Last updated on August 17, 2022.
This Policy describes the information that we gather on or through Elloe Services, how we use and disclose such information, and the steps we take to protect such information. By visiting the Website, or by purchasing or using the Elloe Services, you accept the practices described in this Policy.
In this Policy, “Elloe,” “us” and “we” refers to Elloe AI and its affiliates. The “Website” means Elloe’s websites (including Elloe.AI, Elloe.net, Elloe.io and related domains and subdomains), and the “Elloe Services” means Elloe’s customer service platform and related products, applications and services. “Customer Data” means any data or information provided by you in connection with your use of the Elloe Services.
1. Information we collect
When you use the Elloe Services, we collect different types of information in order to provide the Elloe Service in accordance with the Agreement and to operate and optimize our business.
We collect information about you when you register to use the Elloe Services and provide contact information to us via instant messaging, email, mail, or through the Elloe Services. This information you provide may include your username, first and last name, email address, mailing address and phone number as well as other information, such as geographic area or preferences.
Furthermore, when you purchase the Services, we will also collect transaction information, credit card or other billing information.
All information that is related to a specific identifiable person is considered Personal Data” as further defined in applicable legislation. Since Elloe has no direct relationship with the individuals whose Personal Data is processed as part of the Customer Data, the Customer is responsible for compliance with applicable data protection legislation. As part of the Agreement, Elloe requires the Customer to enter into a Data Processing Agreement.
Information you provide to us
As part of our marketing and advertisement activities, we collect personal information of you when you interact with our advertising messages, such as when you request or sign-up for content (for example, product demos, events, webinars and reports) on our website or other third-party sites that we use for marketing and advertisement purposes. By interacting with our advertising messages, requesting access to content on our website, and providing us with your contact details, you authorise us to process the personal information that you have disclosed to us on that occasion, such as your full name, email address, phone number, company name, and job title.
Automatically Collected Information
You may access or register for the Elloe Services through certain third-party sites and platforms and we may collect information when you interact with our advertisements and other content on third-party sites or platforms.
By authorizing us to connect with a third-party platform, you authorize us to access and store your name, email address(es), date of birth, gender, current city, profile picture URL, and other information that the third-party platform makes available to us, and to use and disclose it in accordance with this Policy.
Information on Equity Holders and holders of financial and legal rights
We collect information about each shareholder, warrant holder, option holder or other types of persons (legal or natural) who hold an ownership, financial or legal interest in Elloe (collectively “Equity Holders”) in order to identify you and register such warrants, shares, equity, or finance and legal rights. For this purpose, we may collect your name, email, phone, equity/capital details, holding company details, log details, and additional shareholder documents.
If the Equity Holder grants proxy to a third party and/or registers the attendance of an advisor, we will collect and process personal data about such persons. We will also register the contact details of a nominated contact person for legal entities who 1) are Equity Holders or 2) hold other financial or legal rights.
2. Use of information
We use your information in the following ways:
The information we collect is used to operate, maintain, optimize, improve and provide the Elloe Service, to provide service and information to you and to provide customer support. Furthermore, we use information to control unauthorized use or abuse of the Elloe Services, or otherwise detect, investigate or prevent activities that may violate our policies or be illegal. Your Customer Data is processed only in accordance with instructions.
We use data to contact you for administrative purposes such as customer service, to address intellectual property infringement, privacy violations or defamation issues related to the Customer Data or Personal Data posted on the Elloe Service or with newsletters, updates on promotions and events, relating to products and services offered by us and by third parties we work with. Your opt-out options for promotional communications are described below under “Your Choices.”
Information is used to analyze usage trends and preferences, administer or optimize the Elloe Services, monitor usage or traffic patterns (including to track users’ movements around the Elloe Services) and gather demographic information about our user base as a whole in order to improve the Elloe Services, and to develop new products, services, feature, and functionality.
Equity management and financial and legal rights management
The information we collect from Equity Holders and others with financial and legal rights are used to identify and register your, or the company whom you represent, rights in relation to Elloe for accountability purposes.
We may use your information for the purpose of forwarding (legal/formal) notices to you, such as the general meeting, and to enable you to exercise your administrative rights.
We process the personal data to comply with our legal obligations (such as requirements needed for bookkeeping purposes), and with shareholders or third parties’ rights set out in the Danish Companies Act, as well as shareholders’ agreement or other agreements. The processing of your information will be also based on based on Elloe’s legitimate interests in being able to identify our shareholders and appropriate fulfil its management obligations in relation to its Equity Holders, as well as in relation to the fulfilment of agreements between you (or the company you represent) and Elloe or between you and other shareholders.
3. Sharing of information
Unless described in this Policy or based on your separate consent, we will not intentionally disclose the Personal Data or Customer Data that we collect or store on the Elloe Service to third parties. We may share information to third parties in the following circumstances:
Third-Party Service Providers
We work with third-party service providers who provide website, development, marketing, hosting, maintenance, and other services for us. These service providers may have access to, or process Personal Data or Customer Data as part of providing those services for us. We share only Personal Data which is reasonably necessary for the service providers, and we make sure they are under obligation to protect the data. You can see a list of our 3rd-party service providers here.
Law and regulation
We may share Personal Data when we in good faith believe that access, use, preservation or disclosure of such information is necessary to satisfy applicable law, regulation, legal process or enforceable governmental request, or in order to enforce an Agreement, or to protect against imminent harm to rights, property or safety for us, the users or the public.
We reserve our right to disclose Personal Data or other information that we in good faith believe is necessary to protect ourselves against liability, fraudulent, abusive, or unlawful uses or activity, third-party claims or allegations, or in order to protect the security or integrity of the Elloe Service and any facilities or equipment used to make the Elloe Service available.
Information that is not Personal Data, meaning not related to an identifiable person, may be shared with third parties for various purposes, including for business or marketing purposes; or for compliance with reporting obligations; or to assist in understanding our customers’ and visitors’ interests, habits, and usage patterns.
Information provided by you in a public area of the Elloe Services may be shared with all customers, users or visitors that can access that information.
Change of Ownership
We may share and/or transfer Personal Data if we become involved in a merger, acquisition, bankruptcy, or any form of sale of some or all of our assets.
4. Your choices
Access and updates
We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Elloe Services. You may access, review, correct, update, change or delete your information at any time by contacting us. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required.
You may update, correct, or delete your Account information and preferences at any time by accessing your Account settings page. Please note that we may store information for backups, archiving, prevention of fraud and abuse, analytics, due to legal obligations, or if we believe that we have a legitimate reason to do so.
We will not send you any commercial information unless you at a previous point have actively agreed to such. If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by contacting us. It may take up to ten (10) business days for us to process your request.
We may provide you with the opportunity to “opt-out” of having Personal Data stored at Elloe. If you decide to opt-out, we may not be able to provide certain features of the Elloe Services to you.
Since Elloe has no direct relationship with the Customers’ users/customers, a person who seeks access to, or wants to correct or delete inaccurate data or withdraw consent for further contact must contact the Customer directly. We will delete, amend or block access to any Personal Data that we are storing only if we receive a written request to do so from the Customer who is responsible for such Personal Data, unless we have a legal right to retain such Personal Data. We reserve the right to retain a copy of such data for archiving purposes, or to defend our rights in litigation.
5. California privacy rights
Provided you are a California resident, California law dictates that you may request information about any sharing of Personal Data with third-parties for direct marketing purposes. Please see instructions and regulation in the Shine the Light Law. Requests shall be made in writing to the Elloe support team.
California law also requires that inform how we respond to a “Do Not Track” signal which some browsers offer to send. Since there is no uniform way to handle these signals, Elloe has not found a best practice, and as such respond to the “Do Not Track” signals. When the industry has decided on a best practice, we intent to follow such.
a) Minors privacy
As stated in our Terms of Service/ the Agreement, the Elloe Services are not for children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access the Elloe Services. Should we learn that Personal Data has been collected through the Elloe Services from children under 18 years of age without verifiable parental consent, we will seek to delete this information.
To the extent that a minor has posted content on the Elloe Services which is available for a group of people, the minor has the right to have this content deleted or removed using options described in this Policy. Even though we will do our outmost to permanently remove content, we cannot guarantee the deletion will be complete.
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymize Personal Data.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us as set forth in the “How to Contact Us” section.
If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
d)Data storage and transfer
The Elloe Services are hosted in the United States or EU. EU customers’ databases will be hosted in our EU datacenter, however, regardless hereof please note that you may be transferring your Customer Data and Personal Data to the United States for storage and processing by our service providers listed here. We will comply with GDPR requirements providing adequate protection for the transfer of Personal Data from EU to the U.S.
Elloe does not own, control or direct the use of any of the Customer Data stored or processed by a Customer or user via the Elloe Services. Elloe is largely unaware of what Customer Data is actually being stored or made available by a Customer to the Elloe Service and does not directly access such Customer Data unless authorized by the Customer, or as necessary to provide the Elloe Services to the Customer and its customers/ users.
Elloe is not responsible for the content of the Personal Data contained in the Customer Data or other information stored on its servers or its subcontractors’ servers at the discretion of the Customer nor is Elloe responsible for the manner in which the Customer collects, handles, distributes or otherwise processes such information.
We reserve the right to change this Policy at any time. Please revisit this page periodically to stay aware of any changes to this Policy. If we make changes, we will post them and will indicate the Policy’s new effective date. If we make material changes to this Policy, we will notify you by email or through notice in the Elloe Services.
Your continued use of the Elloe Services after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.
g) Contact and complaint
Please contact us with any questions or comments about this Policy, your Personal Data, our use and disclosure practices, or your consent choices by email to [email protected] If you have any concerns or complaints about Elloe’s handling of your Personal Data, please contact us and we will do our best to meet your concerns. Other than that, you have the right to bring a complaint to the proper data protection authority.
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