PRIVACY POLICY

Updated at April 15th, 2024
Ela (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how your
personal information is collected, used, and disclosed by Ela .
This Privacy Policy applies to our app, and its associated subdomains (collectively, our “Service”) alongside
our application, Ela . By accessing or using our Service, you signify that you have read, understood, and
agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy
Policy and our Terms of Service.

Definitions and key terms
To help explain things as clearly as possible in this Privacy Policy, every time any of these terms are
referenced, are strictly defined as:
● Cookie: small amount of data generated by a website and saved by your web browser. It is used to
identify your browser, provide analytics, remember information about you such as your language
preference or login information.
● Company: when this policy mentions “Company,” “we,” “us,” or “our,” it refers to Ela Holdings oü,
(Lumemarja tee 51), that is responsible for your information under this Privacy Policy.
● Country: where Ela or the owners/founders of Ela are based, in this case is Estonia
● Customer: refers to the company, organization or person that signs up to use the Ela Service to
manage the relationships with your consumers or service users.
● Device: any internet connected device such as a phone, tablet, computer or any other device that can
be used to visit Ela and use the services.
● IP address: Every device connected to the Internet is assigned a number known as an Internet protocol
(IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be
used to identify the location from which a device is connecting to the Internet.
● Personnel: refers to those individuals who are employed by Ela or are under contract to perform a
service on behalf of one of the parties.
● Personal Data: any information that directly, indirectly, or in connection with other information —
including a personal identification number — allows for the identification or identifiability of a natural
person.
● Service: refers to the service provided by Ela as described in the relative terms (if available) and on this
platform.
● Third-party service: refers to advertisers, contest sponsors, promotional and marketing partners, and
others who provide our content or whose products or services we think may interest you.
● App/Application: Ela app, refers to the SOFTWARE PRODUCT identified above.
● You: a person or entity that is registered with Ela to use the Services.

What Information Do We Collect?

We collect information from you when you visit our app, register on our site, place an order, subscribe to our
newsletter, respond to a survey or fill out a form.
● Name / Username
● Email Addresses
● Age
● Password
We also collect information from mobile devices for a better user experience, although these features are
completely optional:
● Photo Gallery (Pictures): Granting photo gallery access allows the user to upload any picture from their
photo gallery, you can safely deny photo gallery access for this platform.
When does Ela use end user information from
third parties?
Ela will collect End User Data necessary to provide the Ela services to our customers. End users may
voluntarily provide us with information they have made available on social media websites. If you provide us
with any such information, we may collect publicly available information from the social media websites you
have indicated. You can control how much of your information social media websites make public by visiting
these websites and changing your privacy settings.
When does Ela use customer information from
third parties?
We receive some information from the third parties when you contact us. For example, when you submit your
email address to us to show interest in becoming a Ela customer, we receive information from a third party
that provides automated fraud detection services to Ela . We also occasionally collect information that is
made publicly available on social media websites. You can control how much of your information social
media websites make public by visiting these websites and changing your privacy settings.
Do we share the information we collect with
third parties?
We may share the information that we collect, both personal and non-personal, with third parties such as
advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or
whose products or services we think may interest you. We may also share it with our current and future
affiliated companies and business partners, and if we are involved in a merger, asset sale or other business
reorganization, we may also share or transfer your personal and non-personal information to our
successors-in-interest.
We may engage trusted third party service providers to perform functions and provide services to us, such as
hosting and maintaining our servers and the app, database storage and management, e-mail management,

storage marketing, credit card processing, customer service and fulfilling orders for products and services
you may purchase through the app. We will likely share your personal information, and possibly some
non-personal information, with these third parties to enable them to perform these services for us and for
you.
We may share portions of our log file data, including IP addresses, for analytics purposes with third parties
such as web analytics partners, application developers, and ad networks. If your IP address is shared, it may
be used to estimate general location and other technographics such as connection speed, whether you have
visited the app in a shared location, and type of the device used to visit the app. They may aggregate
information about our advertising and what you see on the app and then provide auditing, research and
reporting for us and our advertisers.
We may also disclose personal and non-personal information about you to government or law enforcement
officials or private parties as we, in our sole discretion, believe necessary or appropriate in order to respond
to claims, legal process (including subpoenas), to protect our rights and interests or those of a third party, the
safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to
otherwise comply with applicable court orders, laws, rules and regulations.
Where and when is information collected from
customers and end users?
Ela will collect personal information that you submit to us. We may also receive personal information about
you from third parties as described above.
How Do We Use The Information We Collect?
Any of the information we collect from you may be used in one of the following ways:
● To personalize your experience (your information helps us to better respond to your individual needs)
● To improve our app (we continually strive to improve our app offerings based on the information and
feedback we receive from you)
● To improve customer service (your information helps us to more effectively respond to your customer
service requests and support needs)
● To process transactions
● To administer a contest, promotion, survey or other site feature
● To send periodic emails
How Do We Use Your Email Address?
By submitting your email address on this app, you agree to receive emails from us. You can cancel your
participation in any of these email lists at any time by clicking on the opt-out link or other unsubscribe option
that is included in the respective email. We only send emails to people who have authorized us to contact
them, either directly, or through a third party. We do not send unsolicited commercial emails, because we
hate spam as much as you do. By submitting your email address, you also agree to allow us to use your
email address for customer audience targeting on sites like Facebook, where we display custom advertising
to specific people who have opted-in to receive communications from us. Email addresses submitted only
through the order processing page will be used for the sole purpose of sending you information and updates
pertaining to your order. If, however, you have provided the same email to us through another method, we
may use it for any of the purposes stated in this Policy. Note: If at any time you would like to unsubscribe
from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
How Long Do We Keep Your Information?
We keep your information only so long as we need it to provide Ela to you and fulfill the purposes described
in this policy. This is also the case for anyone that we share your information with and who carries out
services on our behalf. When we no longer need to use your information and there is no need for us to keep
it to comply with our legal or regulatory obligations, we’ll either remove it from our systems or depersonalize
it so that we can’t identify you.
How Do We Protect Your Information?
We implement a variety of security measures to maintain the safety of your personal information when you
place an order or enter, submit, or access your personal information. We offer the use of a secure server. All
supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then
encrypted into our Payment gateway providers database only to be accessible by those authorized with
special access rights to such systems, and are required to keep the information confidential. After a
transaction, your private information (credit cards, social security numbers, financials, etc.) is never kept on
file. We cannot, however, ensure or warrant the absolute security of any information you transmit to Ela or
guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by a
breach of any of our physical, technical, or managerial safeguards.
Could my information be transferred to other
countries?
Ela is incorporated in Estonia. Information collected via our app, through direct interactions with you, or from
use of our help services may be transferred from time to time to our offices or personnel, or to third parties,
located throughout the world, and may be viewed and hosted anywhere in the world, including countries that
may not have laws of general applicability regulating the use and transfer of such data. To the fullest extent
allowed by applicable law, by using any of the above, you voluntarily consent to the trans-border transfer and
hosting of such information.
Is the information collected through the Ela
Service secure?
We take precautions to protect the security of your information. We have physical, electronic, and managerial
procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your
information. However, neither people nor security systems are foolproof, including encryption systems. In
addition, people can commit intentional crimes, make mistakes or fail to follow policies. Therefore, while we
use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If
applicable law imposes any non-disclaimable duty to protect your personal information, you agree that
intentional misconduct will be the standards used to measure our compliance with that duty.
Can I update or correct my information?

The rights you have to request updates or corrections to the information Ela collects depend on your
relationship with Ela . Personnel may update or correct their information as detailed in our internal company
employment policies.
Customers have the right to request the restriction of certain uses and disclosures of personally identifiable
information as follows. You can contact us in order to (1) update or correct your personally identifiable
information, (2) change your preferences with respect to communications and other information you receive
from us, or (3) delete the personally identifiable information maintained about you on our systems (subject to
the following paragraph), by cancelling your account. Such updates, corrections, changes and deletions will
have no effect on other information that we maintain, or information that we have provided to third parties in
accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your
privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your
identity before granting you profile access or making corrections. You are responsible for maintaining the
secrecy of your unique password and account information at all times.
You should be aware that it is not technologically possible to remove each and every record of the
information you have provided to us from our system. The need to back up our systems to protect
information from inadvertent loss means that a copy of your information may exist in a non-erasable form
that will be difficult or impossible for us to locate. Promptly after receiving your request, all personal
information stored in databases we actively use, and other readily searchable media will be updated,
corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably and technically
practicable.
If you are an end user and wish to update, delete, or receive any information we have about you, you may do
so by contacting the organization of which you are a customer.
Personnel
If you are a Ela worker or applicant, we collect information you voluntarily provide to us. We use the
information collected for Human Resources purposes in order to administer benefits to workers and screen
applicants.
You may contact us in order to (1) update or correct your information, (2) change your preferences with
respect to communications and other information you receive from us, or (3) receive a record of the
information we have relating to you. Such updates, corrections, changes and deletions will have no effect on
other information that we maintain, or information that we have provided to third parties in accordance with
this Privacy Policy prior to such update, correction, change or deletion.
Sale of Business
We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of
all or substantially all of the assets of Ela or any of its Corporate Affiliates (as defined herein), or that portion
of Ela or any of its Corporate Affiliates to which the Service relates, or in the event that we discontinue our
business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar
proceeding, provided that the third party agrees to adhere to the terms of this Privacy Policy.
Affiliates
We may disclose information (including personal information) about you to our Corporate Affiliates. For
purposes of this Privacy Policy, “Corporate Affiliate” means any person or entity which directly or indirectly
controls, is controlled by or is under common control with Ela , whether by ownership or otherwise. Any
information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate
Affiliates in accordance with the terms of this Privacy Policy.
Governing Law
This Privacy Policy is governed by the laws of Estonia without regard to its conflict of laws provision. You
consent to the exclusive jurisdiction of the courts in connection with any action or dispute arising between the
parties under or in connection with this Privacy Policy except for those individuals who may have rights to
make claims under Privacy Shield, or the Swiss-US framework.
The laws of Estonia, excluding its conflicts of law rules, shall govern this Agreement and your use of the app.
Your use of the app may also be subject to other local, state, national, or international laws.
By using Ela or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree
to this Privacy Policy, you should not engage with our app, or use our services. Continued use of the app,
direct engagement with us, or following the posting of changes to this Privacy Policy that do not significantly
affect the use or disclosure of your personal information will mean that you accept those changes.
Your Consent
We’ve updated our Privacy Policy to provide you with complete transparency into what is being set when you
visit our site and how it’s being used. By using our Ela , registering an account, or making a purchase, you
hereby consent to our Privacy Policy and agree to its terms.
Links to Other Websites
This Privacy Policy applies only to the Services. The Services may contain links to other websites not
operated or controlled by Ela . We are not responsible for the content, accuracy or opinions expressed in
such websites, and such websites are not investigated, monitored or checked for accuracy or completeness
by us. Please remember that when you use a link to go from the Services to another website, our Privacy
Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a
link on our platform, is subject to that website’s own rules and policies. Such third parties may use their own
cookies or other methods to collect information about you.
Cookies
Ela uses “Cookies” to identify the areas of our app that you have visited. A Cookie is a small piece of data
stored on your computer or mobile device by your web browser. We use Cookies to enhance the
performance and functionality of our app but are non-essential to their use. However, without these cookies,
certain functionality like videos may become unavailable or you would be required to enter your login details
every time you visit the app as we would not be able to remember that you had logged in previously. Most
web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be
able to access functionality on our app correctly or at all. We never place Personally Identifiable Information
in Cookies.
Blocking and disabling cookies and similar

technologies
Wherever you’re located you may also set your browser to block cookies and similar technologies, but this
action may block our essential cookies and prevent our app from functioning properly, and you may not be
able to fully utilize all of its features and services. You should also be aware that you may also lose some
saved information (e.g. saved login details, site preferences) if you block cookies on your browser. Different
browsers make different controls available to you. Disabling a cookie or category of cookie does not delete
the cookie from your browser, you will need to do this yourself from within your browser, you should visit your
browser’s help menu for more information.
Remarketing Services
We use remarketing services. What Is Remarketing? In digital marketing, remarketing (or retargeting) is the
practice of serving ads across the internet to people who have already visited your app. It allows your
company to seem like they’re “following” people around the internet by serving ads on the websites and
platforms they use most.
Kids’ Privacy
We do not address anyone under the age of 13. We do not knowingly collect personally identifiable
information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your
child has provided Us with Personal Data, please contact Us. If We become aware that We have collected
Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to
remove that information from Our servers.
Changes To Our Privacy Policy
We may change our Service and policies, and we may need to make changes to this Privacy Policy so that
they accurately reflect our Service and policies. Unless otherwise required by law, we will notify you (for
example, through our Service) before we make changes to this Privacy Policy and give you an opportunity to
review them before they go into effect. Then, if you continue to use the Service, you will be bound by the
updated Privacy Policy. If you do not want to agree to this or any updated Privacy Policy, you can delete
your account.
Third-Party Services
We may display, include or make available third-party content (including data, information, applications and
other products services) or provide links to third-party websites or services (“Third- Party Services”).
You acknowledge and agree that Ela shall not be responsible for any Third-Party Services, including their
accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other
aspect thereof. Ela does not assume and shall not have any liability or responsibility to you or any other
person or entity for any Third-Party Services.
Third-Party Services and links thereto are provided solely as a convenience to you and you access and use
them entirely at your own risk and subject to such third parties’ terms and conditions.

Tracking Technologies
● Google Maps API
Google Maps API is a robust tool that can be used to create a custom map, a searchable map, check-in
functions, display live data synching with location, plan routes, or create a mashup just to name a few.
Google Maps API may collect information from You and from Your Device for security purposes.
Google Maps API collects information that is held in accordance with its Privacy Policy
Information about General Data Protection
Regulation (GDPR)
We may be collecting and using information from you if you are from the European Economic Area (EEA),
and in this section of our Privacy Policy we are going to explain exactly how and why is this data collected,
and how we maintain this data under protection from being replicated or used in the wrong way.
What is GDPR?
GDPR is an EU-wide privacy and data protection law that regulates how EU residents’ data is protected by
companies and enhances the control the EU residents have, over their personal data.
The GDPR is relevant to any globally operating company and not just the EU-based businesses and EU
residents. Our customers’ data is important irrespective of where they are located, which is why we have
implemented GDPR controls as our baseline standard for all our operations worldwide.
What is personal data?
Any data that relates to an identifiable or identified individual. GDPR covers a broad spectrum of information
that could be used on its own, or in combination with other pieces of information, to identify a person.
Personal data extends beyond a person’s name or email address. Some examples include financial
information, political opinions, genetic data, biometric data, IP addresses, physical address, sexual
orientation, and ethnicity.
The Data Protection Principles include requirements such as:
● Personal data collected must be processed in a fair, legal, and transparent way and should only be
used in a way that a person would reasonably expect.
● Personal data should only be collected to fulfil a specific purpose and it should only be used for that
purpose. Organizations must specify why they need the personal data when they collect it.
● Personal data should be held no longer than necessary to fulfil its purpose.
● People covered by the GDPR have the right to access their own personal data. They can also request a
copy of their data, and that their data be updated, deleted, restricted, or moved to another organization.
Why is GDPR important?
GDPR adds some new requirements regarding how companies should protect individuals’ personal data that
they collect and process. It also raises the stakes for compliance by increasing enforcement and imposing
greater fines for breach. Beyond these facts it’s simply the right thing to do. At Ela we strongly believe that
your data privacy is very important and we already have solid security and privacy practices in place that go
beyond the requirements of this new regulation.
Individual Data Subject’s Rights – Data Access,
Portability and Deletion
We are committed to helping our customers meet the data subject rights requirements of GDPR. Ela
processes or stores all personal data in fully vetted, DPA compliant vendors. We do store all conversation
and personal data for up to 6 years unless your account is deleted. In which case, we dispose of all data in
accordance with our Terms of Service and Privacy Policy, but we will not hold it longer than 60 days.
We are aware that if you are working with EU customers, you need to be able to provide them with the ability
to access, update, retrieve and remove personal data. We got you! We’ve been set up as self service from
the start and have always given you access to your data and your customers data. Our customer support
team is here for you to answer any questions you might have about working with the API.
Contact Us
Don’t hesitate to contact us if you have any questions.
● Via Email: support@ela.live