Introduction
Eloelo values Your trust. In order to honour that trust, Eloelo adheres to ethical standards in gathering, using, and safeguarding any information You provide. Eloelo understands and recognises Your right to confidentiality and is committed to protecting and preserving Your privacy. Subject to the provisions of this privacy policy (“Policy”) and applicable law, Eloelo may collect, receive, store, deal in, handle and share Personal Information including Sensitive Personal Data and Non-Personal Information pertaining to the Users of the Platform/ Services. This Policy outlines the information Eloelo may process and/or use to improve the User experience while using the Platform/Services.
This Policy governs Your use of the application ‘EloElo’ (“Application”),https://www.eloelo.in(“Website”) and the other platforms provided, owned or operated by the Company (together the “Platform”).
Please read this privacy policy (“Policy”) carefully before using the Platform, along with the Terms of Use (“ToU”) provided on the Platform, forming part of the User Agreement. Your use of the Platform, or services in connection with the Platform or Services, or registrations with us through any mode or use of any products including that of SD cards, tablets or other storage/transmitting device shall signify your acceptance to this Policy and Your agreement to be legally bound by the same. Your use of the Platform in any electronic form or device shall be bound by the terms and conditions enumerated and agreed upon hereunder with Your wilful and free consent.
If You wish not to agree with any of the terms and conditions of this Policy, kindly refrain from using the Platform or the Services.
Definitions
Key Definitions: For the purposes of this Policy, unless the context otherwise requires:
"Corporate Affiliate" shall mean any person or entity which directly or indirectly controls, is controlled by or is under common control with the Company, whether by ownership or otherwise.
Company: when this policy mentions “Company,” “we,” “us,” or “our,” it refers to Greenhorn Wellness Pvt. Ltd., #BHIVE HSR Sector 6, L-148, 5th Main, Sector 6 HSR Layout, Bangalore, Karnataka, 560102 that is responsible for your information under this Privacy Policy.
“Information” shall mean collectively Non-Personal Information and Personal Information;
“Non-Personal Information” shall mean and include:
geographic location of a User;
internet protocol address of the User
;details of the User’s telecom service provider or internet service provider;
the type of internet browser used by the User;
device information (such as the operating system of the device and hardware model) and the website you last visited before visiting the Platform; or
clickstream data relating to your activity on the Platform, including but not limited to the duration of your stay on the Platform, date and time of your access of the Platform.
“Personal Information” means any information relating to the Users which, either directly or indirectly, in combination with other information available or likely to be available with the Company, is capable of identifying such Users and includes Sensitive Personal Data of the User;
“Sensitive Personal Data” in relation to a User means personal data or information of a User which consists of information relating to:
-password;
financial information such as bank account or credit card or debit card or other payment instrument details;
physical, physiological and mental health condition;
medical data, records and history;
biometric information;any details relating to the above clauses as provided to the Company for providing Services; and
any information received under the above clauses by the Company for processing, or stored or processed under lawful contract or otherwise:
provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Sensitive Personal Data or Personal Information for the purposes of this Policy.
Terms used but not defined herein, shall have the meanings ascribed to such terms and expressions in the ToU.
Information collected by the Company
Eloelo obtains Information (including Personal Information) when You download, register, or use the Platform/ Services provided by Eloelo. When You register with Eloelo or use the Platform, You generally provide (a) Your name, age, email address, phone number, and password; (b) information that is typically provided when You contact us for help; (c) information You enter into our system when using the Platform; and (d) bank account or credit card or debit card or other payment instrument details while making payments on the Platform (if applicable). The abovementioned information is necessary to allow Eloelo to operate the Platform and provide the Services to the Users. Without it, Eloelo may not be able to provide You with all the requested Services/ access to the Platform, which could result in You having to cease and desist using the Platform.
The Platform may collect certain Information automatically, including, but not limited to, the type of mobile device You use, Your mobile device’s unique device ID, the IP address of Your mobile device, Your mobile operating system, and the type of mobile internet browsers You use.
You may choose to use certain features on Your mobile devices, to provide Eloelo with additional Information in order to obtain a better user experience when using the Platform:
Phonebook (contacts list): Access to the User’s contact list allows the Application to be more user-friendly, since accessing contacts directly from the Application saves time.
Camera (pictures): Granting camera permission allows the User to use the camera and upload any picture directly to the Application
Photo gallery (pictures): Granting photo gallery access allows the User to upload any picture from their photo gallery on the Application.
You may choose to provide Eloelo (through the Platform) with additional Information in order to obtain a better user experience when using the Platform. This additional information will be processed based on Your consent:
Additional Profile Information. You may choose to provide additional information as part of Your profile.
Other Information. You may otherwise choose to provide Eloelo information when You fill in a form, conduct a search, update or add information to Your account, respond to surveys, post to community forums, participate in promotions, or use other features of the Platform.
Non-Personal Information: Eloelo may also collect Non-Personal Information for the purposes of identification or measuring site traffic etc., which may be collected through various ways including through use of cookies.
Eloelo may also receive Information about You from third parties and social media services (such as Facebook and Google), commercially available sources, and business partners. The Information we collect may include Your user name associated with that social media service, any information or content the social media service has the right to share with us, such as Your profile picture, email address or friends list, and any information You have made public in connection with that social media service. You can control the extent of information that social media services make public by visiting these website(s)/application(s) and changing your privacy settings
.Usage of Information collected
Eloelo uses, stores, and processes Information, including Personal Information, about You to:
Facilitate the use of the Platform and use the Personal Information to provide the User with the Services.
We use Information that we collect to personalize the Services being provided
We will use Your contact details to communicate with You in response to Your inquiries, and to send You announcements/ promotions related to the Platform/ Services.
Aggregated and individual, anonymized and non-anonymized data may periodically be transmitted to external service providers to help Eloelo improve the Platform/ Services.
We further use Your Information to improve our products and services. We may use the individual data and behavior patterns combined with Your Personal Information to provide You with personalized content, and to better Your experience. Third parties provide certain services which Eloelo may use to analyze the data and information You provide it to personalize, drive insights and help better Your experience or reach out to You with more value-added applications, products, information and services. However, these third-party companies do not have any independent right to share this information further. We do not sell, trade or rent Your Information to any third party unless we have been expressly authorized by You either in writing or electronically to do so. We may at times provide aggregate statistics about customers, traffic patterns, and related site information to reputable third parties, however this information when disclosed will be in an aggregate form.
We may also share certain Personal Information with third parties who either provide the Services (or any part thereof) or through whom the Services (or any part thereof) are provided.
We may offer email, Platform notifications (including push notifications), SMS, multimedia message service (MMS) or other forms of communication to share information with You about certain promotions or features the Platform may choose to offer or about our affiliates, subsidiaries, business partners, advertisers and sponsors. You may receive such communication when You have registered as a User of the Platform
By submitting Your email address on this Platform, You agree to receive emails from us. You can cancel your subscription to 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 Users who have authorized us to contact them, either directly, or through a third party. Furthermore, 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 Users 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 instructions at the bottom of each email to ‘unsubscribe’.
Storage and Processing of Information
Your Information will primarily be stored in electronic form. However, certain data may also be stored in physical form.
We may store, collect, process and use Your data in countries other than the Republic of India to the extent permissible under applicable laws.
We may enter into agreements with third parties (in or outside of India) to store or process Your Information, subject to applicable law. These third parties may have their own security standards to safeguard Your Information and we will, on commercially reasonable basis, require such third parties to adopt reasonable security standards to safeguard Your Information, as per the requirements of applicable laws.
Sharing of Information
We may share Your Information with our business partners and with our trusted service providers who work on our behalf, including partners and service providers situated outside India.
Eloelo may use and may transfer/disclose/share Information to third parties who support our business such as hosting and maintaining our servers and the Platform, 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 Platform. 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
Such third-party entities do not have an independent use of the Information that Eloelo discloses to them, and do not further transfer or publish the Information we share with them. They have agreed to adhere to the rules set forth in this Policy and under applicable laws, including providing adequate security measures for the Information that Eloelo shares with them.
Further, notwithstanding anything to the contrary contained herein, You may at any time choose to revoke Your consent to share Information with third parties who are working with Eloelo. Upon revocation of such consent, we may not be able to provide You with the Services/ access to the Platform. Please note that Eloelo shall not be responsible or liable in any manner whatsoever for any actions of any third parties that receive Information.
We may also share Your Information 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 Information to our successors-in-interest.
We may share Your Information in furtherance of our obligations under any applicable laws. We may further share Your Information to respond to a court order or summons. We may also share Your Information upon request from a government agency or investigatory body requests or when we are investigating potential fraud. We reserve the right to disclose your Information when required to do so by law or regulation, or under any legal obligation or order under law or in response to a request from a law enforcement or governmental agency or judicial, quasi-judicial or any other statutory or constitutional authority or to establish or exercise our legal rights or defend against legal claims. The Company may also share Personal Information with such third parties to whom the Company believes it is necessary to do so in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of various terms and conditions or our policies.
Retention of Information
Eloelo retains User Information while a User’s account is active on its Platform and for a period of time afterwards which allows Eloelo to meet legal, compliance and business requirements pursuant to this Policy.
Eloelo may alter this practice according to legal and business requirements, and to fulfill the purposes described in this Policy. For example, it may lengthen the retention period for some data if needed to comply with applicable law or voluntary codes of conduct. Unless otherwise prohibited, it may shorten the retention period for some types of data if needed to free up storage space.
When we no longer need to use a User’s Information and there is no need for us to retain the Information for the abovementioned compliances, we either remove it from our systems or depersonalize it so that we cannot identify such User.
Security of Information
The security of Your Personal Information is important to us. Eloelo strives to ensure the security of Your Personal Information and to protect Your Personal Information against unauthorized access or unauthorized alteration, disclosure or destruction. For this purpose, Eloelo adopts internal reviews of the data collection, storage and processing practices and security measures, including appropriate anonymization, encryption and physical security measures to guard against unauthorized access to systems where Eloelo stores Your Personal Information. Eloelo adopts reasonable security practices and procedures as mandated under applicable laws for the protection of Your Information. Provided that Your right to claim damages shall be limited to the right to claim only statutory damages under Information Technology Act, 2000 and You hereby waive and release all the Company entities from any claim of damages under contract or under tort, to the extent permissible under applicable laws.
Eloelo offers 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 Personal Information (credit cards, social security numbers, financials, etc.) is never kept on record.
Eloelo limits access to Information to those employees, agents, contractors and other third parties on a ‘need-to-know basis’, i.e., who need the access in order to fulfil the tasks and duties relating to the provision of Services. All service providers are permitted to process the Information based on the Company’s instructions, they are subject to a duty of confidentiality, and they are required to be compliant and demonstrate compliance with applicable data protection laws.
Eloelo may share Your Information with third parties under a confidentiality agreement which inter alia provides that such third parties shall not disclose the Information further unless such disclosure is for the purposes set forth in this Policy. However, Eloelo is not responsible for any breach of security or for any actions of any third parties that receive Your Personal Information. Eloelo is not liable for any loss or injury caused to You as a result of You providing Your Personal Information to any third party (including any third party websites, even if links to such third party websites are provided on the Platform).
While we will endeavour to take all reasonable and appropriate steps to keep secure any Personal Information which we hold about You and prevent unauthorized access, You acknowledge that the internet or computer networks are not fully secure and that we cannot provide any absolute assurance regarding the security of Your Personal Information.
Notwithstanding anything contained in this Policy or elsewhere, to the extent permissible under applicable laws, Eloelo shall not be held responsible for any loss, damage or misuse of Your Personal Information, if such loss, damage or misuse is attributable to a force majeure event.
DIAMONDS PURCHASE AND REFUND POLICY
You can now license virtual digital goods (such as stickers, gifs, banners, etc) to our users ("Gifts"). You can send such gifts by acquiring Diamonds using our authorised payment methods and through payment providers made available and authorized by us.
Purchasing Diamonds
The price of the Diamonds will be displayed at the point of purchase. All charges and payments for Diamonds will be made in the currency specified at the point of purchase through the relevant payment mechanism as set out by us.
You will be responsible for the payment of any Diamonds purchased by you. Once your payment has been made, your user account will be credited with the number of Diamonds purchased.
Once the Diamonds or any service is purchased successfully on the platform, it cannot be refunded in any manner
Usage of Diamonds
Diamonds can be used to gift creators, users and purchase other digital goods like stickers, badges. Diamonds can also be used to buy frames and wallpapers. Diamonds cannot be exchanged for cash, or legal tender, or currency of any state, region, or any political entity, or any other form of credit.
Diamonds can only be used on our Platform and as a part of our Services and cannot be combined or used in conjunction with other promotions, coupons, discounts or special offers, except those designated by us.
No Diamonds may be assigned or transferred to any other user of the Platform or any third party. The sale, barter, assignment, or other disposal of any Diamonds, other than by us, is expressly prohibited. Any violation of this restriction may result in termination of your account on the Platform, forfeiture of the Diamonds from your account, and/or you may be subject to liability for damages, litigation and transaction costs.
Accrued Diamonds do not constitute property and are not transferable: (i) upon death; (ii) as part of a domestic relations matter; or (iii) otherwise by operation of law.
You agree that we have the right to manage, regulate, control, modify and/or eliminate such Diamonds, where we have a valid reason to do so such as where we reasonably believe you have violated this Diamonds Policy, you are in breach of any applicable law or regulation or for legal, security or technical reasons and that we will have no liability to you based on our exercise of this right. If we decided to eliminate Diamonds from our Services completely, we will do so by providing reasonable notice to you.
Purchasing Gifts
Gifts constitute a limited license to certain features of digital products and services. The conversion/ redemption rate between each Diamond and Gift will be displayed on our Platform.
Published prices include taxes where required under applicable laws of your jurisdiction.
You agree that we have the absolute right to manage, regulate, control, modify and/or eliminate such exchange rate as we deem fit in our sole discretion, in any general or specific case, and that we will have no liability to you based on our exercise of such right.
Except as otherwise set out in this Diamond Policy, all conversions/ redemptions of Diamonds into Gifts are final. We do not offer refunds in any manner.
Gifts cannot be converted into or exchanged for Diamonds or cash or be refunded or reimbursed by us for any reason.
Gifts exchanged or received by any user do not constitute property and are not transferable: (i) upon death; (ii) as part of a domestic relations matter; or (iii) otherwise by operation of law
We may replace previously exchanged copies of Gifts, if we determine in our sole discretion that the Gifts exchanged or received by a user are corrupted or otherwise damaged. We will not charge additional fees for reissuing a corrupted or otherwise damaged Gift.
We reserve the right to terminate or take any other appropriate action against you if you are deemed to be abusing the Diamonds Feature or you are in breach of this Diamonds Policy.
You are not permitted to use any Gift or Diamond in lieu of receipt of any goods or services from any user on the Platform or otherwise.
NOTE TO USERS
Diamonds/ Gifts are not treated as individual goods to be purchased by users but as licenced access to items issued by the Platform.
Diamonds and Gifts associated with your account will be extinguished once you delete your account from our Platform.
Diamonds cannot be used for trading on the internet.
You are solely responsible for the Diamonds/ Gifts you purchase on the Platform and you agree that we will have no liability or responsibility with respect to such Diamonds/ Gifts.
We reserve the right to determine in our sole discretion as to what constitutes a violation.
We reserve the right, in our sole discretion, to change portions of this Diamonds purchase and Refund Policy at any time. If we do this, we will post the changes on this page and will indicate at the top of this page the date on which these terms were last updated.
How you can delete your data from eloelo?
According to Facebook policy, we have to provide User Data Deletion options.
Go to your App Profile
Click “Settings”
Then click “Contact Us”.
Write to us at the email address with your profile account details
Your Rights
Users may exercise any of the rights described in this section by logging into the Application and then following these steps:
Go to ‘App Profile’.
Click ‘Settings’.
Click ‘Contact Us’.
Write to us at info@eloelo.in with Your profile account details. Please note that we may ask You to verify Your identity before taking further action on Your request.
Managing Your Information
Eloelo will provide You with the means to ensure that Your Information is correct and current. If You have filled out a user profile, we will provide an obvious way for You to access and change Your profile from the Platform. Eloelo adopts stringent security measures to protect Your password from being exposed or disclosed to anyone. Upon forgetting the password for Your profile on the Platform, Eloelo will have a right to reset the same for You with Your prior approval as per standard web practices. You are responsible for keeping Your Personal Information up-todate.
Rectification of Inaccurate or Incomplete Information
You have the right to ask us to correct inaccurate or incomplete Personal Information concerning You (and which You cannot update yourself within Your account).
Data Retention and Erasure.
If You no longer want Eloelo to use Your Personal Information to provide Services/ access to the Platform to You, You can request that we erase Your Personal Information and close Your account. Provided, however, any requests for erasure will be acted upon in accordance with applicable law and may adversely impact Eloelo’s ability to provide Services to You.
You hereby agree and acknowledge that a mere request for erasure does not guarantee an erasure of Personal Information and all such requests will be acted upon in accordance with applicable law alone.
Please note that if You request the erasure of Your Personal Information:
We may retain some of Your Personal Information as necessary for protecting our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an account for fraud or safety reasons, we may retain certain information from that account to prevent that User from opening a new account in the future.
Information You have shared with others (e.g., reviews, forum postings) may continue to be publicly visible on the Platform, even after Your account is cancelled. However, the attribution of such information to You will be removed. Additionally, some copies of Your Information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
We maintain the Platform to protect You from accidental or malicious loss and destruction, and residual copies of Your Personal Information may not be removed from our backup systems for a limited period of time.
We will not be required to delete any information which has been de-identified or disassociated with personal identifiers such that it can no longer be used to reasonably identify a particular individual.
Eloelo will not be able to provide You with the Services (or any part thereof) and You should cease and desist from using the Services.
Withdrawing Consent and Restriction of Processing
Where You have provided Your consent to the processing of Your Personal Information by Eloelo, You may withdraw Your consent at any time by changing Your account settings or by sending a communication to Eloelo specifying (with reasonable detail) the consent You are withdrawing. Please note that the withdrawal of Your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. If You withdraw Your consent and restrict processing of any Personal Information, Eloelo may not be able to provide You with the Services (or any part thereof) and You may be required to cease to use the Services (or any part thereof).
Your Consent
Eloelo believes that every User of the Platform/Services must be in a position to provide an informed consent prior to providing any Information required for the use of the Platform/Services. By registering with Eloelo, You are expressly consenting to its collection, processing, storing, disclosing and handling of Your Information as set forth in this Policy now and as amended by us. You understand that processing Your Information includes, but is not limited to, collecting, storing, deleting, using, combining, sharing, transferring and disclosing of Information. If You disclose to us any personal information relating to other people, You represent that You have the authority to do so and You permit us to use the information in accordance with this Policy. If You reside outside India, Your Information will be transferred, processed and stored in accordance with the applicable data protection laws of India.
Changes To Our Policy
As Eloelo evolves, this Policy will need to evolve as well to cover new situations. You are advised to review this Policy regularly for any changes. Your continued use of our Platform/Services shall be deemed to provide Your approval and consent to all changes. If You do not agree to this Policy or any updated Policy, You may discontinue your use of the Platform/Services or delete Your account
Cookies
A cookie is a small file which asks permission to be placed on Your computer system. Once You agree, the file is added, and the cookie helps analyze web traffic or lets You know when You visit a particular site. Cookies allow web applications to respond to You as an individual. The web application can tailor its operations to Your needs, likes and dislikes by gathering and remembering information about Your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyze data about webpage traffic and improve the Platform in order to tailor it to Users’ needs. We only use this information for statistical analysis purposes.
Cookies help us to provide You with a better Platform, by enabling us to monitor which pages You find useful and which You do not. A cookie in no way gives us access to Your computer system or any information about You, other than the data that You choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but You can usually modify your browser setting to decline cookies if You prefer. Please refer to Your web-browser provider or system guide for detailed information on disabling cookies. However, in case You choose to disable the cookies, You may be prevented from taking full advantage of the Platform
Links to Other Websites
This Policy applies only to the Platform/Services. The Platform may present links to third-party websites in a format that enables Eloelo to keep track of whether these links have been followed. Clicking on these links may take You to third-party websites outside the Platform. However, once You have used any of these links to leave the Platform, Eloelo does not have any control over that other website(s)/mobile application(s). You agree and acknowledge that these websites/mobile applications are operated by third parties and are not controlled by, or affiliated to, or associated with Eloelo, unless expressly specified. Eloelo is not responsible for any form of transmission, whatsoever, received by You from any such third party. Accordingly, Eloelo does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites or mobile applications, nor does it control or guarantee the accuracy, integrity, or quality of the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials available on such websites or mobile applications. Eloelo encourages its Users to read the EULA/terms and conditions of each such third-party website that may collect their Personal Information.
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 Eloelo or any of its Corporate Affiliates, or that portion of Eloelo 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 Policy
Corporate Affiliates
Eloelo may disclose Information about You to its Corporate Affiliates. Any Information relating to You that it provides to its Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Policy.
Governing Law
This Policy is governed by the laws of India without reference to its conflict of laws principles. You consent to the exclusive jurisdiction of the courts in Bangalore, India in connection with any dispute arising between the parties hereunder or in connection with this Policy except for those individuals who may have rights to make claims under Privacy Shield, or the Swiss-US framework.
Public Forums
When You use certain features on the Platform/Services like the discussion forums and You post or share any content such as comments, messages, files, photos, Your Information in such content will be available to all Users and will be in the public domain. All such sharing of Information is done at Your own risk. Please keep in mind that if You disclose Information in Your profile or when posting on any forums, this Information may become publicly available.
Contact Us
Eloelo grievance officer shall undertake all reasonable efforts to address Your grievances relating to the processing of Your Information at the earliest possible opportunity and no later than 1 (one) month from the date of receipt of Your complaint.
You may contact us at:
Grievance Officer: Saurabh Pandey(Saurabh@eloelo.in)
Chief Compliance Officer: Kundan Kumar(info@eloelo.in)
Nodal Officer: Anmol Agarwalla (anmol.agarwalla@eloelo.in)
Address: 1090c, 18th Cross Rd, Sector 3, HSR Layout, Bengaluru, Karnataka 560102
