Online Privacy Policy

Updated: October 22, 2026

Elements Financial respects your privacy and is committed to protecting your identity and the information that we collect about you. This Online Privacy Policy (or “Policy”) describes how Elements Financial Federal Credit Union and Elements Wealth Management, together with their affiliates (collectively “Elements Financial”, “we”, “our”, or “us”), collect, use, share, and disclose (“Process”) information that is linked or reasonable to identified or identifiable individuals (“Personal Information”).

This Policy applies to our websites, including www.elements.org and wherever else this Policy is posted (“Websites”), online support services, online and SMS communications, online customer service features, training and educational programs, our digital advertisements, and various other online services we offer and other online interactions you may have with us (our “Online Services”). We adopt this Privacy Policy to fulfill our service commitment to you and to comply with our legal obligations as we process personal information. As you review this Online Privacy Policy, please keep the following general principles in mind:

  • We want to ensure that all individuals are provided with the rights mandated by their governing jurisdiction. Depending on where you live and other factors, our Processing of your Personal Information may be subject to various data privacy laws. For example, residents of California, please see our Supplemental Privacy Notice for California Residents. Connecticut residents, please see our Supplemental Privacy Notice for Connecticut Residents. Residents of Canada, please see our Supplemental Privacy Notice for Residents of Canada. Residents of the European Economica Area (“EEA”), the United Kingdom, and Switzerland, please see our GDPR Notice.
  • If you have any questions about this Policy, the manner in which Elements uses Personal Information, or would like to discuss the rights that you believe may be applicable to you, we encourage you to contact us by email at: privacy@elements.org
  • If you are a U.S. consumer and have a financial product or service with us, our Processing of your Personal Information may also be subject to our Consumer Privacy Policy.
  • This Policy does not apply to information collected or used by any third-party websites or services that may be linked or accessible through our Online Services. Elements Financial has no control over and is not responsible for the content, practices, or privacy policy of such third parties.
  • Our Online Services are not intended for children under 13. We do not knowingly collect Personal Information from children under 13. For more information, please review “How does Elements Financial handle children’s privacy?”, below.
  • Before accessing, using, or interacting with our Online Services, you should review this Privacy Policy. We may change this Policy from time to time and encourage you to review it whenever you interact with us. The most current version of this Policy will govern our Processing of Personal Information and will be located at www.elements.org/online-privacy-policy.

User Consent: By choosing to interact with us and our Online Services, you consent to the Processing of your Personal Information as described in the current version of this Policy. You also promise that you are over 16 years of age. If you do not consent, or are not over 16 years of age, please exit our Online Services and do not use our Online Services or otherwise interact with us online.

What Personal Information Does Elements Financial Collect?

Elements Financial is a credit union. This means we’re like a bank, only better. We offer checking, savings, credit cards, loans, and investments. Profits are returned to our members in the form of fewer fees, higher savings rates, and lower loan rates. Our Online Services support and facilitate our offerings. In order to provide our Online Services, we collect Personal Information from the following categories:

Personal identifiers. In order to provide our Online Services, we may request and collect personal identifiers from you and third parties, including: full name, mailing address, email address, telephone number, account numbers, limited location information, birthdate, username and password, government-issued identifier (e.g., social security number), professional information, and Internet Protocol (IP) address.

User interactions. We collect and store Personal Information about you (including but not limited to name, email address, telephone number, other information you provide, and commercial information) when you communicate with us via email, SMS, through an online portal, using one of the online chat features on our Websites, when you fill out an online form, or enter a contest or promotion offered through our Online Services. We also collect and store the details and content of these communications.

Account and transaction data. We may collect and store information related to member accounts and related transactions, such as account number, credit/debit card number, account history, account balances, loan details, vehicle or property information, credit/debit card purchases, payment or transaction history and details, transfer details, and certain billing statements.

Demographic data. As part of providing certain of our Online Services, we may collect and store certain demographic data, such as: gender, marital status, age, household size, income, and employment information.

Credit report information. In order to provide certain of our Online Services, we may collect credit report information obtained from credit reporting agencies.

Educational tools and events. We may collect information about you if you are use one the educational tools or attend one of the events made available through our Online Services.

Geolocation data. We collect IP-based geolocation data, which may be used to locate the city and state that you are in when you interact with our Websites. The Elements Financial Card Control App may also monitor geolocation on a continuous basis depending on your device settings. You may change your location permissions at any time

Internet or network activity. When you visit our Online Services, we collect technical information about your visit. This may include your IP address, approximate geolocation (derived from the IP address), the devices you use to access our Online Services, which pages you visit on our Websites and which links you click, the length of your sessions, and the sites you visit before and after our Websites. We and our third-party partners may use cookies, pixels, and other similar web technologies to collect this information. We use third-party analytics tools, such as Google Analytics, to assess how users interact with our Online Services, and to improve the user experience.

Sensitive Personal Information. You may provide us certain Personal Information which, under certain privacy laws, is considered “Sensitive Personal Information,” such as a government issued identification number, payment and/or online account login information, race or ethnicity. In addition, and if authorized by the user, the Elements Financial Card Control App periodically collects geolocation information, including precise geolocation, to enable features that prevent and report fraud.

Inferences drawn from other Personal Information. This includes such a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior attitudes, intelligence, abilities and aptitudes.

How Does Elements Financial Use Personal Information?

We use the Personal Information we collect through our Online Services for the following purposes:

Providing you our everyday products and services. We use your Personal Information to administer and perform the Online Services we have agreed to provide you. This may include maintaining and servicing your accounts, verifying your identity, processing transactions, reviewing and processing your applications, responding to your requests, and communicating with you.

Security. We monitor our systems, including your Personal Information, to prevent, detect, or investigate data security incidents or protect against malicious, deceptive, fraudulent, or illegal activity.

Legal. We may use your Personal Information to comply with legal obligations to which we are subject, including regulatory, judicial, tax, accounting, or reporting requirements, as well as our policies and agreements. In addition, under certain circumstances we may use Personal Information to exercise, establish, and defend our legal rights.

Transactional communications. We may use your Personal Information to communicate with you about our ongoing relationship with you. This may include providing account updates, alerts, login verification codes, and similar account or transaction-specific information.

Marketing and advertising. As part of our efforts to grow, we may use your Personal Information to show you relevant advertisements on selected websites you visit. We may also send you marketing communications, such as newsletters and other emails.

Improving and developing our Online Services and other offerings. As part of our ongoing efforts to improve the quality of our Online Services and to develop new services, we may use your Personal Information (including the feedback you provide us) to analyze how customers use our Online Services and how we can make them better. Included in this purpose are our efforts to improve the content of our websites and the way we respond to customer service requests.

Analytics. We use data we collect about your interactions with our Online Services to measure engagement and better understand which features are most useful and interesting to our users. We also use the data to identify visitors to our Websites and measure the effectiveness of our advertising. We may use Google Analytics and other third-party tools to help us conduct this analysis.

General operations. We may use Personal Information as part of our general business operations, such as to analyze credit risk, resolve complaints or disputes, and assess and control risk.

If the Personal Information is aggregated or de-identified in a manner that it can no longer associated with an identified or identifiable person, it is no longer covered by this Policy and may be used for any purpose. If we use de-identified data, we will not attempt to re-identify such data.

Why Does Elements Financial Disclose Personal Information?

We may disclose or share Personal Information with our affiliates, trusted service providers, and other third parties as described below. In particular:

Service Providers. We share Personal Information with a group of trusted third-party service providers we have hired to help us deliver our Online Services and other offerings, including companies that store data, provide our account management platforms, run and collect registration and chat features for online events, offer event kiosk services, deliver referral functionality, and provide enterprise resource planning, and customer relations (including live chat functionality).

Acquisition. If we were to sell or negotiate to sell our business to a buyer or possible buyer, we may transfer Personal Information to a successor or affiliate as part of that transaction.

Legal and safety considerations. We may disclose Personal Information to third parties if we determine that such disclosure is reasonably necessary to (i) comply with the law, including the demands of applicable subpoenas and court orders; (ii) protect any person from death or serious bodily injury; (iii) prevent fraud or abuse of our Online Services or to respond to technical issues; (iv) to verify or enforce our terms of use, our other rights, or other applicable policies; (v) respond to an emergency; (vi) protect our property rights; or, (vii) otherwise protect the rights, property, or security of our customers or third parties.

By your direction, request, or consent. We may disclose or share your Personal Information to further a product or service requested by you or with your consent, direction, or request.

Marketing and advertising. We may share your Personal Information with certain third parties to you show relevant advertisements on selected websites that you visit. We may also send you marketing emails and use third party services to understand how you interact with those emails in order to improve our Online Services and other offerings. Please note: Data obtained through SMS communications or our short code program will not be shared with any third parties for their marketing reasons or purposes.

How Does Elements Financial Protect Personal Information?

We realize that you trust us to protect your Personal Information. We take that trust seriously and maintain physical, electronic, technical and procedural safeguards that are consistent with industry standards to help protect the privacy, accuracy, and reliability of Personal Information and to protect it from loss, misuse, unauthorized access, disclosure, acquisition, exfiltration, alteration and destruction. These steps consider the sensitivity of the Personal Information we Process and the current state of technology.

We also take commercially reasonable steps to ensure that our third-party service providers reasonably protect and secure Personal Information. If we becomes aware that a third-party service provider is using or disclosing Personal Information improperly, we will take necessary and immediate steps to end or correct such improper use or disclosure.

While we attempt to protect the Personal Information in our possession and account for the protection of information provided to our service providers, no security system is perfect and we cannot promise that Personal Information will remain secure in all circumstances. Please do your part to help us keep your Personal Information secure. You are responsible for maintaining the confidentiality of your password(s) and your account(s), and for all activities that occur under your password or account(s). We specifically reserve the right to terminate your access to your online account(s) in the event we learn or suspect you have disclosed your account or password information to an unauthorized third party.

For more information about staying secure online, please visit our Online Security FAQ.

How Long Does Elements Financial Keep Personal Information?

The types and volume of the Personal Information we Process are adequate, relevant, and reasonably necessary for the services we provide our customers. We will only retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, or as otherwise required by law. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

How Does Elements Financial Handle Children’s Privacy?

Protecting children’s privacy is important to us. Our Online Services are not intended or designed for use by individuals under the age of 13. We do not knowingly collect information from individuals under the age of 13 through our Online Services.

Accounts for minors must be jointly owned by a parent or guardian over the age of 18. Mobile and online banking are only available to minors who are 13 years and older and only where permitted by law. For minor accounts owned jointly with a child younger than 13, only the child’s adult parent or guardian who is a co-owner of the account is permitted to access or register for mobile and online banking.

Elements Financial offers access to Banzai Junior to parents of children aged 8 to 12. Banzai Junior is a third-party website and service that provides interactive financial education through real-life scenarios that show users how to make wise decisions when faced with financial dilemmas. Children 8 to 12 may access certain, specially designed sections of the Banzai Junior site only after their parent or legal guardian provides verifiable consent. No Personal Information from, or about, known children under the age of 13 is collected by Elements Financial through the Banzai Junior website. Banzai Junior is a separate, third party and its website is not part of the Online Services offered by Elements Financial. Its privacy practices differ from those of Elements Financial and are described in a separate privacy policy, available here.

Notice of Monitoring

Elements Financial and our third-party service providers and partners may monitor any activity or interaction with our Online Services for business purposes. Our monitoring may include recording your activity while using our Online Services, your sessions on our Websites, information you submit through our Services, and your communications with us through or using the Online Services. Cookies and similar technologies used on our websites may also collect these types of information. This information may be collected and retained by us and our third-party service providers and partners.

If you engage with us using our live chat feature, your conversations may be retained by us and our service providers for business purposes. This may include any interaction between you have with the chat feature, information you input into the chat feature, and the conversations you have using the chat feature.

If you do not consent to the monitoring described in this section and elsewhere in the Policy, please do not use our Online Services.

Like many companies, our Online Services use cookies to distinguish you from other users. A cookie is a small file of letters and numbers that we store on your browser or device. Using cookies helps us to enhance your experience when you use our Online Services, such as by saving your preferences, and also to improve our Online Services, for example by better understanding how people use them. We may also use other, similar technologies to do this. To keep things simple, we will refer to all those technologies as “cookies.” Cookies may be set by us or a third party, including companies that provide analytics, marketing, advertising, and security services.

Cookies We Use. Our Online Services use the following types of cookies.

  • Strictly necessary or essential cookies. These are cookies that are required for the operation of our Online Services and include, for example, cookies that enable you to log into secure areas of our Websites.
  • Analytical or performance cookies. These allow us to recognize and count the number of users and to see how they use our Online Services. This helps us to improve the way our Online Services work, such as by ensuring that users find what they are looking for easily.
  • Functional cookies. These enable us to provide enhanced functionality and personalization and allow us to recognize you when you return to our Services. They enable us to personalize our content for you and remember your preferences.
  • Targeting cookies. These cookies record your visit to our Online Services, the pages you have visited, and the links you have followed. We will use this information to make our services more relevant to your interests. We may also share this information with third parties for this purpose.
  • Advertising cookies. We may share information about your visit(s) to our Websites with a third party that may help us identify and communicate with potential customers.

For more detailed information about the cookies we use, please email us at: [include a privacy specific email address].

Your Cookie Choices. You have the ability to decide whether to accept or reject certain cookies. You can choose which cookies to accept or reject, however you cannot reject “strictly necessary” or “essential” cookies as they are required for the Online Services. You can automatically reject or refuse cookies by configuring settings to automatically reject cookies on your browser or you can manually remove these cookies. Depending on the jurisdiction you are in, you may also be able to switch on or off individual categories of cookies. Where available, those controls are accessible via a pop-up or a link at the footer of the Online Services <Do Not Sell or Share My Personal Information link>

Supplemental Privacy Notice for California Residents

In addition to the information provided in our Online Privacy Policy, the following disclosures apply specifically to California residents whose personal information may be covered by the California Consumer Privacy Act and its implementing rules (“CCPA”). Please note that these rights may not extend to information that is subject the federal Gramm-Leach-Bliley Act.

Our Data Practices

Categories of Personal Information we have collected in the past 12 months. We provide a list of the categories of Personal Information we collect in the section of our Online Privacy Policy entitled, “What Personal Information Does Elements Financial Collect?”.

Categories of sources from which the Personal Information is collected. We describe the sources of the Personal Information we collect in the section of our Online Privacy Policy entitled, “What Personal Information Does Elements Financial Collect?”.

Our business or commercial purposes for collecting Personal Information. We describe the purposes for collecting Personal Information in the section of our Online Privacy Policy entitled, “How Does Elements Financial Use Personal information?”.

Selling or Sharing. Some of the marketing and advertising practices we describe in our Online Privacy Policy may be considered a “sale”/”sharing” under the CCPA or constitute “targeted advertising”. We may sell or share (and may have sold or shared during the preceding 12 months) the following categories of personal information relevant to individuals over the age of 16: identifiers, internet or network activity information, geolocation data. Our “Do Not Sell or Share My Personal Information” link <link> gives you the ability to opt out of these practices at any time. You can also make a “Do Not Sell or Share” request to us via the contact information we provide below.

Sensitive Personal Information. Some of the Personal Information we collect or that you may provide to us (e.g., financial account information) may be considered “sensitive personal information” under the CCPA. We use this information to provide you our products and services. We do not use it for any purposes for which you are able to request limitation of disclosure under the CCPA (“Right to Limit”).

Your CCPA Rights. The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

The Right to Know. The CCPA gives California residents the right to ask us about our processing of the Personal Information we have collected, used and disclosed covering the period from January 1, 2022, through the date we receive your verifiable consumer request, or such shorter period as you may specifically request. To do so, you can submit a verifiable consumer request (“Request to Know”). Once we receive and confirm your verifiable consumer request, we will disclose to you: (a) the categories of Personal Information we collected about you; (b) the categories of sources for the Personal Information we collected about you; (c) our business or commercial purpose for collecting that Personal Information; (d) the categories of third parties with whom we share that Personal Information; and, (e) the specific pieces of Personal Information we collected about you (also called a Data Portability Request).

Correction and Deletion Request Rights. California residents have the right to request that we correct inaccurate Personal Information or delete the Personal Information that we collected from you and retained (“Requests to Correct” or “Requests to Delete”). Once we receive and confirm your verifiable consumer request, we will correct or delete (and direct our service providers to correct or delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if we or our service providers need to retain your Personal Information for one of the purposes listed in the CCPA, which include: (a) completing the transaction for which we collected the Personal Information; (b) providing a product or service that you requested, or taking actions reasonably anticipated within the context of our ongoing business relationship with you; (c) detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible for such activities; and, (d) complying with applicable state and federal regulations or complying with a legal obligation or otherwise using the Personal Information, internally, in a lawful manner.

Right to Limit. You have the right to request that we limit our use and disclosure of your Sensitive Personal Information to only those purposes specifically enumerated in the CCPA. Currently, we do not use or disclose your Sensitive Personal Information for purposes other than those expressly permitted by the CCPA. Should this change in the future, we will update this California Privacy Notice and provide you with methods to limit the use and disclosure of Sensitive Personal Information.

No Retaliation or Discrimination. We will not retaliate or discriminate against you for exercising any of your CCPA rights.

Notice of Financial Incentive. We may offer certain financial incentives permitted by the CCPA that can result in different prices, rates or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects.

How You Can Exercise Your Rights. You may make a verifiable customer request for access or data portability twice within a 12-month period. To exercise the access, data portability, limit use, correction, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Mailing your request to: Elements Financial
    225 S. East St., Ste. 300
    Indianapolis, IN 46202-4509
  • Emailing us at: privacy@elements.org

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. If the request is made through an agent, we reserve the right to require a signed authorization or verification of the agent’s identity from you in order protect the privacy of the Personal Information requested. You may also make a verifiable consumer request on behalf of your minor child.

What is a “Verifiable Consumer Request”? Before we fulfill a request to know, delete, or correct Personal Information, we must verify the consumer making the request matches the person whose information we have collected. Generally, your verifiable request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot provide you with information sought in a Request to Know or comply with a Request to Correct or Delete if we cannot verify your identity or authority to make the request and/or confirm the Personal Information relates to you. Therefore, we reserve the right to request additional information from you to allow us to verify your request before we respond.

Response Timing and Format. We will let you know that we received your request within ten (10) days of receipt and give you information regarding how we will process your request and will endeavor to provide a response to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver our written response electronically by email. Any disclosures we provide will cover the period from January 1, 2022, through the date we received your verifiable consumer request, or such shorter period as you may specifically request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Your Choices Regarding Our Sale or Sharing of Your Personal Information. You have the right to direct us to not sell your personal information or share your personal information for the purposes of targeted advertising, which is showing advertising on other websites or other media based on your browsing history with our websites (the “right to opt-out”). Consumers who opt-in to our sharing of personal information for these purposes may opt-out of future such sharing at any time.

To exercise the right to opt-out of the sale or sharing of your personal information, you (or your authorized representative) may submit a request to us by (i) visiting the “Do Not Sell or Share My Personal Information” link in the footer of our websites, (ii) setting your browser to refuse all or some browser cookies, or to alert you when cookies are being sent, or by (iii) sending us an email with your request to privacy@elements.org. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our websites. You can find more information about cookies at http://www.allaboutcookies.org.

You can also use the Global Privacy Control (GPC) signal in supported browsers to opt out automatically. If you use GPC, you'll need to turn it on in each browser you use, which will opt you out of the sale or sharing of your personal information. If you participate in a financial incentive program as described below that requires the “sale” or “sharing” of your personal information and we receive your request, we will request that you confirm that you no longer wish to participate in the financial incentive program or that you wish us to ignore the privacy control signal.

Once you make an opt-out request, we will wait at least 12 months before asking you to reauthorize our “sale” and/or “sharing” of your personal information, as applicable.

Supplemental Privacy Notice for Connecticut Residents

We adopt following Supplemental Privacy Notie for Connecticut Residents to comply with Connecticut law, including the Connecticut Data Protection Act (“CTDPA”). In addition to the information provided in our Online Privacy Policy, this Supplemental Privacy Notice applies specifically to consumers who reside in the State of Connecticut. Please note that these rights may not extend to information that is subject the federal Gramm-Leach-Bliley Act.

How We Collect, Use, and Disclose Personal Information. We collect, use, and disclose Personal Information as described in our Online Privacy Policy.

Rights and Choices of Connecticut Residents. The CTDPA grants Connecticut residents additional rights over their Personal Information. This section describes those rights and explains how to exercise them.

Right to Opt-Out of Targeted Advertising and the Sale of Your Personal Information. You have the right to direct us to not sell your personal information or share your personal information for the purposes of targeted advertising, which is showing advertising on other websites or other media based on your browsing history with our websites (the “right to opt-out”). Consumers who opt-in to our sharing of personal information for these purposes may opt-out of future such sharing at any time.

To exercise the right to opt-out of the “sale” or “sharing” of your personal information, you (or your authorized representative) may submit a request to us by (i) visiting the “Do Not Sell or Share My Personal Information” link in the footer of our websites, (ii) setting your browser to refuse all or some browser cookies, or to alert you when cookies are being sent, or by (iii) sending us an email with your request to privacy@elements.org. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our websites. You can find more information about cookies at http://www.allaboutcookies.org.

You can also use the Global Privacy Control (GPC) signal in supported browsers to opt out automatically. If you use GPC, you'll need to turn it on in each browser you use, which will opt you out of the sale or sharing of your personal information. If you participate in a financial incentive program as described below that requires the “sale” or “sharing” of your personal information and we receive your request, we will request that you confirm that you no longer wish to participate in the financial incentive program or that you wish us to ignore the privacy control signal.

Access Rights. Connecticut residents have the right to request that we disclose certain information to them about our collection and use of their Personal Information, such as (a) confirmation of whether or not we are processing your Personal Information; and, (b) access to your Personal Information that we process. Once we receive and confirm a Connecticut resident’s consumer request, we will provide confirmation/access to the applicable Personal Data.

Data Correction Rights. Connecticut residents have the right to request that we correct inaccuracies in their Personal Information, considering the nature of their Personal Information and the Processing of their Personal Information. Once we receive and confirm your request, we will commercially reasonable efforts to correct the inaccurate Personal Information.

Deletion Rights. Connecticut residents have the right to request that we delete their Personal Information, subject to certain exceptions.

Data Portability Right. Connecticut residents have a right to request that we provide a portable copy of the Personal Information that they provided to us. Once we receive and confirm a consumer request, we will provide a copy of your Personal Data to the extent reasonably and technically feasible.

No Retaliation or Discrimination. We will not retaliate or discriminate against you for exercising any of your CTDPA rights.

How to Exercise Your Access, Correction, Deletion, and Data Portability Rights. Connecticut residents may make a “verifiable consumer request” related to their own Personal Information, or the Personal Information of their minor child. A “verifiable consumer request” must: (a) provide sufficient information that allows us to reasonably verify that the Connecticut resident is the person about whom the Personal Information relates or an authorized representative; and, (b) describe the request with sufficient detail that allows us to properly understand, evaluate and respond to it. This does not require creating an account with us, but we may require authentication that is reasonable in light of the nature of the Personal Data requested, such as using an existing account to contact us. If we cannot verify your request, we cannot respond to it.

To exercise the rights described above, please submit a verifiable consumer request to us by either:

  • Mailing your request to: Elements Financial
    225 S. East St., Ste. 300
    Indianapolis, IN 46202-4509
  • Emailing us at: privacy@elements.org

We will try to respond within 45 days of receipt. If we require more time, of up to 90 total days, we will notify you within 45 days of receiving your request and explain our reason. We do not charge a fee to process or respond to a request unless it is excessive, manifestly unfounded, or made more than once in a 12-month period. If we determine that your request warrants a fee, we notify you and provide a cost estimate before completing your request. Alternatively, we may decline to respond to the request and notify you of our reason. If we are unable to comply with your request, our response will explain why.

If we decide that we cannot comply with your initial request, that you have the right to appeal our decision by contacting us at the address or email, above. The appeal should clearly indicate that it is an appeal of an initial request and should include the initial request along with our response explaining why we cannot comply with the request. We will review all appeals and provide a response within 60 days of receiving the appeal, including the reasons we can or cannot comply with the request, as applicable. If we cannot comply with a request after an appeal is made, you may submit a complaint to the Connecticut Attorney General, which can be found here: https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page.

Supplemental Privacy Notice for Residents of Canada

Under certain circumstances and subject to applicable data protection laws, in addition to the rights described in this Policy, you may also be entitled to request additional information regarding our data governance practices, including details regarding what information is collected about you, the categories of persons who have access to your information, and how long your information will be retained for. You may also be entitled to request that we cease communicating your information, or de-index any hyperlink attached your name that provides access to your personal information by a technological means.

GDPR Notice

If you live in the European Economic Area (“EEA”) or the United Kingdom (“UK”), our collection and use (“Process” or “Processing”) of your Personal Information is governed by the General Data Protection Regulation (“GDPR”) and the UK’s version of the GDPR (“UK GDPR”). In addition, if you are a resident of Switzerland, your Personal Information will be treated in accordance with the terms of this Section, except to the extent otherwise required by the Swiss Federal Data Protection Act. This notice supplements our Online Privacy Policy with information specific to those laws. In general, when we are Processing your Personal Information, we are acting as a “controller”, as that term is defined in the GDPR.

Legal Bases of Our Processing. Article 6 of the GDPR permits the Processing of Personal Information only when there is a legal basis for it. Below (in italics) are each of the Processing purposes we list in our Online Privacy Policy, followed by the GDPR legal basis for our Processing:

Provide you services, manage and administer our relationship with you

  • Legal basis: to perform a contract

Provide you with information, communications or services you have requested and to contact you in relation to any queries you may submit

  • Legal basis: to perform a contract

Conduct analytics to improve our services; to understand how you interact with our Websites, improve our Websites, personalize your experience and to provide you services

  • Legal basis: necessary for our legitimate interests

Present, optimize, and maintain the security of our Websites and their contents

  • Legal basis: necessary for our legitimate interests

Register, maintain, and provide notifications to you about your account and relationship with us

  • Legal basis: necessary for our legitimate interests

Detect and prevent fraud or other crimes

  • Legal basis: necessary for our legitimate interests

Manage your accounts, orders, invoices, and payments

  • Legal basis: necessary for our legitimate interests

Analytics and marketing

  • Legal bases: necessary for our legitimate interests and, where applicable, consent

Manage and provide technical support and customer service

  • Legal basis: necessary for our legitimate interests

Your Rights. As a “data subject” under the GDPR or similar law, you have the following rights:

  • To receive confirmation as to whether we have Personal Information concerning you and, if so, obtain (i) a copy of the personal information we are Processing, and (ii) information concerning the nature and Processing of the Personal Information;
  • To request that we correct or supplement your Personal Information without undue delay;
  • To request us to delete your Personal Information if (i) no longer necessary, (ii) you have withdrawn consent, (iii) you have objected to Processing, or (iv) your Personal Information has been unlawfully collected;
  • To restrict Processing Personal Information if you contest its accuracy, the lawfulness of its Processing, or if we no longer need it;
  • To object to the Processing of your Personal Information if Processing is based on our legitimate interests or for direct marketing purposes;
  • To be informed about the existence of automated decision making, including profiling, and about its significance and consequences on you;
  • To request a transfer of your Personal Information to a third party in certain circumstances;
  • To lodge a complaint with the data protection authority in your jurisdiction if you believe our Processing of your personal information violates the GDPR; and
  • To withdraw consent from our Processing of your Personal Information, the legal basis for which is your consent.

You may exercise these rights by contacting us at: privacy@elements.org

Data Transfers

We Process and transfer Personal Data outside of the EEA, Switzerland, and the UK, primarily in the United States. Whenever we transfer your personal information outside the EEA, Switzerland, or UK., we apply safeguards that are equivalent to those of your home jurisdiction.

Contact us

It’s important to us that you understand our privacy practices. If you have any questions about this Online Privacy Policy, please feel free to reach out by using the Contact Us methods available on our website. You may also write, call, or email us at:

Elements Financial
225 S. East St., Ste. 300
Indianapolis, IN 46202-4509
800-621-2105
privacy@elements.org