Privacy policy

Privacy Policy for Elleloom

Last updated: April 3, 2024

This Privacy Policy describes our policies and procedures regarding the collection, use, and disclosure of your information when you use the Service, and informs you about your privacy rights and how the law protects you.

We use your personal data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation
Words with an initial capital letter have meanings defined under the following conditions. The following definitions have the same meaning whether they appear in singular or plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for you to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for the election of directors or other managing authority.
• Application means the software program provided by the Company and downloaded by you on an electronic device, named Elleloom.
• Company (referred to as "the Company," "We," "Us," or "Our" in this Agreement) refers to Maronipult BV, Terminalweg 19a, 1821 AJ, Amersfoort, Netherlands.
  For the purposes of the GDPR, the Company is the Data Controller.
• Cookies are small files that are placed on your computer, mobile device, or any other device by a website, containing the details of your browsing history on that website among its many uses.
• Country refers to: Netherlands.
• Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal entity that determines, alone or jointly with others, the purposes and means of the processing of Personal Data.
• Device means any device that can access the Service, such as a computer, a mobile phone, or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable person. For the purposes of the GDPR, Personal Data means any information about you, such as a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity.
• Service Provider means any natural or legal person who processes data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, provide the Service on behalf of the Company, perform services related to the Service, or assist the Company in analyzing how the Service is used. For the purposes of the GDPR, Service Providers are considered Data Processors.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to Elleloom, accessible from https://miavitals.com/.
• You means the individual accessing or using the Service, or the company or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under the GDPR (General Data Protection Regulation), you can be referred to as the Data Subject or the User, as you are the person using the Service.

Collection and Use of Your Personal Data

Types of Data Collected

Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personal data will always be kept strictly separate from usage data and will be stored separately on European servers. Personally identifiable information may include, but is not limited to:

• Email address
• First and last name
• Phone number
• Usage Data

Usage Data

Usage Data is automatically collected when using the Service and is stored strictly separately from personal data. We use an internally generated ID to indirectly link data to a user. All data is stored in encrypted form.

Usage Data may include information such as your device’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

When you access the Service via a mobile device, we may automatically collect certain information, including, but not limited to, the type of mobile device you use, your mobile device’s unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers, and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service via a mobile device.

Information Collected During the Use of the Application

While using our Application, we may collect the following information with your prior consent in order to provide features of our Application:

• Location Information
  We use this information to provide features of our Service, improve and customize our Service. The information may be uploaded to the Company’s servers and/or a Service Provider’s server or it may simply be stored on your device.

  You can enable or disable access to this information at any time through your device’s settings.

• Images of Your Cervix
  Images of your cervix are used solely for measurements and are not stored on our servers. Images and measurements are only stored on the user’s device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to monitor activity on our Service and store certain information. The tracking technologies used include beacons, tags, and scripts to collect and track information and to improve and analyze our Service. The technologies we use may include:

• Cookies or Browser Cookies: A cookie is a small file placed on your device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some portions of our Service. Unless you have adjusted your browser settings to refuse Cookies, our Service may use Cookies.

• Web Beacons: Certain sections of our Service and our emails may contain small electronic files known as web beacons (also called clear gifs, pixel tags, and single-pixel gifs) that allow the Company to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a particular section and verifying the integrity of the system and server).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser. You can learn more about cookies on the TermsFeed website.

We use both Session and Persistent Cookies for the purposes described below.

Necessary / Essential Cookies

Type: Session Cookies
Managed by: Us
Purpose: These cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services you requested cannot be provided, and we use these cookies solely to deliver those services.

Cookies Policy / Consent Cookies
Type: Session Cookies
Managed by: Us
Purpose: These cookies identify whether users have accepted the use of cookies on the Website.

Functionality Cookies
Type: Persistent Cookies
Managed by: Us
Purpose: These cookies allow us to remember choices you make when you use the Website, such as remembering your login credentials or language preferences. The purpose of these cookies is to provide you with a more personalized experience and to prevent you from having to re-enter your preferences each time you use the Website.

Tracking and Performance Cookies
Type: Persistent Cookies
Managed by: Third Parties
Purpose: These cookies are used to track information about the traffic to the Website and how users utilize the Website. The information collected by these cookies may identify you directly or indirectly as an individual visitor. This is because the collected information is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these cookies to test new pages, features, or functionalities of the Website to see how our users respond.

For more information about the cookies we use and your choices regarding cookies, you can refer to our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service: This includes monitoring the usage of our Service.
• For account management: To manage your registration as a user of the Service. The Personal Data you provide may give you access to different functionalities of the Service available to you as a registered user.
• For the execution of a contract: This includes the development, compliance, and enforcement of the purchase contract for the products, items, or services you have purchased or any other agreement with us via the Service.
• To contact you: To contact you via email, phone calls, SMS, or other equivalent forms of electronic communication, such as push notifications from a mobile application regarding updates or informational communication related to the functionalities, products, or contracted services, including security updates when necessary or reasonable for their implementation.
• To provide you with news, special offers, and general information about other goods, services, and events we offer that are similar to those you have already expressed interest in or inquired about, unless you have chosen not to receive such information.
• To manage your requests: To attend to and manage your requests to us.
• For business transfers: We may use your information to evaluate or conduct a merger, sale of assets, financing, or acquisition of all or a portion of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar procedure, in which Personal Data we hold about our users of the Service may be transferred as assets.
• For other purposes: We may use your information for other purposes, such as data analysis, identifying user trends, assessing the effectiveness of our promotional campaigns, and improving our Service, products, services, marketing, and your experience.

We may share your personal information in the following situations:

• With Service Providers: We may share your personal information with service providers to monitor and analyze the use of our Service, for payment processing, or to contact you.
• For business transfers: We may share or transfer your personal information in connection with or during negotiations of a merger, sale of assets, financing, or acquisition of all or a portion of our assets to another company.
• With Affiliates: We may share your information with our affiliates, requiring those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners, or other companies under common control with us.
• With Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions.
• With Other Users: When you share personal information or otherwise interact in public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
• With Your Consent: We may disclose your personal information for any other purpose with your consent.

Retention of Your Personal Data

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analytical purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen security, enhance the functionality of our Service, or when we are legally obligated to retain this data for a longer period.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operational offices and in any other places where the parties involved in the processing are located. This means that this information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Company will take all reasonably necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy, and that no transfer of your Personal Data will occur to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.

Deletion of Your Personal Data

You have the right to request the deletion of Personal Data we have collected about you or to request our assistance in deleting it.

Our Service may provide you with the ability to delete certain information about you from the Service.

You can update, modify, or delete your information at any time by logging into your Account, if you have one, and visiting the account settings that allow you to manage your personal information. You may also contact us to access, make corrections, or request the deletion of all personal information you have provided to us.

However, please note that we may be required to retain certain information when we have a legal obligation or legitimate basis to do so.

Disclosure of Your Personal Data

Business Transactions
If the Company is involved in a merger, acquisition, or sale of assets, your Personal Data may be transferred. We will notify you before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement
Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Other Legal Requirements

The Company may disclose your Personal Data in the sincere belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of the Company, prevent or investigate possible misconduct in connection with the Service, protect the personal safety of users of the Service or the public, or protect against legal liability.

Security of Your Personal Data

The security of your Personal Data is important to us, but remember that no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Detailed Information about the Processing of Your Personal Data

The Service Providers we use may have access to your Personal Data. These external providers collect, store, use, process, and transfer information about your activity on our Service in accordance with their Privacy Policy.

Analysis

We may use external Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the collected data to monitor and analyze the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can choose to make your activity on the Service unavailable to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visit activity.

You can also choose to disable certain features of Google Analytics through your mobile device settings, such as your device's advertising settings, or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy.

For more information about Google's privacy practices, you can visit the Google Privacy & Terms webpage: https://policies.google.com/privacy.

Firebase

Firebase is an analytics service provided by Google Inc.

You can disable certain Firebase features through your mobile device settings, such as your device's advertising settings, or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy.

We also encourage you to review Google's data protection policy: https://support.google.com/analytics/answer/6004245.

For more information about the type of information Firebase collects, you can visit the webpage on how Google uses data when you use our partner sites or apps: https://policies.google.com/technologies/partner-sites.

Email Marketing

We may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You can choose not to receive any or all communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting us.

We may use Email Marketing Service Providers to manage and send emails to you.

Klaviyo

Klaviyo is an email service for sending marketing messages, provided by Klaviyo, Inc.

For more information about Klaviyo's privacy practices, you can refer to their Privacy Policy: https://www.klaviyo.com/legal/privacy.

Payments

We may offer paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g., payment processors).

Stripe
Stripe processes your name and payment details such as your bank account or credit card number. Stripe has implemented appropriate technical and organizational measures to protect your personal data. Stripe does not retain your data longer than permitted by law.

Klarna
To handle (part of) the payments in our online store, we also use the Klarna platform. Klarna processes your name, address, and payment details such as your bank account or credit card number. Klarna has implemented appropriate technical and organizational measures to protect your personal data. Klarna does not retain your data longer than permitted by law.

Mollie

Mollie processes your name and payment details, such as your bank account or credit card number. Mollie has implemented appropriate technical and organizational measures to protect your personal data. Mollie does not retain your data longer than permitted by law.

We will not store or collect your payment information. This information is provided directly to our third-party payment processors, whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards established by PCI-DSS, as managed by the PCI Security Standards Council, a collaborative effort of brands such as Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure that payment information is handled securely.

GDPR Privacy

Legal Basis for the Processing of Personal Data under the GDPR

We may process Personal Data under the following conditions:

• Consent: You have given your consent for the processing of Personal Data for one or more specific purposes.
• Performance of a Contract: The provision of Personal Data is necessary for the performance of a contract with you and/or for any pre-contractual obligations thereof.
• Legal Obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital Interests: Processing Personal Data is necessary to protect your vital interests or those of another natural person.
• Public Interest: Processing Personal Data relates to a task carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate Interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will be happy to help clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a legal or contractual obligation, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company is committed to respecting the confidentiality of your Personal Data and ensuring that you can exercise your rights.

You have the right under this Privacy Policy, and by law if you are in the EU, to:

• Request access to your Personal Data: The right to request access to, update, or delete the information we hold about you. Where possible, you can access, update, or request the deletion of your Personal Data directly within the account settings section. If you are unable to perform these actions yourself, please contact us for assistance. This also allows you to receive a copy of the Personal Data we hold about you.

• Request correction of the Personal Data we hold about you: You have the right to request the correction of any incomplete or inaccurate information we hold about you.

• Object to the processing of your Personal Data: This right exists when we rely on a legitimate interest as the legal basis for our processing, and there is something about your particular situation that makes you want to object to our processing on this ground. You also have the right to object when we process your Personal Data for direct marketing purposes.

• Request deletion of your Personal Data: You have the right to request that we delete your Personal Data when there is no good reason for us to continue processing it.

• Request the transfer of your Personal Data: We will provide you, or a third party you have chosen, with your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information that you initially provided with your consent for our use or where we have used the information to perform a contract with you.

• Withdraw your consent: You have the right to withdraw your consent for the use of your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific features of the Service.

Exercising Your GDPR Data Protection Rights

You can exercise your rights to access, rectification, deletion, and objection by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you submit a request, we will do our best to respond as quickly as possible.

You have the right to lodge a complaint with a Data Protection Supervisory Authority regarding our collection and use of your Personal Data. For more information, if you are located in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

Sources of Personal Information

We obtain the categories of personal information mentioned above from the following categories of sources:

• Directly from you: For example, from the forms you fill out on our Service, preferences you express or provide via our Service, or from your purchases on our Service.

• Indirectly from you: For example, by observing your activity on our Service.

• Automatically from you: For example, through cookies that we or our service providers set on your device while you navigate through our Service.

• From service providers: For example, external vendors for monitoring and analyzing the use of our Service, external vendors for payment processing, or other external vendors that we use to provide the Service to you.

Use of Personal Information for Business or Commercial Purposes

We may use or disclose the personal information we collect for "business purposes" or "commercial purposes," which may include the following examples:

 

To operate our service and provide you with our service.

To provide support and respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our service.

To fulfill the reason for which you provided the information. For example, if you share your contact details to ask a question about our service, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery.

To respond to requests from law enforcement agencies and as required by applicable law, court orders, or governmental regulations.

As described to you at the time of collecting your personal information.

For internal administrative and auditing purposes.

To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activities, including, when necessary, prosecuting those responsible for such activities.

Note: The examples provided above are illustrative and not meant to be exhaustive. For more details on how we use this information, please refer to the section "Use of Your Personal Information."

If we decide to collect additional categories of personal information or to use the personal information we have collected for materially different, unrelated, or incompatible purposes, we will update this privacy policy.



Sharing of Personal Information

We may share your personal information identified in the categories above with the following categories of third parties:

• Service providers
• Payment processors
• Our affiliates
• Our business partners
• Third-party vendors to whom you or your representatives authorize us to disclose your personal information in connection with products or services we provide to you.

Sale of Personal Information of Minors Under 16 Years

We do not knowingly collect personal information from minors under the age of 16 through our service, although certain third-party websites we link to may do so. These third-party websites have their own terms of service and privacy policies, and we encourage parents and legal guardians to monitor their children's internet usage and instruct their children never to provide information on other websites without their consent.

We do not sell the personal information of consumers that we actually know to be under the age of 16, unless we receive explicit consent (the "right to opt-in") from the consumer who is between 13 and 16 years old, or from the parent or guardian of a consumer under the age of 13. Consumers who consent to the sale of personal information may opt out of future sales at any time. To exercise the right to opt out, you (or your authorized representative) can submit a request to us by contacting us.

If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient details to enable us to remove that information.

Do Not Sell My Personal Information

You have the right to opt out of the sale of your personal information. Once we receive and confirm a verifiable request from you, we will stop selling your personal information. To exercise your opt-out right, please contact us.

The service providers we work with (such as our analytics or advertising partners) may use technology on the service that sells personal information. If you want to opt out of the use of your personal information for interest-based advertising purposes and these potential sales, you can do so by following the instructions below.

Please note that each opt-out is specific to the browser you are using. You may need to opt out in each browser you use.

Website

You can choose to receive personalized advertisements displayed by our service providers by following the instructions on the service.

The opt-out places a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies that your browser has stored, you will need to opt out again.

Mobile Devices

Your mobile device may offer you the ability to opt out of the use of information about the apps you use to show you advertisements that are targeted to your interests:

• "Opt out of interest-based ads" or "Opt out of ad personalization" on Android devices
• "Limit Ad Tracking" on iOS devices

You can also stop the collection of location data from your mobile device by changing the preferences on your mobile device.

Our Service does not respond to Do Not Track signals.

However, some third-party websites track your browsing activities. If you visit such websites, you can set your preferences in your web browser to inform websites that you do not wish to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Children's Privacy

Our Service is not directed at individuals 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 information, please contact us. If we become aware that we have collected personal information from someone under the age of 13 without parental consent verification, we will take steps to remove that information from our servers.

If we must rely on consent as a legal basis for processing your information and your country requires parental consent, we may require the consent of your parent before we collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly encourage you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will notify you via email and/or a prominent notice on our Service prior to the change becoming effective, and we will update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

If you have any questions about this Privacy Policy, please contact us via email at: support@elleloom.care