1.1. Eluxit and its affiliates (“Eluxit,” “us,” “we,” or “our”) recognize and respect the importance of maintaining the privacy of our Users. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at https://www.eluxit.com/terms (the “Terms”). This Privacy Notice describes the types of information we collect from you when you visit our Site or mobile application (together the “Site”) or use our Service. This Privacy Notice also explains how we may process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information.
1.2. Eluxit is the data controller in respect of the processing activities outlined in this Privacy Notice. Our registered office is 1229 Wilshire Blvd., Santa Monica, CA 90403 and our registration number is [NUMBER]. Information may also be collected by additional data controllers as listed below.
1.3. “Personal Information” means any information that refers to, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law.
- Information We Collect
2.1. We collect information from you when you choose to visit our Site or use our Service. In order to access or use the Service, or make a purchase through the Site, you will be required to provide us with certain Personal Information. We also collect Personal Information when you request information from us, sign up for newsletters or alerts or our email lists, complete online forms, or contact us for any other reason. If you use the Service by logging in through Facebook or any other third-party login service, we may also receive Personal Information about you as provided by Facebook or such other third-party login service. Please check such third-party service’s policies in order to understand what information we receive.
2.2. Examples of the Personal Information that we collect from you may include your name, email address, phone number, bank account details, billing address, birth date, credit card details including BIN number and last four digits, and device ID.
2.3. We also collect any materials, including images, photos, or documents you may upload to the Site or your browsing history on the Site.
2.4. In addition, when you use the Site, certain information may be automatically gathered about your computer or mobile device, such as operating system, IP address, and, subject to your consent as may be required under applicable law, geographic location, as well as your browsing history and any information regarding your viewing and purchase history on our Site.
2.5. It is your voluntary decision whether to provide us with any such Personal Information but, should you decline to provide such information we may not be able to register you to the Site or provide you with the Service.
- Eluxit’s Use of Personal Information
We and any of our trusted third-party subcontractors and service providers may use the Personal Information we collect from and about you for any of the following purposes:
(i) to provide you with the Site or Service;
(ii) to respond to your inquiries or requests, or contact and communicate with you;
(iii) to develop new products or services and conduct analyses to improve our current content, products, and services;
(iv) to provide you with customized content, targeted offers, and advertising on the Site, on other third-party sites or apps you may visit, or via e-mail, including alerts for specific searched deals;
(v) to contact you with informational newsletters and promotional materials relating to our Site and Service;
(vi) to review the usage and operations of our Site and Service;
(vii) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below);
(viii) to prevent fraud, protect the security of our Site and Service, and address any problems with the Site or Service; and
(ix) to provide customer support.
3.2. Statistical Information
By analyzing all information that we receive, including information concerning users, we may compile statistical information across a variety of platforms and users (“Statistical Information”). Statistical Information helps understand trends and consumer needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. Statistical Information is anonymous and aggregated, and we will not link Statistical Information to any Personal Information. We may share such Statistical Information with our partners, without restriction, on commercial terms that we will determine at our sole discretion.
We, or our service providers or subcontractors, may use analytics tools (“Tools”) to collect information about the use of the Site or Service. Such Tools collect information such as how often users visit the Site, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Site. The Tools may collect certain Personal Information and may link such Personal Information to specific information stored in our customer database. We use the information we get from the Tools to improve our Site and Service.
3.4. Legal Use
We may use or disclose your Personal Information as required or permitted by any applicable law.
- Disclosure of Information
We may share your information, including Personal Information, as follows:
4.1. Business Partners, Service Providers, Affiliates, and Subcontractors
We may disclose information, including Personal Information we collect from or about you, to our trusted service providers, business partners, affiliates, subcontractors, who may use such information to:
(i) assist with providing the Site or Service to users;
(ii) aid in our understanding of how users are using the Site and Service;
(iii) provide targeted offers and advertising to users on the Site, as well as on other mobile applications or sites users choose to visit.
4.2. International Transfer
We may use subcontractors and service providers and have business partners and affiliates who are located in countries other than your own and send them information we receive (including Personal Information). We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice. You hereby consent to such international transfer. In cases where you explicitly request or give consent to such transfer, we may transfer certain Personal Information to an entity in a country without the same level of privacy protection described in this policy.
4.3. Business Transfers
We may transfer our databases containing your Personal Information if we sell our business or part of it.
4.4. Disclosure Related to Law Enforcement
We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or digital content, including in the event of any User suspected to have engaged in illegal or infringing behavior. We may also share your Personal Information with third-parties:
(i) if we believe in good faith that disclosure is appropriate to protect our rights, property or safety (including the enforcement of the Terms and this Privacy Notice);
(ii) to protect the rights, property or safety of third parties;
(iii) when required by law, regulation subpoena, court order or other law enforcement related issues; or
(iv) as is necessary to comply with any legal and/or regulatory obligation. You can request such Personal Information as specified herein by emailing us at firstname.lastname@example.org.
4.5. Other Uses or Transfer of Your Information
We allow you to use our Site and Service in connection with third-party services, sites, and/or mobile applications. If you use our Site and/or Service with or through such third parties, we may receive information (including Personal Information) about you from those third parties. Please note that when you use third parties outside of our Site, their own terms and privacy policies will govern your use of those services.
- Protection of Personal Information
We make efforts to follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
- Data Controllers
If you have not disabled third party cookies (please see section on Cookies below), and you use our Site or Service, additional third parties may also be serving as controllers in connection with the collection of your Personal Information.
- Your Rights Regarding Our Use of Certain Information
You have certain rights concerning the Personal Information that we and our co-controllers collect and retain, as detailed below. For any requests to exercise such rights with respect to information held by our co-controllers, please contact the applicable co-controller directly. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information or comply with any of your requests, as outlined below.
7.1. Right of Access and Data Portability.
You have a right to know what Personal Information we collect from you and, in some cases, to have that information communicated to you. Subject to the limitations of applicable law, you may be entitled to obtain from us a copy of the Personal Information that you have provided to us (excluding information that we obtained from other sources) in a structured, commonly-used, and machine-readable format, and you may have the right to request that we transmit such Personal Information to another party. If you wish to exercise this right, please contact us letting us know what information in particular you would like to receive or transmit by emailing us at email@example.com. Subject to applicable law, we may charge you a fee for transmittal of such information. Please note that we may not be able to provide all requested information, such as an instance in which the requested information includes Personal Information about another person. Where we are not able to provide you with the requested information, we will provide reasonable explanation regarding such an inability, to the extent possible. We will try to respond to any request for a right of access in a timely manner.
7.2. Right to Correct Personal Information.
Subject to the limitations imposed by applicable law, you may request that we update, correct, or delete inaccurate or outdated Personal Information, or that we suspend the use of Personal Information, the accuracy of which you may contest, while we verify the status of that Personal Information. We will correct your Personal Information within a reasonable time from the receipt of your written request therefor sent by email to firstname.lastname@example.org.
7.3. Deletion of Personal Information.
In certain circumstances, you have a right to request that we delete the Personal Information we have retained. Should you wish to have any Personal Information deleted, please contact us using the contact information below. Subject to applicable law, we will delete Personal Information provided to us by a user within a reasonable time from the receipt of a written (including via email) request by such user to delete the collected Personal Information. We cannot restore information once it has been deleted. Please note that, to ensure that we do not collect any further Personal Information, you should also delete our mobile application from your mobile devices and terminate your Profile, as well as clear our cookies from any device on which you have accessed the Site or Service. We may retain certain Personal Information (including following your request to delete) for audit and record-keeping purposes, as well as other purposes that are permissible or required under applicable law. We may also retain your information in an anonymized form.
7.4. Account Deactivation.
You may request that we deactivate your Profile by contacting us using the information below. In order to deactivate your Profile, we may ask you for additional information.
7.5. Direct Marketing Opt-Out.
You may change your mind at any time about your election to receive marketing communications from us and/or having your Personal Information processed for direct marketing purposes. If the event that you wish to opt out of receiving future marketing communications, please notify us by contacting us as detailed in this Privacy Notice. We will process your request as soon as reasonably possible, however, your request to opt out may not be effective immediately.
7.6. Right to Object.
Subject to applicable law, you may have the right to object to processing of your Personal Information, including for the purpose of direct marketing.
7.7. Supervisory Authority.
If you are a European Citizen, you may have the right to submit a complaint to the relevant supervisory data protection authority.
- EU Data Subjects
This section applies if you are an individual located in the European Union or European Economic Area (collectively, “EU”) (“EU Data Subject”). For these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland.
8.2. Data Controller.
Eluxit is the data controller for the processing of your Personal Information.
8.3. Your Rights.
Subject to applicable law, you have the following rights in relation to your Personal Information:
8.3.1. Right of Access
If you ask us, we will confirm whether we are processing your Personal Information and, if so, provide you with a copy of that Personal Information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
8.3.2. Right to Rectification
If your Personal Information is inaccurate or incomplete, you are entitled to have it rectified or completed. If we have shared your Personal Information with others, we will tell them about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Information so that you can contact them directly.
8.3.3. Right to Erasure
You may ask us to delete or remove your Personal Information and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion). If we have shared your data with others, we will tell them about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Information so that you can contact them directly.
8.3.4. Right to Restrict Processing:
You may ask us to restrict or ‘block’ the processing of your Personal Information in certain circumstances, such as where you contest the accuracy of that Personal Information or object to us processing it. We will tell you before we lift any restriction on processing. If we have shared your Personal Information with others, we will tell them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Information so that you can contact them directly.
8.3.5. Right to Data Portability:
Effective 25 May 2018, you have the right to obtain your Personal Information from us that you consented to give us or that is necessary to perform a contract with you. We will give you your Personal Information in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
8.3.6. Right to Object:
You may ask us at any time to stop processing your Personal Information, and we will do so:
(i) If we are relying on a legitimate interest to process your Personal Information — unless we demonstrate compelling legitimate grounds for the processing; or
(ii) If we are processing your Personal Information for direct marketing.
8.3.7. Rights in Relation to Automated Decision-Making and Profiling
You have the right to be free from decisions based solely on automated processing of your Personal Information, including profiling, that affect you, unless such processing is necessary for entering into, or the performance of, a contract between you and us or you provide your explicit consent to such processing.
8.3.8. Right to Withdraw Consent
If we rely on your consent to process your Personal Information, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your prior consent.
8.3.9. Right to Lodge a Complaint with the Data Protection Authority
If you have a concern about our privacy practices, including the way we have handled your Personal Information, you can report it to the data protection authority that is authorized to hear those concerns.
8.4. You may exercise any of the rights enumerated in Section 8.3 by contacting us as indicated under the “Comments and Questions” section below.
8.5. Legitimate Interest.
- Data Retention
Subject to applicable law and our regulatory obligations, we retain information, as necessary, for the purposes set forth above. We may delete information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth above.
- Cookies and Similar Technologies
10.1. “Cookies” Defined
10.1.1. A “cookie” is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this visitor returns. A “session cookie” is temporary and will remain on your device until you leave the Site. A “persistent” cookie may be used to help save your settings and customizations across visits. It will remain on your device for much longer or until you delete it. First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies. Information may also be collected through web beacons, which are small graphic images (“pixel tags”), which typically work in conjunction with cookies to identify users and user behavior. These may be shared with third parties.
10.1.2. We may use the terms “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above.
10.2.2. The specific names and types of the cookies, web beacons, and other similar technologies used may change from time to time. However, the cookies generally fall into one of the following categories:
(i) Necessary Cookies: These are necessary in order to allow the Site and Service to function properly. They enable you to access and explore the Site or access different services, applications, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled.
(ii) Functionality Cookies: These remember your settings and preferences (such as language or regional preferences) and assist with personalizing your experience and offering enhanced functionality and content.
(iii) Security Cookies: These assist with identification and prevention of security risks. They may be used to store your session information and prevent others from changing your password without your login information.
(iv) Performance Cookies: These assist with collecting information that provides an understanding of how users use the Site or Service, such as frequency with which messages or specific pages are viewed or the amount of time spent on a given page. This assists with improvement to the performance of the Site or Service.
(v) Analytic Cookies: These assist with gauging the popularity of features of the Site or Service among users and provide insight regarding improvements to the Site or Service.
(vi) Advertising Cookies – The purpose of these is to deliver content, including ads relevant and meaningful to you and your interests. They may also be used to deliver targeted advertising or to limit the number of times you see an advertisement. This assists with tracking the efficiency of advertising campaigns, both for our own Site and Service and for other websites.
10.3. How to Adjust Your Preferences
10.3.1. Most web browsers are initially configured to accept cookies, but you can modify this setting so that your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Site or Service may function improperly when cookies are disabled or removed.
10.3.2. By modifying your device settings, you can prevent your device’s advertising identifier from being used for interest-based advertising, or you can reset your device’s identifier. Typically, you can find the identifier preferences under “privacy” or “ads” in your device’s settings, although these may vary depending upon the device.
10.3.3. Adjusting your preferences as described in this section does not mean you will no longer receive advertisements, it only means the advertisements you see will be less relevant to your interests.
10.4. Third-Party Cookies Used by Eluxit
(i) Facebook – Analytics (www.facebook.com)
(ii) Google – Google Analytics/ Google Adsense
(iii) Other Third-Party Sites
- Third-Party Applications and Services
All use of third-party applications or services is at your own risk and subject to such third-party’s privacy policies.
Subject to your consent, and as required under applicable law, we may send you email or other messages or a newsletter about Eluxit, the Site, or the Service. You may remove your Personal Information from our mailing list and stop receiving future communication from us by following the UNSUBSCRIBE link located at the bottom of each communication or by emailing us at email@example.com. You will also be given the opportunity to unsubscribe from commercial messages in any such email or message sent, as well as through your Profile settings on the Site or Service. Please note that we reserve the right to send you service-related communications, including service announcements and administrative messages relating to your Profile, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may deactivate your Profile.
We do not knowingly collect personally-identifiable information from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has registered for a Profile without parental permission, please inform Eluxit immediately.
While using the Site or Service, you will be asked to accept the terms of this Privacy Notice. If you do not agree with the terms herein, please do not use the Site or the Service. We may update this Privacy Notice from time to time and users will be notified of such updates. We will post the updated Privacy Notice on this page. Any new Privacy Notice will be effective from the date of your acceptance of the updated Privacy Notice.
- Comments and Questions
If you have any comments or questions about our Privacy Notice, or if you wish for us to amend or delete your Personal Information, please contact us at firstname.lastname@example.org.