Privacy Policy

Effective Date: 19/03/2024

Elo AI Ltd ("Elo AI", "we" or "us") respects your privacy. This Privacy Policy (this "Policy") describes how we process Personal Data (as defined below) we gather through our websites at https://elo.ai/, https://app.elo.ai/, https://live.elo.ai/, https://docs.elo.ai/, when you interact with Elo AI, or when you access the Elo AI platform (together, the "Platform"). It also tells you about your rights and choices with respect to your Personal Data, and how you can contact us if you have any queries or concerns.

In addition to the activities described in this Policy, we may process Personal Data on behalf of our commercial customers when they use services provided by Elo AI (the "Services"). We may process such Personal Data as a "data processor" of our commercial customers, which are the entities responsible for the data processing. To understand how a commercial customer processes your Personal Data, please refer to that customer's privacy policy.

1. Personal Data We Collect

In this Policy, "Personal Data" means any information relating to an identified or identifiable natural person. We may collect and process Personal Data about you in the ways outlined below. Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, you may not be able to benefit from our services if that information is necessary to provide you with them or if we are legally required to collect it.

Information provided by you

When you create an account. If you register for an Elo AI account, we will ask you to provide us with Personal Data including your name and contact details (email address and phone number), user profile picture, and the company you work for.
When you access our Platform. If you engage with our Platform and upload your company files, such as documents, presentations and photos, you may provide us with your Personal Data. Additionally, any meeting, call or chat that you connect our Platform to may be recorded and stored, and we may process Personal Data contained in such recordings.
When you contact us. If you contact us using a contact form, via email, or by other means, you may provide us with Personal Data, such as your name and contact details, the company you work for, and the content, date and time of our communications.

Information collected via automated means

Cookies and similar technologies. We use cookies and similar technologies (collectively "cookies") to ensure that our Platform functions properly, to improve our products and services and to assist with marketing campaigns. Cookies are small text files containing a string of alphanumeric characters. We and third-party partners collect information using cookies, pixel tags, or similar technologies. We and third-party service providers may use the following cookies:
- Functional cookies. Some cookies are strictly necessary to make our Platform available to you. For example, to provide login functionality, support payment processing or to allow you to fill out forms. We cannot provide you with the Platform without this type of cookie.
- Analytics cookies. We use cookies for website analytics purposes in order to operate, maintain and improve our Platform. We work with third parties such as Posthog and June.so for these purposes.
The information collected via such cookies may include information such as your IP address, time spent on the Platform, actions taken on the Platform, device information, searches, interactions, hardware information, and other related information.

Information collected from other sources

Information from Google. We may obtain Personal Data about you from Google if you choose to sign in using their services. The information we receive from Google may include your name, email address, language preference and profile picture.
Information from lead generators. We may obtain Personal Data about you from lead generators, such as Cognism. The information we receive from lead generators may include your name, email address and phone number.

2. How We Use Personal Data

We will only process your Personal Data based on a valid legal ground. The table below describes the legal ground by purpose.

Purpose	Description	Legal ground
Providing the Platform	We use Personal Data about you to operate, maintain, and provide our Platform. For example, we use your Personal Data to create your account, set your preferred language and allow you to login.	We have a legitimate interest in using your Personal Data for the purpose of developing, hosting, and maintaining the Platform
Support	We use Personal Data to provide technical support, including diagnosing and resolving any issues you report.	We have a legitimate interest in using your Personal Data for the purpose of providing technical support
Fraud prevention	We use your Personal Data to keep our Platform secure and to identify and prevent fraud in the use of our Platform.	We need it to comply with a legal obligation, for instance to comply with a court order We have a legitimate interest in using your Personal Data for the purpose of preventing fraud
Customer relationship management	We may process your Personal Data for customer relationship management purposes.	We have a legitimate interest in using your Personal Data for the purpose of managing customer relationships
Communicating with you	We may use your email address and other Personal Data as necessary to contact you for administrative purposes such as to provide information that you request, to respond to comments and questions, or to ask you to provide feedback and complete surveys.	We have a legitimate interest in using your Personal Data for the purpose of communicating with you
Analytics and product development	We use Personal Data about you to analyse usage trends and preferences to improve our Platform, as well as to develop new products, services, features, and functionalities.	We have a legitimate interest in using your Personal Data for the purpose of evaluating and improving our products or services
Marketing	We may process your Personal Data for marketing purposes, such as to develop and provide promotional materials or events that may be relevant, valuable or otherwise of interest to you.	You give us consent to do so We have a legitimate interest in using your Personal Data for the purpose of delivering marketing and advertising materials
Administrative and legal purposes	We may use your Personal Data to enforce this Policy, our Terms of Service, to defend our legal rights and to comply with our legal obligations and internal policies.	The processing is necessary for entering into, or performance of a contract to which you are a party We need it to comply with a legal obligation, for instance to comply with a court order We have a legitimate interest in using your Personal Data for the purpose of addressing administrative and legal issues
Aggregation	We may aggregate or otherwise de-identify Personal Data and use the resulting information for other business purposes, as permitted by applicable law.	We have a legitimate interest in using your Personal Data for the purpose of aggregating and de-identifying the data

3. How We Share Your Personal Data

We may share your Personal Data with third parties in the following circumstances:

Service providers, vendors and analytics partners. We work with third party service providers to operate our Platform, including for IT-hosting and maintenance, data processing and caching, AI-related processing, payment processing, and other services. These third parties may have access to or process your Personal Data as part of providing those services to us. In addition, we use analytics service providers such as Posthog and June.so to collect and process certain analytics data.
Legal. We may disclose your Personal Data to third parties if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We also reserve the right to disclose your Personal Data that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of our Platform and any facilities or equipment used to make our Platform available, or (v) protect our property or other legal rights, including to enforce our agreements, or the rights, property, or safety of others.
Merger. We may disclose or otherwise transfer Personal Data to an acquirer, investor, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, financing or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
Consent. We may also disclose your Personal Data with your permission.

4. Data Retention

We take measures to delete your Personal Data or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we need to retain certain information as required by law, including to comply with tax requirements, or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse or enforce our terms and conditions. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the relevant statute of limitations. For instance, if a user terminates their account we will retain the data on their account for 90 days.

5. Your Rights in Relation to Your Personal Data

Depending on where you reside, you may also have the following legal rights:

Access and Portability. You may ask us to provide you with a copy of the Personal Data we maintain about you, including a machine-readable copy of the Personal Data that you have provided to us, and request information about its processing.
Rectification and Deletion. You may ask us to update and correct inaccuracies in your Personal Data, or to have the information anonymised or deleted, as appropriate.
Restriction and Objection. You may ask us to restrict the processing of your Personal Data, or object to such processing.
Consent Withdrawal. You may withdraw any consent you previously provided to us regarding the processing of your Personal Data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
Complaint. You may lodge a complaint with the UK Information Commissioner's Office, who you can contact using the details found at www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner's Office, so please contact us in the first instance.

You may exercise these rights by contacting us using the contact details at the end of this Policy. Please note that there are exceptions and limitations to each of these rights.

6. Third Parties

Our Platform may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

7. Security

We make reasonable efforts to protect your Personal Data by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information, to the extent permitted by applicable law.

8. Children's Privacy

We do not knowingly collect, maintain, or use Personal Data from children under 18 years of age, and no part of our Platform is directed to children. If you learn that a child has provided us with Personal Data in violation of this Policy, then you may alert us by contacting us using the contact details at the end of this Policy.

9. Cross-Border Data Transfers

We use outsourced services in the United States ("U.S.") in order to support our business. If you choose to use our Platform from regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Data outside of those regions to the U.S. for storage and processing.

We will comply with applicable data protection laws when transferring your Personal Data outside of the UK. In particular we will rely on (i) UK adequacy regulations, (ii) contractual protections for the transfer of your Personal Data, or (iii) another valid data transfer mechanism. You may contact us as specified below for more information about the safeguards we use to transfer Personal Data outside the UK.

10. Changes to this Policy

We may update this Policy from time to time to reflect changes in our privacy practices. If we modify this Policy, we will indicate the date of the latest revision at the top of this Policy.

11. Our contact information

Should you have any queries regarding this Policy, about Elo AI's processing of your Personal Data or if you wish to exercise your rights with respect to your Personal Data, you can contact Elo AI by email: [email protected] or by writing to us at: 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE.