Privacy Policy - Elo Plus

Elo App Privacy Policy

Last Updated: 20th March 2025

1. Introduction

Welcome to Elo (“we,” “us,” “our”). This Privacy Policy explains how we collect, use, share, and protect your personal data when you use the Elo App (“App” or “Platform”). Your privacy is of utmost importance to us, and we are committed to complying with applicable data protection laws, including the Data Protection Act of Kenya (2019), the General Data Protection Regulation (GDPR), and other relevant standards.

By accessing or using Elo, you agree to the collection and use of your data in accordance with this Privacy Policy. If you do not agree with our policies and practices, please do not use our App.

2. Information We Collect

2.1 Information You Provide Directly

Account Information: Name, email address, phone number, date of birth, and password.
Profile Information: Photos, bio details, interests, and selected visibility settings (Precise, Nearby, Hidden).
Communications: Messages, chats, and any other communications with other users or customer support.

2.2 Information Collected Automatically

Device Information: IP address, device type, operating system, and browser type.
Usage Data: Details about your interactions with the App, such as pages viewed, features used, and time spent on the App.
Location Data: Information derived from your device’s location services, subject to your selected visibility setting.

2.3 Information from Third Parties

Social Media: Data from social media platforms if you choose to register or connect your account via such services.
Payment Processors: Information necessary to complete transactions, provided by third-party payment services.

3. How We Use Your Information

We use the information we collect for the following purposes:

Service Delivery: To provide, maintain, and improve the functionality and features of Elo.
Personalization: To tailor your experience, such as by providing personalized recommendations and customized content.
Communication: To send you updates, notifications, promotional materials (with your consent), and customer support communications.
Safety and Security: To monitor, detect, and prevent fraud, abuse, and other illegal or unauthorized activities.
Analytics: To understand how users interact with our App and to help us improve our products and services.
Legal Compliance: To comply with applicable laws and regulations and to enforce our terms and policies.

4. How We Share Your Information

We do not sell or rent your personal data. We may share your information in the following circumstances:

4.1 Service Providers and Partners

Third-Party Service Providers: We may share your data with trusted service providers who perform services on our behalf (e.g., payment processing, analytics, data storage) under strict confidentiality obligations.
Business Partners: With your consent, we may share information with business partners for joint marketing efforts, promotions, or to enhance our services.

4.2 Legal and Regulatory Requirements

Compliance: We may disclose your information if required by law, regulation, legal process, or governmental request.
Protection: We may share your information to protect our rights, privacy, safety, or property, as well as that of our users or the public.

4.3 Business Transfers

In the event of a merger, acquisition, or asset sale, your information may be transferred as part of the transaction. We will notify you by email and/or a prominent notice on our App of any change in ownership or uses of your personal data.

5. Data Security

We implement robust technical and organizational measures to safeguard your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, regular security assessments, and strict access controls. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

6. Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When personal data is no longer required, we will securely delete or anonymize it.

7. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal data, including:

Access: Request access to the personal data we hold about you.
Correction: Request that we correct any inaccuracies in your personal data.
Deletion: Request the deletion of your personal data, subject to legal obligations.
Restriction: Request that we restrict the processing of your personal data in certain circumstances.
Objection: Object to the processing of your personal data where applicable.
Data Portability: Request that we transfer your data to another organization or directly to you.

To exercise these rights, please contact us at the address provided in Section 9.

8. International Data Transfers

If you are accessing Elo from outside Kenya, please note that your personal data may be transferred to and processed in Kenya and other countries where our servers are located. We ensure that such transfers are made in compliance with applicable data protection laws, using mechanisms such as standard contractual clauses or other approved methods.

9. Camera and Photo Access Policy

9.1 Introduction

Elo Plus App (“Elo Plus,” “we,” “our,” or “us”) values your privacy and is committed to transparency regarding how we collect, use, and manage your data. This policy explains why and how we request access to your device’s camera and photos, ensuring compliance with applicable data protection laws.

9.2 Purpose of Camera and Photo Access

Elo Plus requests access to your camera and photos for the following purposes:

Profile Customization: Allowing users to upload profile pictures and other media to personalize their accounts.
In-App Messaging & Sharing: Enabling users to send images and videos within the app’s chat and content-sharing features.
Augmented Reality (AR) Features: Supporting interactive and visual engagement within the app.
Video Calls & Live Streaming: Allowing users to engage in real-time interactions using video features where applicable.

9.3 User Consent

Before accessing your camera or photos, Elo Plus will request explicit permission through a system-generated prompt.
You have the right to accept or deny access. Denying access may limit the functionality of some features.
You can modify or revoke permissions at any time through your device settings.

9.4 Data Storage & Security

Elo Plus does not store photos or videos without user action (e.g., uploading or sharing within the app).
Any media uploaded is processed securely and, where applicable, encrypted to protect user privacy.
We do not use your camera or photos for any unauthorized purposes, including third party advertising.

9.5 Third-Party Access & Compliance

We do not share your camera or photo data with third parties without your consent, except as required by law.
Our policies align with international data protection regulations, including GDPR (Europe), CCPA (California, USA), and Kenya’s Data Protection Act.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When changes are made, we will update the “Last Updated” date at the top of this document and notify you via the App or email if the changes are significant. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your data.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Elo Privacy Team
Email: [support@elo.plus]

12. Subscription - Restore Purchases

To restore previous purchases (e.g., after reinstalling the app or switching devices), Elo Plus uses Apple’s StoreKit framework to verify your subscription status through your Apple ID. This process does not collect additional personal data but relies on transaction records stored securely by Apple.