Privacy Policy

  1. Who is responsible for the processing of your personal data?

This Privacy Policy governs the processing of Users’ personal data through the ēllu application (hereinafter, the “Application” or “App“) and the website www.ellu.app (hereinafter, the “Website“). The Application and the Website are the property of TU NUEVA RED DE COMUNICACIÓN S.L.U. (hereinafter, “ēllu“), with registered office at Paseo de la Castellana,144 – Planta 14º Letra B, 28046 Madrid, and tax identification number B86525086.

 

  1. How to contact us?

For any issue, suggestion, or question related to how we process the personal data of users, you can contact us at the email address protecciondedatos@ellu.app.

We also have a Data Protection Officer who you can contact at protecciondedatos@ellu.app or directly at dpd@ellu.app.

  1. What personal data do we collect and process?

In order to provide you with the services you request or for which you request information, we will ask you for certain personal data. For example, when you contact our Customer Service, request to receive commercial communications, create an account, or use our App and/or our Website. In the event that the User is under fourteen (14) years of age, the personal data will be provided by his/her parent or guardian, who must also provide his/her own personal data, which will be processed in accordance with this Policy.

In this regard, the personal data that may be processed by ēllu are divided into two categories:

(i) those data that the User (or the parent, or guardian in the case of Users under 14 years of age) provides both at the time of registration and during the use of the Application and/or the Website, or in subsequent communications with ēllu.

(ii) data that is automatically collected by ēllu when the User uses the Application and/or the Website.

The first category of data includes the following types of data, some of which are required and some of which are optional, at the User’s discretion:

  • Required data: first and last name, mobile phone number, email and postal address (the latter and last name, only in case of subscription to the Full Service Subscription (Premium Subscription) + Band, in order to be able to send you the Band).
  • Optional data: image, voice, date of birth.

Payments are processed through our payment provider Stripe, which is PCI DSS compliant. All payment information is handled, processed and verified by Stripe. ēllu does not store data about the payment method and/or card used during the payment process associated with the subscribed plan, and the entire process is conducted in a secure environment.

By providing personal data through the App and/or the Website, you warrant that you are over fourteen (14) years of age, or that you have the legal authorisation, right and freedom to provide said data according to the laws of your country and that all personal data provided are true and accurate, for which ēllu may ask Users to prove their age. The data provided by Users to prove this will be processed exclusively for this purpose and will not be stored.

If the user is under fourteen (14) years, it will be the parents, or legal guardian of the minor, who shall consent and accept, on behalf of the minor, the processing of personal data included in this Privacy Policy. For this purpose, the parent or legal guardian of the minor shall sign the corresponding authorization, which will be provided by ēllu, and forward it to ēllu to be kept on file.

References in this Privacy Policy to “User” shall also refer to parent(s) and/or legal guardian(s) in the case of minors under the age of fourteen (14).

Please note that you must inform ēllu of any changes to the identification data you have provided and, in any case, you will be responsible at any time for the truthfulness and accuracy of the same.

The second category of data includes the following additional types of data that enable particular features within our App and our Website. For example, we request access to your phone’s location data to record your itineraries and your contacts so that you can interact with them.

These personal data include your:

  • Geolocation data: GPS, IP address, location data of your device.

 

  • Device and navigation data: navigation and App usage data. This data may include: device model, operating system, App version, browser and mobile network.

 

  • Data relating to the use of the Application: strictly necessary SDK. These SDKs (Software Development Kits) help us to understand how you interact when using the App, gathering and providing information in an aggregated and anonymous form with the aim of improving the service, knowing the functionalities most and least used by Users, as well as the problems encountered by them and potential improvements. We use a token that identifies your device to send push notifications.

    We will not use this information for other purposes, nor will we share it with third parties.

    In accordance with the AEPD guidelines on audience measurement tools, we use these SDKs with strict privacy guarantees: the use of the information collected has a limited duration of 13 months, without automatic renewal, it is kept for a maximum of 25 months and the data is used exclusively to generate aggregated statistics that allow us to understand the performance and use of the Application.

    This information will never be used to make individualized decisions about users or to create behavioral profiles.

 

  • Furthermore, if you allow it, the Application may, in order to offer you the services and the different features, access the following elements of the mobile device (and the information stored in them): Microphone, stored files, camera, GPS and your contacts.

 

It is possible that in the future the features of the App may be increased and, therefore, that new categories and types of data may be processed. If this happens, we will inform you through the App and will proceed to modify this Privacy Policy if necessary. 

 

  1. What do we process your personal data for?

ēllu informs you that the personal data you provide us with as a result of:

(i) your browsing and use of the Application, and/or

ii) the queries you send us via the e-mail addresses provided in the App.

will be processed exclusively for the following purposes:

To manage your relationship with ēllu:

  • To identify you as a User.
  • To manage your registration and subscription.
  • To process your payment and deliver your ēllu Band.
  • To answer any queries you may have when contacting us.
  • To manage your candidacy in the corresponding HHRR selection process, in the event that you have sent us your CV.
  • Depending on your settings on the Use of Cookies, to perform statistical analysis and create profiles based on your browsing habits.

To improve the quality of ēllu’s service:

  • To analyse your use of the App in order to improve it and improve our Services.
  • To contact you in case we detect any issue in the use of the Application.
  • To send you notifications.
  • To learn how you use our products and services and improve your User experience.
  • To help us diagnose technical and service problems and to manage our Application and Website.

To detect illegal use of the ēllu service:

  • We may also use your personal data about how you use our App and/or our Website to prevent or detect fraud, abuse, illegal uses, violations of our Terms and Conditions of Use, and to comply with court orders, government requests, or applicable laws.

To assess your candidacy for internal selection processes:

  • To evaluate your application to be part of ēllu Team. To manage the onboarding of new employees, verifying the information provided to determine their suitability and aptitude for it.

To promote ēllu’s service:

  • To send you commercial information about our products and services where you have consented to this by registering on the Website or Application.

To operate, improve and maintain our products and services, we may use your information in an unidentifiable manner.

In the event that we use your data for other purposes, we will notify you in advance.

 

  1. What will we not use your personal data for?

We will not use your personal data to share them with third parties who may use them for commercial and advertising purposes. 

 

  1. Legal basis.

The legal basis for the processing of your data is the contractual relationship that exists between the User and ēllu upon registration of the Application and the use of our services, your consent for those treatments that so require it, as well as the legitimate interest of ēllu to resolve your queries and to allow and improve access to the features of the App and the Website.

 

  1. Geolocation.

The App has a geolocation tool whose main purpose is to know the location of the User and allow other Users, authorised by you, to know your location. For this purpose, it is essential to have the geolocation function of the mobile device activated (at that moment) in order to benefit from all the functionalities of the Service. If the User does not have geolocation activated, he/she will be asked to activate it by means of a notification. In any case, the User may choose to activate and deactivate the geolocation service on their mobile device or on the Application itself. In addition, in the “Aware”, “Let’s meet”, “SOS”, “Proximity” and “Location”   features, the User may choose to share location with other Users. The other Users must accept each time another User wants to see their location. Under no circumstances will this geolocation service will be used by ēllu to provide your location to third parties without the prior consent of the User, except as provided for in current legislation.

 

  1. Interaction with other Users.

The App will allow you to locate and add to your mobile phone contacts who have installed the Application. Also, by downloading the App, you will allow your mobile contacts to add you to their contact list. You will be able to exchange messages, files, voice notes, images and location with other Users of the Application. You can also create, join, or be added to groups, which are linked to your account information. The Users you communicate with may store or re-share the information you send them (including your phone number or messages) with others both inside and outside of our services.

ēllu offers end-to-end encryption in chats, enabled by default. With end-to-end encryption, messages are encrypted so that they cannot be read by ēllu.

App Users will be able to invite friends to download the App. The App also makes it possible to send an invitation to the User’s contacts on the communication channels available to the User. The User declares, under his/her sole responsibility, that he/she knows the recipient of the invitation and that he/she has his/her consent to the use of his/her data for the purpose of sending the invitation.

ēllu shall not use the data contained in the invitation, notably the recipient’s telephone number, which shall be used exclusively for sending the invitation. ēllu shall not store or further process this telephone number.

 

  1. How long and why do we keep your data?

The data provided will be kept for the time necessary to fulfil the purpose for which they were collected and to ensure compliance with the various legal obligations pertaining to ēllu.

Messages are stored in Amazon Web Services for up to 3 days after they are delivered to all recipients, or up to 30 days, if the message cannot be delivered. Media files (photos/video/audio…) are stored in AWS S3 for a maximum of 30 days, unless they are forwarded, which restarts the period for another 30 days from that moment.

Regarding location information, if it is a static location, it is treated like a text message, i.e. it is deleted once it is delivered to everyone at the end of that week. If the location is real-time, the User’s last known location is stored.  Previous locations you have sent will be delivered to all those Users who have authorised access, and then deleted.

 

  1. Who do we share your data with?

ēllu will never share your personal data with any third-party company that intends to use it for commercial or advertising actions.

ēllu may disclose personal data where such disclosure is authorised by law, or is necessary to comply with a legal obligation, including disclosure to competent authorities, judges and courts.

Similarly, your data may be made available to providers who need access to them for the development of services (for example, Internet service providers who help us to manage our website, or perform the contracted services, computer support and maintenance companies, logistics companies, agencies and tax and accounting advice, etc.). In any case, these third parties may only process the data following the instructions that ēllu provides them with and must adopt the necessary legal and organisational measures to guarantee the security of and access to the data. Some of these providers are located, or process data, outside the European Union, in countries that do not offer the same level of data protection as Spain.  ēllu has taken the necessary legal measures to transfer data to these providers. If you would like more information about the international transfers that are carried out and the measures implemented to carry them out, please contact protecciondedatos@ellu.app.

 

  1. How do we protect your data?

As part of ēllu’s commitment to privacy, we have implemented appropriate technical and organisational security measures to ensure the security of your personal data and prevent their alteration, loss, unauthorised processing and/or access, taking into account the state of technology, the nature of the data stored and the risks to which they are subject.

Any processing related to the services of the Application is carried out only by designated data processing staff or staff involved in maintenance operations.

 

  1. What are your rights?

As a User of our Application and our Website, you may at any time revoke the authorisation granted for the processing of your personal data, as well as exercise your rights of access, rectification, cancellation, opposition, the right to request the restriction of the processing of your personal data and the right to portability. To do so, you can write to us by e-mail at protecciondedatos@ellu.app.

You also have the right to lodge a complaint with the Spanish Data Protection Agency, especially when you have not obtained satisfaction in the exercise of your rights.

 

  1. Modification of the Privacy Policy. 

ēllu may update this Privacy Policy, and will inform you prior to the modification. We recommend that you regularly review the Application to ensure that you are aware of any changes.

 

  1. Cookies Policy.

For the purposes of using cookies and other tracking technologies, please refer to our Cookies Policy.

This Privacy Policy has been revised and posted as of November 24, 2024.