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PRIVACY POLICY

This privacy notice for Ekluv ('Company', 'we', 'us', or 'our',), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services'), such as when you:

  • Visit our website at https://www.ekluv.com, or any website of ours that links to this privacy notice

  • Download and use our mobile application (Ekluv), or any other application of ours that links to this privacy notice

  • Engage with us in other related ways, including any sales, marketing, or events

 

 

Questions or concerns?

Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@ekluv.com.

 

 

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by reading the relevant section in this Privacy Policy.

 

What personal information do we process?

When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Ekluv and the Services, the choices you make, and the products and features you use.

 

Do we process any sensitive personal information?

We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.

 

How do we process your information?

We process your information to provide, improve, and administer our Services.  We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

 

How do we keep your information safe?

We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.  Your information is held in our Google Firebase and RevenueCat projects.

 

 

 

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.  The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include, but is not limited to the following:

  • names

  • email addresses

  • usernames

  • contact or authentication data

  • age

  • gender

  • sexuality

  • job titles

  • education background

  • ethnicity

  • location

  • religious beliefs

  • religious status

  • marital status

  • children status

  • drinking status

  • smoking status

  • dietary preferences

  • personality traits

  • languages spoken

  • body shape

  • height

  • hair length

  • hair colour

  • traits

  • hobbies

  • foods you like

  • drinks you like

  • sports you like

  • films and TV shows you like

  • books you like

  • music you like

  • preferences related to any of the above bullet points

 

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Apple. You may find their privacy notice link(s) here: https://www.apple.com/legal/privacy/en-ww/.

 

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

  • Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.  Please note this may compromise the extent to which you are able to use our services.

  • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.  Please note this may compromise the extent to which you are able to use our services.

  • Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.

  • Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.  Please note this may compromise the extent to which you are able to use our services.

 

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

 

 

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics may be collected automatically when you visit our Services.

We may automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

 

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).

  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

  • Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

 

 

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, and to communicate with you.  We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

  • To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.

  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

  • To deliver targeted advertising to you. We may process your information to develop and display personalised content and advertising tailored to your interests, location, and more.

  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

  • To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

  • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

 

 

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary to provide you with services.

 

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time by going to the “Settings” tab and pressing “Delete my account”.

  • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

    • Send users information about special offers and discounts on our products and services

    • Develop and display personalised and relevant advertising content for our users

    • Analyse how our services are used so we can improve them to engage and retain users

    • Support our marketing activities

    • Diagnose problems and/or prevent fraudulent activities

    • Understand how our users use our products and services so we can improve user experience

  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

 

 

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

  • Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

 

 

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

 

 

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

 

 

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

 

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

 

 

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@ekluv.com or report the user via the means provided in our mobile application services.

 

 

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us via email at support@ekluv.com.

We will consider and act upon any request in accordance with applicable data protection laws.

 

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by signing into the the Mobile Application, going to the “Settings” tab and pressing “Delete my account”.

 

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

 

Account Information

If you would at any time like to review or change the information in your account you can update this via the Mobile Application in the “Profile” or “Preferences” tab.

 

If you would at any time like to terminate your account, you can to to our Mobile Application, sign in to your profile, go to the Settings tab, press "Delete my account”.  Please note, you must complete onboarding for this option to become available.

 

Upon your request to terminate your account, we will delete your account and information from our active databases.  Some information may remain in the database, but flagged as requiring deletion such as chat data.  When information is flagged as requiring deletion, this will be done manually or systematically by Ekluv.

 

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to decline cookies. If you choose to remove cookies or decline cookies, this could affect certain features or services of our Services.

 

 

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

 

12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

 

California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please contact us via email at support@ekluv.com

 

Users under the age of 18 are not permitted to use our app.  However, if you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us via email at support@ekluv.com and include the email address associated with your account and a statement that you reside in California.  Alternatively, you can to to our Mobile Application, sign in to your profile, go to the Settings tab, press "Delete my account”.  Please note, you must complete onboarding for this option to become available.  We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

 

CCPA Privacy Notice

The California Code of Regulations defines a 'resident' as:

  • every individual who is in the State of California for other than a temporary or transitory purpose and

  • every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as 'non-residents'.

If this definition of 'resident' applies to you, we must adhere to certain rights and obligations regarding your personal information.

 

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

  • Identifiers including contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

  • Personal information categories listed in the California Customer Records statute including name, contact information, education, employment, employment history, and financial information

  • Protected classification characteristics under California or federal law including gender and date of birth

  • Commercial information including transaction information, purchase history, financial details, and payment information

  • Internet or other similar network activity including browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements

  • Geolocation data including device location

  • Audio, electronic, visual, thermal, olfactory, or similar information including images and audio, video or call recordings created in connection with our business activities

  • Professional or employment-related information including business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

  • Education Information including student records and directory information

  • Inferences drawn from other personal information including inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

  • We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

    • Receiving help through our customer support channels

    • Participation in customer surveys or contests

    • Facilitation in the delivery of our Services and to respond to your inquiries.

 

 

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be 'selling' of your personal information.

Ekluv has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Ekluv will not sell personal information in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.  Users can delete their own data the App, by going to the “Settings” tab and pressing “Delete my account”.  Please note, you must complete onboarding for this option to become available.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

  • whether we collect and use your personal information

  • the categories of personal information that we collect

  • the purposes for which the collected personal information is used

  • whether we sell your personal information to third parties

  • the categories of personal information that we sold or disclosed for a business purpose

  • the categories of third parties to whom the personal information was sold or disclosed for a business purpose

  • the business or commercial purpose for collecting or selling personal information.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

 

 

Other privacy rights

  • You may object to the processing of your personal information by deleting your account

  • You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.

  • You can designate an authorised agent to make a request under the CCPA on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with the CCPA.

 

To exercise these rights, you can contact us via email at support@ekluv.com. If you have a complaint about how we handle your data, we would like to hear from you.

 

 

13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time.  If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

 

 

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at support@ekluv.com

 

 

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please either use the functionality in the app to update or delete your account by going to the “Settings” tab and pressing “Delete my account”.  Please note, you must complete onboarding for this option to become available.

 

 

Last updated June 26, 2024

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