Last updated April 20, 2023
Effective April 20, 2023

Elloveo – Privacy Policy

This Privacy Policy explains what information of yours will be collected and used by Elloveo, Inc. (“Elloveo,” “we,” “us,” or “our”) when you download the mobile applications available on iTunes provided by us (the “App(s),") or visit our website at Elloveo.com (collectively, the “Service,). We will not use or share your information with anyone except as described in this Privacy Policy. Each time you use our Service you are accepting the practices described in this Privacy Policy at that time.

Our goal is to provide educational content while protecting the personal information of all users. When you download our App(s), we will collect some information from you. We want to be clear about what sort of information we will collect, how we use and process this information and, when, if at all, we disclose information about you to others.

The Apps downloaded to your iOS or Amazon Fire Tablet device all allow game play and are intended for families and users of all ages. As used in this privacy policy, “children”, “child”, and “kid(s)” refer to children under the age of 13, except for those jurisdictions where the privacy law specifies a different age. When we use the term “parent”, we include legal guardians.

The Elloveo Website at www.elloveo.com is provided for use in managing and providing information about our App(s), The Website is intended for a general audience and does not allow game play.

Information we collect

Personal information provided by you:

We do not collect personally identifiable information (“PII” or “personal information) directly from users under 18 on our App(s). Users 18 and over and/or parents will be asked to enter an email address. This is optional and not required to play the game. In future versions of the game, if parents enter an email they may have the option to create an account to, for example, monitor their child(ren)’s progress through the game. If users and/or parents enter an email, we may send you emails for marketing purposes or any other game related information in the future.

If you contact us directly via email we will respond to your inquiry and we will then save your email for future communications, unless you inform us that you do not want to receive these emails.

We do not share or sell your personal information to any 3rd parties for their own marketing purposes.

Information collected automatically

For App downloaded onto a mobile device:

When using the game, Elloveo will collect non-personalized data related to game play progress through the App to be used in aggregate to help us make changes to the game as needed. A child’s usage information, such as scores from games and assessments is only shared in an aggregated, anonymous manner and never in a way that could personally identify the child.

Elloveo will also collect and store unique device ID, operating system version in order to improve the game, recreate bugs, and to improve the user experience. This information is stored in a MongoDB cloud based database. By using our game, you are agreeing to be bound by MongoDB, Inc’s privacy policy which can be found at www.mongodb.com/legal/privacy-policy

For Website usage:

Your browser automatically reports log file information each time you access a web page on our Website. When you access the Website, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other similar information.

We may use mobile analytics software and various backend systems to analyze certain information regarding your use of the Website such as email address, pageviews, and transaction related information.

We do not collect information about your location from your mobile device. We do log your IP address when you visit our Website, which can be used to approximate location. We use IP addresses only for activities necessary to maintain or analyze the Service; perform network communications; authenticate users or personalize content; protect the security or integrity of the user and the Service; ensure legal or regulatory compliance; or fulfill a request of a user.

How we use your information

We use or may use information we collect for a variety of purposes, including:

  • To send updates, security alerts, technical notices, and support and administrative messages.
  • Respond to your questions, requests and provide customer support.
  • To operate the game, monitor the effectiveness of the game, to improve the content of the game, and layout and design.
  • To help provide you with a smooth, efficient user experience.
  • To monitor, analyze and describe usage patterns and performance of the game, including aggregate metrics such as total number of visitors, traffic, and demographic patterns.
  • To conduct system administration and system troubleshooting and to diagnose or fix technology problems.
  • We may give you the option to receive local push notifications.  You can turn push notifications on or off through settings within the app or on your device
  • To comply with legal requirements and process (for example, in response to subpoenas, court orders, and law enforcement or governmental requests or investigations), and to protect our legal rights or the rights of others (for example, by working to reduce the risk of fraud or misuse of the Service).
  • In connection with an unusual business transaction, such as the bankruptcy or liquidation of, sale of, purchase of, or merger with our business or another business.
  • When we have a good faith belief that disclosure may prevent fraud and abuse of us, our users or protect our property rights.

How we share your information

Personal Information

Elloveo, Inc will not rent or sell your Personal Information to others, nor will we share your Personal Information with independent third parties for marketing purposes. To operate the Service, however, we may share your Personal Information with our agents, representatives and contractors so they can provide us with support services and other features. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.

Non-Personally Identifiable Information

We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes to people over the age of 13; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Website.

Please visit https://www.elloveo.com/providers for a list of third-party service providers that we use.

Google Cloud

Our site is hosted by Google Cloud. Personal information hosted by or through Google Cloud is subject to their privacy policy which may or may not contain terms as protective as this Privacy Policy.

Google Cloud may use a variety of technologies, now and hereafter devised, that automatically record certain usage information. When accessing our Site, Google Cloud, passively collects the IP address and user agent, or web browser being used. This information is used in the aggregate, and is never linked back to any Personal Information.

By using Elloveo, Inc’s app or the Elloveo website, you are agreeing to be bound by the Google Cloud Privacy Notice which can be viewed here: https://policies.google.com/privacy

Instances where we are required to share your Personal Information

Elloveo, Inc will disclose your Personal Information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Elloveo, Inc, our users or others. It is our policy to provide notice to our users before producing their Personal Information in response to law enforcement requests unless (i) we are prohibited by law or court order from doing so, (ii) we have reason to believe the user’s account has been compromised such that the notice would go to the wrong person, or notice would otherwise be counterproductive or would create a risk to safety, or (iii) it is an emergency request and prior notice would be impractical (in which case we may provide notice after the fact).

How you can share your in-application information

App users can create, name and share their own levels in the Elloveo, Inc mobile app. This means that a user can create a game scene, save it to their device and to Elloveo, Inc’s database, and then send that scene to a known individual using their personal contact information.

Elloveo, Inc does not have access to the personal information of the sender or receiver of these game scenes.

Elloveo does not monitor the content of the levels sent between individual users.

If Elloveo plans to make the levels available to the general game play population, the company will review this content to ensure it is appropriate.

What happens in the event of a change of control?

We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of our products, services, assets and/or businesses. Your information, such as email addresses, and other user information related to the Service, may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company.

Important Information for Users Outside the U.S.

We primarily store data about you, including personal information, on servers located and operated within the United States. If you reside outside of the United States, in order to provide and operate the Service, we may send and store your personal information (also commonly referred to as personal data) outside of the country where you reside or are located, to the United States. Therefore, our collection and use of your personal information is subject to the United States’ laws related to privacy and use of personal data and information.

These laws, including what is determined to be “personal data and/or information,” are different and may be less protective than those applicable to you in your country of residence. By accepting the terms of this privacy policy, you acknowledge, agree and consent to (1) the transfer to and processing of personal information on servers located outside of the country where you reside, (2) our collection and use of your personal information as described herein and in accordance with the laws of the United States that may be different and may be less protective than those in your country and (3) that you are taking a risk by using the service.

Processing Personal Data

Lawful Bases for Processing Personal Data

If you are an individual in the European Union (EU) or an EU citizen, we collect and process data about you only where we have legal bases for doing so under applicable EU laws. This means we collect and process your data only when:

  • It is necessary for a legitimate interest (which is not overridden by your individual privacy interests), such as preventing fraud, improving the Service, and increasing the security of the Service and network infrastructure;
  • You have consented to this collection and processing for a specific purpose;
  • It is necessary to fulfill our contractual obligations; or
  • It is necessary to comply with a legal obligation.

Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. If you wish to withdraw your consent, please contact us at info@elloveo.com. Some examples of our legitimate interests and the data being processed include:

  • Customer Support and fraud prevention (name, email address)
  • Improving our products and services (hardware information, activity logs)

Where we rely on our legitimate interests to process your personal data, you have the right to object. More information on exercising this right can be found in the Individual Rights section below.

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us at info@elloveo.com.

Your Choices About Your Information

You may, of course, decline to share certain personal information with us. You may update, correct, or delete your profile information and preferences at any time by accessing your account preferences page in the game or contacting us at info@elloveo.com, note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

Data Portability

You have the right to obtain copies of your information in a structured, commonly used format that you can move your data between our service and the services of others. We may request more information to confirm your identity before providing any personal data

Contact for Individual Rights Requests

Please use the below information when submitting a request to exercise any of the above rights. Please do not submit requests across multiple communications channels. We will make all efforts to respond to your request within a reasonable timeframe.

Email

info@elloveo.com

Physical Mail

Elloveo, Inc

1325 Palmetto Street, STE 108
Los Angeles, CA 90013
USA

Data Retention

Elloveo, Inc may retain users’ data for the following purposes:

  • To develop new features and improve the game;
  • To support subsequent customer service inquiries;
  • To improve the safety and security of the game; or
  • Comply with our legal obligations.

We will retain your information for as long as is reasonably necessary in relation to the purposes for which this data was collected. In many instances, we will retain your data while it is necessary for your use of the game, which may include maintaining this information beyond when you cease using the game.

Email and Recommendation Communications That We May Send

For our users 17 and over, we may send you, or you may elect to sign up to receive, emails from us. To help us understand whether we are providing information of interest to you, we may include software code or other tracking technologies in our emails to monitor whether you opened a particular email, whether you have clicked on the images and/or links in the email, the date and time the message was opened, and whether your computer is capable of receiving HTML-based email. We endeavor to allow you to unsubscribe at any time from our email programs by clicking on the unsubscribe link at the bottom of any email message.

Security Measures

We have put in place reasonable administrative, technical and organizational controls and established policies designed to safeguard the personal information we collect via our App(s) and Website against unauthorized access, disclosure, misuse and/or destruction. However, no security measures are perfect, and we cannot guarantee that personal information that we collect will never be accessed or used in an unauthorized way.

Compromise of Personal Information

In the event that Personal Information is compromised as a result of a breach of security, Elloveo, Inc will promptly notify those persons whose Personal Information has been compromised, in accordance with the notification procedures set forth in this Privacy Policy, or as otherwise required by applicable law. In the event that we, or our game, suffers a data security breach that requires us to provide you with notice, such as under applicable law, you consent to allow us to provide you with such notice by sending an e-mail to the primary e-mail address that is associated with your account.

Changes to this Privacy Policy

We may change this Privacy Policy at any time and for any reason. We encourage you to review this Privacy Policy each time you visit our App(s) or Website.

If we make material changes to how we collect, use, or share your personal information, we will describe the changes, and, if required by law, seek your consent for such changes.

California Privacy Rights

Since 2005, California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share our customer's personal information with unaffiliated third parties for their own direct marketing purposes. For inquiries regarding our disclosure policy, please send us an email to info@elloveo.com, or write us at: Elloveo, Inc.; 1325 Palmetto st, STE 108 Los Angeles, CA 90013 ATTN: Privacy Team/Privacy Policy. We will be happy to honor your request.

CARU COPPA Safe Harbor

This privacy policy and the CARU icon shown on our mobile apps and websites confirm that Elloveo Inc. is a valid licensee and participating member in the CARU COPPA Safe Harbor Program (“CARU Safe Harbor”). To protect your privacy, we have voluntarily undertaken this privacy initiative. CARU has reviewed and certified that we meet established online information collection and use practices on all Elloveo, Inc. properties where this privacy policy is posted.

As part of the CARU Safe Harbor, we are subject to audits and frequent monitoring of our websites and/or apps and other enforcement and accountability mechanisms administered independently by CARU.

If you believe that we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact CARU at:

CARU COPPA Safe Harbor
Attn: Director
112 Madison Avenue, 3rd Floor
New York, NY 10016
infocaru@bbbnp.org

@2017-2021 Elloveo, Inc. All rights Reserved

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