Effective: May 8th, 2024

Welcome to ELETY website! We value your privacy and are committed to protecting your personal data. This Privacy Policy outlines how we collect, use, share, and safeguard your personal information when you use our personalized clothing style consultation services.

If you are a US resident (in particular California, Colorado, Connecticut, Nevada, Utah, Virginia resident), please see our Notice for US Residents below for information regarding your rights.

If you are a resident of the European Union, United Kingdom, or EEA, you may have additional rights to access, delete and restrict use of your data, as described in this Privacy Policy.

1. INFORMATION ABOUT US

When we refer to ELETY website and services, “we”, “our” or “us” we mean Elety sp. z o. o., the owner and provider of this Website and the Service.

Registered address: Młyńska 16/8, 61-730, Poznań, Poland

Email address: [email protected]

In accordance with Data Protection Laws (such as EU Regulation 2016/679 General Data Protection Regulation (“GDPR”)) and RODO, ELETY is the data controller unless otherwise stated.

2. WHAT INFORMATION WE COLLECT ABOUT YOU AND ON WHAT LEGAL GROUND

When we mention “personal data“, we mean any information relating to an individual that can identify them, directly or indirectly. Please keep in mind that we do not collect any special categories of personal data about you, which includes information about your race, ethnicity, beliefs, sexual orientation, political views, health, or biometric data.

We may collect following personal information:

Information You Provide

Fit profile information like age, measurements (height, weight, body shape), your photos reference clothing items or brands, which you provide to us. We use your measurements as they are – and we don’t infer other information from them. This processing is based on the contract legal ground and necessary to provide you with services you requested.

Registration Information (your name, email) is collected for delivering course’s services.

Contact Information (your name, email, phone number, and mailing address) is collected for communication and service delivery.

Name, surname, email, contact details with your consent for direct marketing purposes or on other occasions where we ask you for consent, using the data for the purpose which we explain at that time.

Payment and Billing Information. We do not store this data; it’s processed directly by our payment gateways like PayPal/Stripe.

Information Automatically Collected

When you visit the website or interact with emails that we send to you, we passively collect information from you, including your internet protocol address (“IP address”), browser type, operating system, device identifier, device model, software version, or mobile or ISP carrier information. We and our third-party partners use cookies and other technologies to collect information about your visit to the website, such as the date and time of your visit, the information you searched to find the website, your activity on the Website, and your clicks on our ads. The data collected on our Website may include anonymous “traffic information” provided by the host or a similar provider of such data (such as Google Analytics, Hotjar), which does not personally identify you. This data is of a statistical nature and covers details such as the pages on our Website that visitors frequently visit and the duration of their stay on specific pages. It also may include the data about the browser, network, or device utilized for visiting our Website. For further information about Google Analytics and opt-out options, please be sure to check out the information in Section 8 below. Additionally, upon visiting our Website, we may retain your IP address and a unique device identifier. This assists us in identifying server-related issues, administering our Website, and presenting content in alignment with your preferences.

The legal basis for such processing of personal information lies in our legitimate interest to analyze and enhance the performance of our Website and user experience. However, this does not imply that we track your online activities while using our Services.

Cookies are small files which may be stored on your computer during your use of the website and contain data about your use of the website. We use session cookies (which expire when you close your browser) and persistent cookies (which stay on your computer until you delete them or after a specified expiry date) to understand more about your activity on the website.

Please see Cookie Policy for details about how we use cookies and other tracking technologies and how you can control the cookies set on your browser.

Where permitted by law, this Privacy Policy does not limit our use or disclosure of de-identified, aggregate, pseudonymous or anonymous information, and we reserve the right to use and disclose such information to our partners, advertisers, and other third parties at our discretion.

3. WHAT WE USE YOUR INFORMATION FOR

We may use the personal information we collect for:

• Offering personalized clothing style advice;
• Responding to your inquiries and providing service updates;
• Payment processing;
• Website enhancement and improving user experience;
• Complying with legal obligations (including enforcing our terms of service), safety, security, accounting, audit, and business/asset sale (or similar) purposes according to applicable laws, such as tax and consumer protection laws.

4. THIRD PARTY WEB SITES AND SERVICES. INFORMATION SHARING AND DISCLOSURE

We may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to, payment handling, search engine facilities, advertising and marketing. The providers of such services do not have access to certain personal data provided by you. Any data used by such parties is used only to the extent required by them to perform the services that requests. Any use for other purposes is strictly prohibited.

To help us provide you with the best service, we work with third party analytics providers. This information is for internal use only and can’t be shared. It’s just for us to help us improve our services for you. We will not rent or sell your personal data to any third parties, but we may share your information from tools like log files, device identifiers, and location data, with third-party organizations that provide automatic data processing technologies for the website. We do not control or influence these third parties’ tracking technologies or how they may be used.

Google Analytics is a web analytics service provided by Google, Inc. Address: Google, Google Data Protection Office, 1600 Amphitheater Pkwy, Mountain View, CA 94043, USA. Google privacy policy.

Hotjar is a web analytics service provided by HotjarLtd., Dragonara Business Centre. 5th Floor, Dragonara Road, Paceville StJulian’s STJ 3141.USA. Hotjar privacy policy

Kajabi is a web analytics and marketing service provided Kajabi LLC, 17100 Laguna Canyon Rd Suite 100 Irvine, CA 92603, USA. Kajabi Privacy Policy

Payment processing providers, such as Stripe and Paypal (United States) help us to process payments.

Please note that while integrating external tools and services we choose legal entities that can assure they apply all necessary technical and organizational measures to protect personal data. However, we cannot guarantee the security of any information transmitted from us to any such legal entity. We are not responsible for any accidental loss or unauthorized access to your personal data through the fault of such legal entities. These legal entities are separately responsible for their privacy policies and practices.

We may disclose information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

5. CHILDREN’S PRIVACY

Our website and service are not intended for children under 18. Therefore, we do not knowingly collect or solicit any personal information from children under 18. If you are under 18, do not use or provide any information about yourself, including your email address. If we learn that we have collected personal information from a child under 18 without the parental consent verification, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.

6. DATA RETENTION

Please keep in mind that one of our most important principles is data minimization, therefore we collect only the minimum amount of information about you, which is required to provide you with our Service, and store it no longer than our relevant purpose requires.

We will generally retain your personal information for as long as we need it for a lawful purpose. We will keep your personal data (i) to perform the contract between you and us, such as enforce our Terms and Conditions, and (ii) toсomply with our legal obligations, for instance we may keep your information for up to for 5 years to respond to any questions or complaints or to maintain financial and other records in accordance with applicable laws and regulations. Your fit profile information will be retained for a period not exceeding six months from the date of collection, unless otherwise required by law or for legitimate business purposes. After this period, your data will be securely deleted from our systems to ensure that it is not retained longer than necessary for the purposes for which it was collected.

7. DATA SUBJECT RIGHTS

The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects.

You may contact us [email protected] to exercise any of the rights you are granted under applicable data protection laws.

If you are a resident of the European Union, United Kingdom, or EEA, you have:

(A) Right to access

You may ask us whether we collect or use any of your personal data and, if so, to receive access to that data in the form of a copy.

Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, we will provide you with a date when the information will be provided. If for some reason access is denied, we will provide an explanation as to why access has been denied.

(B) Right to rectification

You have the right to have your data rectified if it is inaccurate or incomplete. Upon request, we will correct inaccurate personal data about you and, taking into account the purposes of the processing, complete incomplete personal data, which may include the provision of a supplementary statement.

(C) Right to erasure

You have the right to have your personal data erased. This means that we will delete your data. Erasure of your personal data only takes place in certain cases, as prescribed by applicable laws and listed in Article 17 of the General Data Protection Regulation (GDPR). This includes situations where your personal data is no longer necessary for the purposes for which it was originally processed and situations where your data was processed unlawfully. Due to the way in which we maintain certain services, it may take some time before backup copies are erased.

(D) Right to restriction of processing

You have the right to obtain a restriction on the processing of your personal data. This means that we will suspend the processing of your data for a certain period. Circumstances which may give rise to this right include situations where the accuracy of your personal data is contested, and we need some time to verify its (in)accuracy. This right does not prevent us from continuing to store your personal data. We will inform you before the restriction is lifted.

(E) Right to data portability

Your right to data portability entails that you may ask us to provide you with your personal data in a structured, commonly used and machine-readable format, and have such data transmitted directly to another controller, where technically feasible. Upon request and where this is technically feasible, we will transmit your personal data directly to the other controller.

(F) Right to object

You have the right to object to the processing of your personal data. This means you may ask us to no longer process your personal data. This only applies if the ‘legitimate interests’ ground (including profiling) constitutes the legal basis for processing. You can object to direct marketing at any time and at no cost to you if your personal data is processed for this purpose, which includes profiling to the extent that it is related to direct marketing. If you exercise this right, we will no longer process your personal data for such purposes.

You have the right to complain to a data protection authority. If you are located in the European Union, you can have recourse to the European Data Protection Supervisor or the national data protection authority of the state of your residence.

You may withdraw your consent at any time by following the specific instructions concerning the processing for which you provided your consent. For example, you can withdraw consent by clicking the unsubscribe link in the email.

You may also contact [email protected]. For more information on how you can withdraw your consent for cookies and similar technologies we use when you visit our website, please check our cookie policy.

Notice for US Residents

If you are a US resident, you have the rights to access, edit, and delete your personal information can be found below.

A) The right to opt-out of the sale of your personal information. We do not sell your personal information.

B) The right to request deletion of the personal information that we have collected from you, subject to certain exemptions (for example, where the information is used by us to detect security incidents, debugging or to comply with a legal obligation).

C) The right to know (request disclosure of) the personal information we collected about the consumer, from whom it was collected, why it was collected, and, if sold, to whom.

D) The right to nondiscriminatory treatment for exercising your privacy rights, subject to certain limitations.

E) The right to initiate a private cause of action for data breaches.

G) The right to correct inaccurate personal information.

You can submit a right-to-know or other request online by contacting us via email at [email protected].

We have 45 days to respond to a verifiable consumer request. This period may be extended by another 45 days when necessary based on complexity and volume of requests.

Please note, when making a verifiable request, you will need to:

• Provide information for your identification and residency verification, including name, address, email, and security questions.
• Clearly describe your request.
• If an authorized agent is involved at your end, they must provide written authorization or a power of attorney.

If we can’t verify your identity or connection to the request, we may ask for more information or documentation. We might also use third-party verification services to ensure data protection and proper handling of your request. The personal data provided by you for your verification will only be used for that purpose and deleted afterward.

We do not engage in the practice of selling and have not sold your personal information to any party, including in the prior 12 months.

8. HOW TO OPT OUT

You may choose to opt-out from our marketing emails or prevent this Website from aggregating and analyzing your actions while using the Website as described below.

If you prefer not to receive marketing emails from us, you have the option to opt-out or unsubscribe by contacting us via email [email protected] or clicking the “Unsubscribe” link at the bottom of our communications. If you have multiple email addresses, you will need to opt-out for each address individually to be excluded from our active database.

You have the option to control and manage the gathering and handling of data associated with your use of the Website by following the instruction provided below. It is important to keep in mind that opting to disable all cookies could impact the functioning of the Website; certain features that contribute to the Website’s efficiency might not operate as intended.

Google Analytics: Should you wish to refrain from being tracked by Google Analytics, you can install and activate the Google Analytics Opt-out Browser Add-on (by Google). Furthermore, you have the ability to manage cookies and/or delete cookies that have already been established by Google Analytics by accessing your browser settings. Detailed information regarding Google Analytics’ data practices and relevant instructions are accessible at Google webpage about Using Google Analytics.

9. DATA SECURITY

We employ industry-standard security measures, including encryption and access controls, to safeguard your data. We also advise you to protect your data, particularly in public spaces and online interactions.

10. POLICY UPDATES

This policy may be updated periodically to reflect changes in our practices or regulations.

11. CONTACT INFORMATION

If you have questions or concerns about this policy or your personal data, contact us by e-mail [email protected].