Effective Date: October 30, 2018
Welcome to H Labs, LLC dba ellie ("ellie," "we," "us" or "our"). ellie provides a group communication platform where users create, find, join groups and create and consume content.
1. WHAT INFORMATION DO WE COLLECT?
We collect the following types of information (collectively, “User Data”).
- Group and User Account Information. To create, update or join a group, you create a login and may supply ellie with an email address, phone number, password, domain and/or similar account details (each such user, an “Authorized User”).
- Usage Information.
- Services Metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users work. For example, ellie logs the group, topics, users, features, content and links you interact with, the types of files shared and what Third Party Services are used (if any).
- Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
- Device information. ellie collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
- Location information. We receive information from you and other third-parties that helps us approximate your location. We may, for example, use an IP address received from your browser or device to determine approximate location, which may be used when you’re creating an event to auto-populate nearby places or to recommend local groups to you, or share local deals. ellie may also collect location information from devices in accordance with the consent process provided by your device.
- Third Party Services. Our mobile application does not currently engaged with Third Party Services, but it may in the future, such as Venmo or Google Calendar or Google Drive. Typically, Third Party Services are software that integrate with our Services, and User can decide whether or not to interact and/or enable third Party Services. Once enabled, the provider of a Third Party Service may share certain information with ellie. For example, if a cloud storage application is enabled to permit files to be imported to a group, we may receive user name and email address of Authorized Users, along with additional information that the application has elected to make available to ellie to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to ellie. When a Third Party Service is enabled, ellie is authorized to connect and access Other Information made available to ellie in accordance with our agreement with the Third Party Provider. We do not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services.
- Contact Information. In accordance with the consent process provided by your device, any contact information that an Authorized User chooses to import (such as an address book from a device) is collected when using the Services.
- Third Party Data. ellie may receive data about organizations, industries, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
- Analytics Information. We may use third-party analytics tools to help us measure traffic and usage trends for the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User
- Additional Information Provided to ellie. We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with ellie.
Generally, no one is under a statutory or contractual obligation to provide any User Data, User Content or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as group setup details, is not provided, we may be unable to provide the Services.
2. HOW WE USE YOUR INFORMATION
User Data will be used by ellie in accordance with User’s instructions and User’s use of Services functionality, and as required by applicable law. ellie is a processor of User Data and the group administrator is the controller. The group administrator may, for example, use the Services to grant and remove access to a group, assign roles and configure settings, access, modify, export, share and remove User Data and otherwise apply its policies to the Services. ellie uses Other Information in furtherance of our legitimate interests in operating our Services and business. More specifically, ellie uses “Other Information”, as set forth below:
- To provide, update, maintain and protect our Services and business. This includes use of Other Information to prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Authorized User’s request.
- As required by applicable law, legal process or regulation.
- To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
- To develop and provide search, learning and productivity tools and additional features. ellie tries to make the Services as useful as possible for specific groups and Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, topics or expertise to an Authorized User, make Services suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience or create new productivity features and products.
- To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about ellie. These are marketing messages so you can control whether you receive them.
- For billing, account management and other administrative matters. ellie may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
- To investigate and help prevent security issues and abuse.
- We may use third-party analytics tools to help us measure traffic and usage trends for the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.
By using the Service, you irrevocably grant all such rights and permissions in or relating to User Data to enable ellie and its Affiliates to use your User Data as set forth herein.
3. SHARING OF YOUR INFORMATION (by us and you)
How we may share your User Data
- With our “Affiliates”--i.e. businesses that are legally part of the same group of companies that ellie is part of, or that become part of that group. These Affiliates will honor the choices you make about who can see your profile and posts;
- Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective ellie partner the average amount of posts in a typical topic.
- Displaying the Services. When an Authorized User submits Other Information, it may be displayed to other Authorized Users in the same or connected groups. For example, an Authorized User’s email address may be displayed with their profile.
- Administrator Access. Group administrators may be able to access, modify or restrict access to Other Information. This may include, for example, your administrator using Service features to export logs of group activity, or accessing or modifying your profile details to determine the members of their group.
- Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services.
- Third Party Services. Authorized Users may enable Third Party Services. When enabled, ellie may share Other Information with Third Party Services. Third Party Services are not owned or controlled by ellie and third parties that have been granted access to Other Information may have their own policies and practices for its collection and use. Please check the privacy settings and notices in these Third Party Services or contact the provider for any questions.
- To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. Please see the Data Request Policy to understand how ellie responds to requests to disclose data from government agencies and other sources.
- To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of ellie or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
- With Consent. ellie may share Other Information with third parties when we have consent to do so.
Parties with whom you may choose to share your User Content:
- Any User Content you voluntarily disclose for posting to the Service becomes available to the public, as controlled by any applicable privacy settings that you set. To change your privacy settings on the Service, please change your profile setting. Once you have shared User Content or made it public, that User Content may be re-shared by others.
- Any personal information that you include in any content submitted or posted when using the public areas of our Services can be viewed by the general public, so please consider this before submitting any such information or content. Additionally, even if a group is “private” it may have thousands of members. You are solely responsible for any information, including any Personally Identifiable Information, you disclose on the Service, and any use of such information by any third-parties regardless of whether you permitted or did not permit such use. We cannot control how others use the information that you post to public areas of our Service.
- If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service.
4. HOW WE STORE AND PROCESS YOUR INFORMATION
- Your information collected through the Service may be stored and processed in the United States, the European Union, or any other country in which ellie, its Affiliates or Service Providers maintain facilities.
- ellie, its Affiliates, or Service Providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world, including to a destination outside the European Economic Area ("EEA") such as the United States. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. If you are located in a jurisdiction other than the United States, the laws governing data collection and use may differ from U.S. law and we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction (see “Special Note to International Users”).
- We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, ellie cannot ensure the security of any information you transmit to ellie or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.
- Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and ellie, at all times. Your privacy settings may also be affected by changes the social media services you connect to ellie make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.
5. YOUR RIGHTS AND YOUR INFORMATION
- Update your account at any time by logging in and changing your profile settings.
- Unsubscribe from email communications from us by clicking on the "unsubscribe link" provided in such communications. As noted above, you may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices).
- Deactivate your account by sending an email to firstname.lastname@example.org.
- Following termination or deactivation of your account, ellie, its Affiliates, or its Service Providers may retain information (including your profile information) and User Data for a commercially reasonable time for backup, archival, and/or audit purposes.
- Once you leave a group, User Content that you previously shared with that group will remain visible to other group members, as determined by that group’s privacy settings.
- Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. Please contact us at email@example.com for further inquiry.
- To the extent that ellie’s processing of your Personal Data is subject to the General Data Protection Regulation, ellie relies on its legitimate interests, described above, to process your data. ellie may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to ellie’s use of your Personal Data for this purpose at any time.
6. AGE LIMITS; an app for adults
ellie is an app for parents ages 18 or over. ellie does not knowingly collect or solicit any information from anyone under the age of 18 or knowingly allow such persons to register for the Service. The Service and its content are not directed at children. In the event that we learn that we have collected personal information from from anyone under the age of 18 without parental consent, we will delete that information as quickly as possible. By using or signing up for the Services, you represent and warrant that you are at least 18 years of age. If you believe that we might have any information from or about a user under 18, please contact us at firstname.lastname@example.org.
7. OTHER WEB SITES AND SERVICES
Inviting your friends to ellie:
- If you choose to find your friends or invite members through a search of names or usernames on ellie then simply type a name to search and we will perform a search on our Service.
- Note about "Invite" via email or text feature: If you choose to invite someone to the Service through our "Invite friends" feature, you may select a person directly from the contacts list on your device and send a text or email from your personal account. You understand and agree that you are responsible for any charges that apply to communications sent from your device, and because this invitation is coming directly from your personal account, ellie does not have access to or control this communication.
8. SPECIAL NOTE TO INTERNATIONAL USERS
Identifying The Data Controller And Processor
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, the Authorized User the controller of User Content. In general, ellie is the processor of User Content and the controller of Other Information.
9. HOW TO CONTACT US