Last updated: June 25, 2021
Elayaa.com pays the utmost attention to the privacy of its visitors and users and is fully committed to protecting their personal information and using it correctly, in accordance with data protection legislation.
This policy describes how we collect and use personal information as well as the rights and choices available to our visitors and users with respect to such information.
We encourage you to read this policy and ensure that you fully understand and accept it before accessing or using any of our services.
1. Read carefully!
2. What information do we collect?
2.1. Information about Visitors and Users
We collect two types of information about our Visitors and Users:
- Unidentified and non-identifiable information pertinent to a Visitor or unidentified User that is made available to us or is automatically collected through your use of the Services ("Non-Personal Information"). Such Non-Personal Information does not allow us to identify the Visitor or User from whom it was collected. The Non-Personal Information we collect consists primarily of technical information for aggregate use, such as navigation and click-stream activity on the Services, session heatmaps and scrolls, and information that does not identify the Visitor's or User's device, operating system, Internet browser, screen resolution, language and keyboard settings, Internet service provider, referring/exit pages, date/time stamps, etc.
- Personally identifiable information, which is information that identifies an individual or may, through reasonable effort, result in the identification of an individual, or which may be private or sensitive in nature ("Personal Information"). The Personal Information we collect consists primarily of contact information (e.g., email address or phone number), billing information (name, physical billing address, payment method and transaction data) that is only collected from Users of the Paid Services, browsing or usage session data (IP address, geo-location and/or unique device identifier), data related to linked third party accounts (such as email or username of a linked PayPal, Google or Facebook account), digitized identification documents disclosed (such as ID card, driver's license, passport or official business registration documents), correspondences (including those made or downloaded through our Services) and any other Personal Information provided to us by Visitors and/or Users through their access and/or use of the Services. For the avoidance of doubt, any Non-Personal Information that is connected or related to Personal Information (e.g., for the purpose of improving the Services we offer) is considered and treated by us as Personal Information for so long as such connection or link exists.
2.2. Information Users
We may also collect similar information relevant to Visitors and Users of our Users' websites or services ("Users of Users"), solely for and on behalf of our Users (as described in more detail in Section 6 below.
2.3. Information on Candidates for Jobs elayaa.com
We also collect Information that is provided to us by candidates for elayaa.com job openings ("Candidates"), when they apply for any of the open positions posted at www.elayaa.com, by email or otherwise (as described in more detail in Section 7 below).
3. How do we collect this information?
We primarily use 3 methods:
- We collect information through your use of the Services. When you visit or use our Services, as well as when you browse our Site or a User's Site, register a user account, edit your User Site and upload information and content, and/or download and use Apps from elayaa. com and/or Mobile Apps, we are aware of this and routinely perform the collection and recording of such usage, sessions and related information, either independently or with the help of third party services as described in more detail in Section 8 below, including the use of "cookies" and other tracking technologies as described in more detail in Section 9 below.
- We collect information that you voluntarily provide to us. For example, we collect Personal Information that you provide to us when you register for our Services; when you access our Services through third party services such as Facebook or Google; when you make purchases; when you submit or upload such Personal Information when using any of our Services; and/or when you contact us directly, through any communication channel (e.g., contact form elayaa.com, email messages).
- We also collect information from third party sources, as described in Section 8 below.
4. Why do we collect this information?
We collect such Non-Personal Information and Personal Information for the following purposes:
- Provide and manage the Services;
- Further develop, customize and improve our Services, based on the common or personal preferences, experiences and difficulties of Visitors and Users;
- Provide our Users with ongoing customer service and technical support;
- Contact our Visitors and Users with generic or personalized service communications and promotional messages (as described in more detail in Section 10 below);
- Facilitate, sponsor and offer special contests, events and promotions, determine participant eligibility, monitor performance, contact winners and award prizes and benefits;
- Generate aggregate statistical data and other aggregate and/or inferred Non-Personal Information that can be used by us or our business partners to provide and improve our respective services;
- Strengthen our data protection and fraud prevention capabilities;
- Consider Candidates' applications for employment positions at elayaa.com (as described in more detail in Section 7 below);
- Comply with all applicable laws and regulations.
We will use Your Personal Information only for the purposes set forth in Section 4, wherein:
- our use of your Personal Information is necessary for the performance of a contract or to carry out the steps necessary to enter into a contract with you (for example, to provide you with a quotation for our services, to provide customer service and technical support);
- our use of Personal Information is necessary to comply with a legal obligation or requirement to which we are subject;
- our use of your Personal Information is necessary in pursuit of a legitimate business interest (for example, to maintain and improve our Services by identifying user trends and the effectiveness of elayaa.com campaigns and identifying technical problems), provided that such use is always proportionate and respects your privacy rights.
Our Services are not available to persons under the age of 18. We do not ask for any Personal Information through our Services from anyone under the age of 18. We do not knowingly collect Personal Information from children under the age of 18. Parents and guardians are required to supervise their children's activities at all times.
5. Where do we store your information?
Personal information of elayaa.com visitors, users and users of elayaa.com users may be retained, processed and stored by elayaa.com, its affiliates and authorized service providers, in Europe and other jurisdictions as necessary for the proper provision of our Services and/or as required by law (as described in more detail below).
Information regarding candidates for elayaa.com job openings will be stored, processed and archived at the locations of the requested job position and as needed, in secure cloud storage hosted at Third Party facilities.
The affiliates and service providers of elayaa.com responsible for storing or processing your Personal Information on behalf of elayaa.com are individually and contractually committed to keeping it protected and secure, in accordance with industry standards and regardless of any less stringent legal requirements that may apply in their jurisdiction.
elayaa.com is responsible for the processing of Personal Information received, pursuant to regulation, and subsequently transferred to a third party acting as an agent on its behalf.
Upon request, elayaa.com will notify the User if it has any of his or her Personal Information.
You have the right to access, rectify or request deletion of your Personal Information.
We will respond to your request within the timeframe required by local law or within a reasonable period of time.
Please note that the permanent deletion of your elayaa.com account also entails the deletion of all information about you from elayaa.com's databases. After completing this procedure, you will no longer be able to use the elayaa.com Services, your User Account and all related data will be permanently removed, and elayaa.com will not be able to restore your account or recover your data in the future. If you contact elayaa.com Support in the future, the system will not recognize your account and support personnel will not be able to locate your deleted account.
6. Users information
Elayaa.com may collect, store and process certain Non-Personal and Personal Information of Users of Users ("User User Information of Users"), solely on behalf of and at the instructions of its Users. For example, each of our Users may import their email contacts from third party services such as Gmail, or otherwise collect and manage them through their respective User Site. Such contacts are then stored at elayaa.com, on behalf of the User.
For such purposes, elayaa.com operates and shall be considered as a "Controller" of the processing and not as a "Data Processor" (as defined by both such terms in capital letters in the European Union General Data Protection Regulation) of such Users' User Information. Users who control and operate such User Sites shall be deemed "Responsible" for such User User Information and shall comply with all laws and regulations applicable to the collection and control of such User User Information, including all privacy and data protection laws in all relevant jurisdictions.
You are responsible for the security, integrity and authorized use of your Users' Users' Personal Information and for obtaining all consents and authorizations, as well as providing notice of processing, necessary for the collection and use of such information
elayaa.com cannot offer legal advice to Users or their Users' Users, so it recommends that all of them post and maintain clear and comprehensive privacy notices on their Users' Sites in compliance with applicable laws and regulations and ensure that all Users' Users carefully read these notices and agree to them. For more information on how elayaa.com handles Users' User Information (e.g., with respect to the particular notice to be provided to Users' Users and/or the consent to be obtained from Users' Users), see Sections 8, 12 and 13 below.
If you are a visitor, user or client of one of our Users, please read the following carefully: elayaa.com has no direct relationship with the individual Users of Users whose Personal Information it processes. If you are a visitor, user or client of one of our Users and you have a request or question regarding your Personal Information, please contact that User directly. For example, if you wish to access, correct, amend, or delete inaccurate information that is being processed by elayaa.com on behalf of its Users, please direct your request to the corresponding User (who is the "Responsible Party" for processing such data). Requests for removal of Personal Information of Users of Users, will be processed within the period of thirty (30) days. Unless otherwise indicated by our User, we will retain the Personal Information of its Users of Users for the period set forth in Paragraph 12 below.
If you are under the age of 18, please do not attempt to access any of the services offered by Elayaa.com, and please don't send any Personal Data about yourself to us, unless you are a School-based User with an account provided to you by your school. If we learn that we have collected Personal Data from somebody under the age of 18 who is not a School-based User, we will delete that information and that account as quickly as possible.
7. Apply for jobs in Elayaa.com
Elayaa.com invites all eligible Candidates to apply for open positions posted at www.elayaa.com, by sending us contact details and CV ("Candidate Information") by e-mail to [email protected], available on our Site or by any other means made available by us.
We understand that privacy and discretion are important to our Candidates; therefore, we agree to keep their information confidential and to use it solely for internal elayaa.com recruitment purposes (as well as to identify Candidates, evaluate their applications, make hiring and employment decisions, and contact Candidates by phone or in writing). Please note that elayaa.com may retain the information submitted by Candidates for a period not exceeding two years from the assignment or closing of the position applied for. This is in order to be able to reconsider the Candidates for other positions and opportunities in elayaa.com; in this way it will be possible to refer to the Information for future applications that they will submit and, in case of employment of the Candidate, for other business and employment opportunities related to his work in elayaa.com.
If you have already submitted your Candidate Information to elayaa.com and wish to access, update or delete it from the elayaa.com systems, please contact us at [email protected]
8. Sharing Personal Information with Third Parties
Elayaa.com may share your Personal Information with third parties (or otherwise grant them access) only in the following ways and cases:
8.1. Third Party Services
Elayaa.com works with a number of selected service providers whose services and solutions complement, facilitate and enhance ours. These include server hosting and co-location services, communications and content delivery networks (CDNs), data and information security services, billing and payment processing services, fraud detection and prevention services, web analytics, software development, and other information technology solutions dedicated to improving our services, email distribution and tracking services, session recording and remote access services, performance measurement services, overseas and/or remote training, data optimization and marketing content providers and our legal and financial advisors (collectively, "Third Party Services" or "Third Party Services").
Such Third Party Services may receive or otherwise have access to our Visitors' and Users' Personal Information and/or Users' Personal Information, in whole or in part, depending on their particular roles and purposes in order to facilitate and improve our Services and our business and may use them only for such purposes.
8.2. Enforcement, Legal Requirements and Duties
Where permitted by local data protection laws, elayaa.com may disclose or otherwise grant others access to Your Personal Information pursuant to a legal obligation, such as a subpoena, court proceeding, search warrant, court order, or under applicable law, if it believes in good faith that such conduct is required by law, with or without prior notice to You.
8.3. Protection and Security Rights
elayaa.com may share your Personal Information with others if it has a good faith belief that doing so will help protect the rights, property, or personal safety of elayaa.com, any User, a User of Users, or an individual in the general public, with or without prior notice to you.
8.4 Social Media Features and Frame Pages.
Our Services include certain Social Media Features and graphical elements (widgets), single sign-on features, such as the "Connect to Facebook" or "Sign up for Google" features, the "Facebook Like" button, the "Share" button or other interactive mini-programs ("Facebook Features"). These Social Media Features may collect information such as your IP address or the page you are visiting on our Site, and may set a cookie to enable them to function properly. Social Media Features are hosted by third parties or directly on our Services. Your interactions with these third party Social Media Features are governed by their policies and not ours.
In addition, our Services may allow you to share your Personal Information directly with third parties, such as through page framing techniques to deliver content to or from Third Party Services or others, while maintaining the look and feel of our Site and Services ("Frame"). You should be aware that if you choose to interact or share Personal Information through such Frames, you are in fact providing it to such third parties and not to us, and that such interactions and sharing are also governed by such third parties' policies and not ours.
8.5. APP by elayaa.com
In addition, by installing certain elayaa.com Apps, the User allows the respective provider to share and/or access certain Non-Personal and Personal Information about the User and/or its Users of Users. Such information includes, but is not limited to, contact information, messages, business/management applications and certain activities on the Services and/or the User's Site, which are stored and henceforth accessible through the User Account.
To further protect the privacy of you and your Users of Users, we contractually prohibit all Third Party Developers from matching Personal Information collected across the various User Sites and Services and sharing Personal Information of Users of Users except with other Apps installed on the same User Site or Service, for the purposes of that specific User Site or Service. elayaa.com does, however, have the right to access and use information collected and stored through the various User Sites and Apps, for the purposes of providing and improving the Services.
You are solely responsible for notifying your Users of the collection, processing and use of their respective Personal Information as well as notifying them of the transfer to elayaa.com and elayaa.com's processing of their respective Personal Information on their behalf.
In order to prevent the collection or sharing of Personal Information through elayaa.com APPs, the User should avoid installing Apps on their Site or compatible electronic device, or revoke the permission granted to the installed Apps, or simply uninstall them. You should be aware, however, that previously installed Apps may still retain certain information collected prior to revocation, so if you wish to delete such information, we suggest that you contact elayaa.com directly and ask them to do so.
8.6. Subsidiaries and Affiliates of elayaa.com
If we have a good-faith belief that such a change in control could materially affect the Personal Information we hold about you, we will notify you by email and/or post a prominent notice on our Site about this event and the choices you have regarding your Personal Information.
For the sake of clarity, elayaa.com may share your Personal Information in ways other than those described above only with your express approval or if we are legally obligated to do so.
In addition, elayaa.com may transfer, share, disclose or otherwise use Non-Personal Information in its sole discretion and without the need for further approval.
8.7. California Privacy Rights
California Civil Code Section 1798.83 permits users of the services offered by Elayaa.com who are California residents to request certain information regarding its disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email with "California Privacy Rights" in the heading to [email protected]
Elayaa.com, along with its marketing, analytics and technology partners, uses certain tracking and monitoring technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis and offer our Users and their Users of Users a better experience. For example, using these technologies, we are able to maintain and track our Users' preferences and authenticated sessions, to better protect our Services, to identify technical issues, user trends and campaign effectiveness, and to monitor and improve the overall performance of our Services.
Cookies: In order for certain of these technologies to function properly, a small data file ("cookie") must be downloaded and stored on your device. By default, we use various persistent cookies for the purposes of session and user authentication, security, maintaining your preferences (e.g., regarding language and default settings), connection stability (e.g., for media loading, e-Commerce functionality, etc.), monitoring the performance of our Services and marketing campaigns, and generally providing and improving our Services. If you wish to delete or block cookies, please refer to the help and support area of your Internet browser for instructions on how to locate the file or directory where cookies are stored. Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services or otherwise adversely affect your experience.
Clear Gifs: We and certain Third Party Services may employ a software technology called Clear Gifs (a.k.a. Web Beacons/Web Bugs), which allows us to improve our Services by measuring their effectiveness and performance. Clear Gifs are small graphics with a unique identifier, similar in function to cookies, but are not stored on your device, but instead are embedded within our Services.
Flash and HTML5: We and certain Third Party Services may also use certain tracking technologies known as "Flash Cookies" and "HTML5", primarily for advertising purposes. Various browsers may offer their own tools to remove or block such technologies.
Behavioural Targeting/Retargeting: Certain Third Party Services and third party ad networks may display advertisements on our Site, elayaa.com Apps and elayaa.com Mobile Apps or manage our advertising on other sites. These parties may use certain tracking technologies to collect certain information regarding your activity on the Services and various third-party services in order to provide you with targeted advertising based on your interests and preferences. You may opt out of receiving targeted advertisements from certain advertisers and ad networks by checking and following the procedure described here (www.youronlinechoices.com). Note that this does not, however, allow you to opt out of receiving all advertising, but that opting out will only affect the specific advertisement. You will continue to receive the advertising you have not opted out of.
Integration of User Data: We may receive information about you from other sources, including publicly available databases, or from third parties from whom we have purchased data, and combine this data with the information we already have about you. This allows us to update, expand and analyze our records, identify new customers and provide products and Services that may be of interest to you. If we obtain Personal Information about you from these third parties, we ensure that these parties contractually agree to inform you that your Personal Information will be transmitted to us and we take appropriate steps to ensure its accuracy before using it. If You provide us with Personal Information about others, or if others provide us with information about You, we will only use that information for the specific reason it was provided to us.
"Do Not Track" signals: We do not change our practices in response to a "Do Not Track" signal in the HTTP/HTTPS header from a browser or mobile application.
10. Communications from Elayaa.com
10.1 Promotional Messages
We may use your Personal Information to send you promotional content or messages via email, SMS, text messages, business calls and similar forms of communication from elayaa.com or our partners (acting on behalf of elayaa.com) through such means.
If you do not wish to receive such promotional messages or calls, you may notify elayaa.com at any time or follow the unsubscribe or discontinue instructions contained in the promotional communications you receive.
We take appropriate steps to limit the promotional content we send to you to a reasonable and proportionate level and to send you information that we believe may be of interest or relevant to you, based on the information we have about you.
10.2 Service and Billing Messages
elayaa.com may also contact you with important information regarding the Services or their use. For example, we may send you a notice (through one of our available means) if a particular Service is temporarily suspended for maintenance; respond to support requests or emails; send reminders or notices regarding upcoming payments or late payments for current or future subscriptions or installments; report abuse of your account; or communicate material changes to our Services.
It is important that you are always able to receive such messages. For this reason, you may not opt out of receiving such Service and Billing Messages unless you are no longer a Visitor or an elayaa.com User (which you can do by deactivating your account).
We may also contact You with Service or Billing-related messages and content. The User may not opt out of receiving such messages.
11. Access to your personal information
It is imperative that the User be able to exercise control over their Personal Information. For this reason, elayaa.com is implementing appropriate measures to allow the User to access, receive copies, update, modify, delete or limit the use of their Personal Information.
Before transmitting the requested Personal Information, we may ask you for additional information in order to ensure your identity and for security reasons. We reserve the right to charge a fee where permitted by law (e.g., in the event of an unfounded or excessive request).
You have the right to complain to your local data protection supervisory authority (but we recommend that you contact us first).
If a Visitor or User elayaa.com would like to receive copies of, access and/or ask us to make corrections to Personal Information stored with us (their or Users' Users) or would like to request a list of Personal Information (if any) about them that we have disclosed to third parties for direct marketing purposes, they are encouraged to contact us at [email protected]
We will make every reasonable effort to comply with your request in a timely manner (unless we need additional information for this purpose), subject to legal or other constraints.
Please note that you may also rectify, update or delete portions of such Personal Information yourself through your User Account settings.
Please note that the permanent deletion of your elayaa.com account also entails the deletion of all information about you from elayaa.com's databases. After completing this procedure, you will no longer be able to use the elayaa.com Services, your account and all related data will be permanently removed, and elayaa.com will not be able to restore your account or recover your data in the future. If you contact elayaa.com Support in the future, the system will not recognize your account and support personnel will not be able to locate your deleted account.
12. Data Storage
We may continue to store such Personal Information after you deactivate your User Account and/or stop using any particular Service, to the extent reasonably necessary to comply with legal obligations, resolve disputes regarding our Users or their Users of Users, prevent fraud and abuse, enforce contracts entered into, and/or protect our legitimate interests.
We have put in place a data storage policy that we apply to information that is disclosed to us. If your Personal Information is no longer needed, we will ensure that it is securely deleted.
Elayaa.com has implemented security measures to protect the Personal Information shared by you, including physical, electronic and procedural measures. Among other things, we offer secure HTTPS access to most areas of our Services; the transmission of sensitive payment information (e.g., credit card number) through our designated purchase forms is protected by an industry-standard SSL/TLS encrypted connection. In addition, we periodically monitor our systems for possible vulnerabilities and attacks and are constantly looking for new ways and Third Party Services to further enhance the security of the Services and the privacy protection of our Visitors and Users.
Regardless of the measures and efforts put in place by elayaa.com, we cannot and do not guarantee the absolute protection and security of your Personal Information, User Information of Users or other User Content uploaded, posted or otherwise shared with elayaa.com or anyone else. We therefore urge you to set strong passwords for your User Account and to avoid providing us with sensitive information whose disclosure could result in substantial or irreparable harm. In addition, because some areas of our Services are less secure than others (e.g., setting a "public" request on our blog or navigating to a non-SSL page) and because email and instant messaging are not recognized as secure forms of communication, we encourage you not to share any Personal Information in any of these areas or through any of these methods.
If you have any questions regarding the security of our Services, please contact us at [email protected]
14. Public forums and user content
Our Services offer publicly accessible blogs, communities and social channels. You should be aware that any information you provide in these areas may be read, collected and used by others who have access to it. To request removal of your Personal Information from our blogs, communities or social channels you should contact us at: [email protected]
In some cases, we may not be able to remove Your Personal Information from those areas. For example, if you use a third party application to post a comment (e.g., Facebook social plugin application) while you are logged into your profile with that third party, you must log into that application or contact your provider if you wish to remove Personal Information posted on the platform.
In any case, it is recommended not to post in these areas information (or use means to post information) that you do not wish to make public on these platforms.
If you upload any Content to your User Account or post or otherwise provide it as part of your use of any of our Services, you do so at your own risk.
We have put in place appropriate safeguards to protect your Personal Information. However, we cannot control the actions of other Users or members of the public who may access User Content, and we are not responsible for any circumvention of privacy settings or security measures in such cases. You understand and acknowledge that even after removal by you or us, copies of User Content may remain visible in caches or archives or where third parties (including any User of Users) have copied or stored such User Content. For the sake of clarity, you are advised against uploading or posting information that you do not wish to make public.
15. Updates and interpretation