policy, the Company does not share, rent, or sell personal information about you with other people or companies. The Company reserves the right to use in any manner and also to disclose any non-personal information that it collects, including, but not limited to, cookie and traffic data. The Company may release personal information when it believes that doing so is appropriate to comply with the law (for example, to respond to a lawful subpoena, warrant, or court order), to enforce or apply its policies, to initiate, render, bill, and collect for amounts owed to the Company, to protect its rights or property, to protect its users from fraudulent, abusive, or unlawful use of its Services, or if it reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.

Information about the Company’s users, including personal information, will be disclosed as part of any merger or acquisition, creation of a separate business to provide the Services, sale or pledge of Company assets, as well as in the event of any insolvency, bankruptcy, or receivership in which personal information would be transferred as one of the business assets of the Company. The Company reserves the right to transfer your personal information to a third party in the event of a corporate sale, merger, acquisition, dissolution, or similar event.

Data Protection Rights.
We are headquartered in the United States and have service providers that are located in the United States and other countries. As such, your personal data may be transferred to the United States or other locations outside your state, province, or country where privacy laws are not as protective as those in your state, province or country. We will however take all necessary measures to protect your personal data in accordance with this privacy notice and applicable law.

Your data may be stored or processed in multiple locations around the world, for as long as necessary in accordance with our reasonable business needs; as necessary for the performance of our Service; for supporting and exercising our legitimate interests; and in accordance with our legal obligations.

Every user is entitled to the following:

• The Right to Access – You have the right to request copies of your personal data from the Company, which may charge you a small fee for this service.

• The Right to Rectification – You have the right to request that the Company correct any information you believe is inaccurate, and you have the right to request that the Company complete information you believe is incomplete.

• The Right to Erasure – You have the right to request that the Company erase your personal data, under certain conditions.

• The Right to Restrict Processing – You have the right to request that the Company restrict the processing of your personal data, under certain conditions.

• The Right to Object to Processing – You have the right to object to the Company’s processing of your personal data, under certain conditions.

• The Right to Withdraw Consent – You have the right to withdraw any consent to data processing previously provided to the Company.

• The Right to Data Portability – You have the right to request that the Company transfer the data that it has collected to another organization, or directly to you, under certain conditions.

• The Right to Complain to a Data Protection Authority – You have right to right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. The Company responds to all requests that it receives from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

To exercise these rights, please e-mail [email protected].

Unsolicited E-mail (Spam).
You should be aware that unscrupulous marketers can sometimes “harvest” your e-mail address directly from your computer or another person’s address book or even obtain your e-mail address through programs that automatically search webpages and e-mail traffic for e-mail addresses. The Company also may disclose or exchange with others information you have provide to it if it believes that the law requires it to do so or if it is necessary to protect the rights or property of the Company, its affiliate companies, its staff, or its users.

Information Automatically Collected.
The Company automatically receives and collects certain types of information whenever you visit or otherwise interact with the Services. For example, like many similar types of Services, the Company reserves the right to use “cookies” to obtain certain types of information when your web browser accesses and goes through the Services. Cookies are text files placed on your device to collect standard Internet log information and visitor behavior information. When you interact with the Services, the Company may collect information from you automatically through cookies or similar technology. For further information visit allaboutcookies.org. The Company uses this information to monitor and understand the usage and performance of its Services, to enhance its customers’ search experiences, and to determine aggregate information about the Company’s user base and usage patterns—all of this helps the Company make improvements to the Services. The Company also uses your IP address to help diagnose problems with its server, to administer its Services, and to communicate with you after you have sent communications to the Company. If you send communications to the Company, from time to time, the Company may use information about your preferences and interests to send updates to you about the Company, the Services, listings, special offers, or information that may be of interest to you. Some third-party websites occasionally serve you cookies, as well. The Company does not have control over cookies placed by others. If you do not want any cookies, your web browser likely includes an option that allows you to not accept them. However, if you sent your browser to refuse cookies, some portions of the Services may not function properly. This Privacy Policy covers the use of cookies by the Company and does not cover any subsequent use of cookies by any third-party advertisers. If you wish to opt-out of advertising by third party advertisers, available third-party tools to opt-out include the Digital Advertising Alliance and the Network Advertising Initiative.

Do Not Track.
The Company does not track the users of its Services over time and across third-party websites in order to provide targeted advertising. The Company therefore does not respond to Do Not Track signals. However, some third-party websites do keep track of your browsing activities when they serve you content, which enables them to tailor information that is presented to you. If you are visiting third-party websites, you should become familiar with the websites’ tracking policies. The Company makes no representations and accepts not responsibility for the tracking activities of any third party.

Sensitive Personal Data.
The Company does not knowingly collect or obtain from third parties any data revealing or concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health or sexual activity, sexual orientation, genetic data, or biometric data.

Security.
The Company will use reasonable precautions to keep the information disclosed to it secure and not to allow unauthorized disclosure such information to any third parties. However, the Company is not responsible for any breach of security or for any actions of any third parties that may receive the information. The Company takes commercially reasonable steps and appropriate measures (as determined in its sole and absolute discretion) to limit access to your personal information to people who need it to do their jobs. For example, if the Company needs to mail something to you, it must share your name and address with a direct mail company. The Company limits such third parties in their access and use of your personal information. The Company cannot guarantee the protection of information against interception, misappropriation, misuse, or alteration or that your information may not be disclosed or accessed by accidental circumstances or by the unauthorized acts of others. The Company has no control over the security of other websites on the Internet that you might visit, interact with, or from which you buy goods or services.

Linked Websites.
The Services include links to other websites, applications, or other services operated and maintained by separate companies. Similarly, authorized users in collaboration spaces may share links to other websites, applications, or other services operated and maintained by separate companies. The Company has no responsibility for linked websites, applications, or other services operated and maintained by separate companies. Those websites, applications, or other services may have different privacy policies. If you click through to another website, application, or service, you should check the privacy policy of that website, application, or service, which will usually (but not always) be posted on the website or otherwise in conjunction with the application or service. The Company is not responsible for the privacy policies of other websites, applications, or services.

Children.
The Services are directed to adults and are not directed to children under the age of 18. The Company complies with the Children’s Online Privacy Protection Act and does not permit registration by, and will not knowingly collect personally identifiable information from, anyone under the age of 18. Individuals under the age of 18 are not permitted to use or otherwise access the Services. If your children disclose information about themselves in publicly accessible areas of the Services, they may receive unsolicited messages from other parties. Accordingly, you should tell them not to do so. This Privacy Policy will be posted in conjunction with the Company’s Services.

Changes to Information.
The Company needs your help in making sure that your personal information is correct in its systems. Please notify the Company of changes to your name, address, title, telephone number, billing information, or e-mail address. You may correct your personal information or select the option not to receive future marketing or promotional communications from the Company (for example, mailings, calls, etc.) by sending an e-mail to the Company at the address below. In the event you elect not to receive future marketing or promotional communications from the Company, it will endeavor to remove your name from its contact list for marketing or promotional communications; however, it only promises to endeavor to remove you from any marketing or promotional lists controlled by the Company. The Company shall have no liability under this Privacy Policy for its failure to accomplish this objective.

Your Consent.
By using the Services, you consent to the collection, use, processing, and disclosure of information in accordance with this Privacy Policy. By using the Services, you should also be aware that any personally identifiable information that you submit may be able to be read, collected, or used by others of the Services, and could be used to send you unsolicited messages. The Company is not responsible for the personally identifiable information that you choose to submit through your use of the Services. If your personally identifiable information changes, or if you no longer desire the Services, you may correct, update, delete, or deactivate your personally identifiable information by doing so in your account or by sending an e-mail to the Company’s Privacy Policy Coordinator at [email protected]. The Company reserves the right to modify or amend this Privacy Policy at any time and in its sole and absolute discretion. If the Company changes this Privacy Policy, it will post any changes on this webpage, and your continued use of the Services constitutes your acceptance and agreement to any revisions to this Privacy Policy.

IP Address.
Your Internet Protocol (“IP”) address is usually associated with the place from which you access the Internet, like your home Internet Service Provider, your company, or your university. The Company may use your IP address to help diagnose problems with its server, gather broad demographic information, and administer its Services. In some cases, an IP address can be considered personally identifiable information.

California Privacy Rights.
If you are a California resident, California Civil Code Section 1798.83 permits you to request information with respect to the disclosure of your personal information by the Company to third parties for such third parties’ direct marketing purposes. The Company is only required to respond to a particular customer’s request for such information once during a calendar year. To make such a request, please send an e-mail to [email protected].

Changes to the Privacy Policy.
The Company keeps this Privacy Policy under regular review and places any updates on this webpage. This Privacy Policy was last updated on May 18, 2026.

Contacting the Company.
If you have other concerns or questions about any aspect of this Privacy Policy, you may also e-mail our Privacy Policy Coordinator at [email protected].

 
Third-Party Services Addendum

The following third-party services and privacy practices may be invoked by your uses of the Services.

  • Google Authentication Integration (via Google Meet REST API): We offer authentication integration with Google. To enable this feature, we utilize OAuth 2.0 for authorization. This means that you will be asked to grant our application permission to access your Google account.
    • Data Collection and Usage:
      • We only use OAuth to authenticate on your behalf.
      • We collect basic profile information authorized by you and Google. This typically includes your Full Name, Email Address and Profile Picture URL
    • Permissions: The specific permissions requested via OAuth are limited to the following:
      • Authentication to Services
    • Data Security: We adhere to industry best practices for data security and comply with all applicable privacy laws and regulations.
    • Transparency and Control: You can revoke our application’s access to your Google account at any time through your Google account settings.
    • Google privacy practices are covered under Google’s main privacy policy: https://policies.google.com/privacy.
  • Microsoft Authentication Integration (via Microsoft’s identity platform (formerly Azure AD)): We offer authentication integration with Microsoft. To enable this feature, we utilize Microsoft’s identify platform for authorization. This means that you will be asked to grant our application permission to access your Microsoft account (Microsoft Entra ID).
    • Data Collection and Usage:
      • We collect basic profile information authorized by you and Microsoft. This typically includes your Full Name, Email Address and Profile Picture URL
      • Authentication tokens: We receive authentication tokens from Microsoft to verify your identity. These tokens do not grant us access to your Microsoft password.
    • Permissions: The specific permissions requested via Microsoft’s identity platform are limited to the following:
      • Authentication to Services
    • Data Security: We adhere to industry best practices for data security and comply with all applicable privacy laws and regulations.
    • Transparency and Control: You can revoke our application’s access to your Microsoft account at any time through your Microsoft account settings.
    • Microsoft’s privacy practices are covered under Microsoft’s main privacy policy: https://www.microsoft.com/en-us/privacy/privacystatement.
  • Live Chat Support via Tawk.to: We offer real-time customer support via tawk.to
    • Data Collection and Usage:
      • We capture information voluntarily provided via tawk.to such as Name, Email Address and the contents/transcripts of the chat session in order to facilitate customer support inquiries.
      • Information collected automatically when the widget loads includes items such as IP address, device/browser information and time/date of the inquiry.
    • tawk.to serves as a data processor for Company (data controller). tawk.to’s privacy practices are covered under their privacy policy: https://www.tawk.to/privacy-policy/
  • Other Meeting Content and Metadata: When you use the Company for audio/video conferencing, we may collect and store meeting content, which may include:
    • Meeting Data: This refers to information generated during the meeting itself and chat messages sent via the Company’s native chat and messaging capabilities.
    • Meeting Metadata: This includes information about the meeting, such as meeting ID, participant list (names, email addresses), start and end times, meeting duration, and topic.
    • Recordings: If you choose to record a meeting, the recording and associated metadata will be stored and accessible through your Company account.
      • This data is collected and processed to enable core features of the Company Services, including: facilitating real-time communication, enabling collaboration, providing recording and playback functionality screen sharing content, transcripts (if enabled), and enhancing the user experience within the Company’s virtual environment.
    • We utilize one or more of the following technologies for audio/video conferencing: AWS Chime, Microsoft Azure Communication Services (ACS), and Microsoft Teams.