ELSA CORP. PRIVACY POLICY

Last updated October 1, 2020

This Privacy Policy (“Policy”) describes how ELSA Corp. and its related companies (“we,” or “us,” or “Company”) collect, use and share personal information of users of the ELSA mobile application (“ELSA” or the “App”), this website (the “Site”) and other services provided by the Company (the App, the Site, and such services shall be collectively referred to as the “Service”). This Policy also applies to any of our other mobile applications or websites that post this Policy. This Policy does not apply to websites that post different statements.

WHAT WE COLLECT

We get information about you in a range of ways.

HOW WE USE PERSONAL INFORMATION

We use your personal information for the following purposes:

SHARING OF PERSONAL INFORMATION

In certain circumstances we may share your personal information with third parties without further notice to you, unless required by the law, as set forth below:

We may share aggregate data with interested third parties to assist them in conducting research, developing new products, and understanding the interest and usage patterns for certain information, products, services, data, content, services, advertisements, promotions, and/or functionality on the Service.

RETENTION OF PERSONAL INFORMATION

We will retain your personal information for as long as your account is active, and as long as is reasonably necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

YOUR PRIVACY RIGHTS AND CHOICES

You have certain rights and may make certain choices regarding our processing of your personal information:

ADVERTISING AND REMARKETING

We may allow other companies, called third party ad servers or ad networks, to serve advertisements within the Site or the App. These third party ad servers or ad networks use technology to send, directly to your browser, the advertisements and links that appear on the Site. They automatically receive your IP Address when this happens. They may also use other technologies (such as cookies, JavaScript, or web beacons) to measure the effectiveness of their advertisements and to personalize their advertising content. Further, these advertisers may also serve ads to you on other websites (including ads for our products and services) based on information collected from you while using the Site. For example, we may use Google’s “remarketing” service to target our ads to you based on your prior use of the Site or the App when you visit on other sites in Google’s content network.

You should be aware that advertisers may target advertisements to users based on certain user characteristics. If you respond to this type of targeted advertisement, the advertiser or ad server may conclude that you fit the description of the audience they were trying to reach. Our Privacy Policy does not apply to, and we cannot control the activities of, such ad servers, ad networks, or their advertiser clients.

LINKS TO OTHER SITES

The Site may contain links or references to external websites. These are provided for your convenience only, and we do not have control over the privacy or security practices and policies of third party sites. Any personal information you provide on linked pages is provided directly to that third party and is subject to that third party's privacy policy. Please learn about the privacy and security practices and policies of external websites before providing them with personal information.

CHILDREN

Consistent with the federal Children's Online Privacy Protection Act of 1998 (COPPA), we do not knowingly collect personally identifiable information from anyone under the age of thirteen (13) without parental consent. Any person who provides their personal information to us through the Site represents that they are 13 years of age or older. We ask for and store users’ date of birth to ensure they are 13 or older, but do not share that information unless the user chooses to share it on the user’s profile. If you believe that we have collected information from an individual under the age of 13, please contact us so that we may take appropriate steps to address the issue.

SECURITY OF YOUR PERSONAL INFORMATION

We take steps to help protect personal information. No company can fully prevent security risks, however. Mistakes may happen. Bad actors may defeat even the best safeguards.

TRANSFER OF PERSONAL INFORMATION TO THE UNITED STATES OR OTHER COUNTRIES

Your personal information will be transferred to, and stored and processed in, the United States, and may in the future be transferred to, and stored and processed in, other countries. All transfers will either (a) be under the European Commission’s model contracts for the transfer of personal information to third countries, or (b) rely on the EU-US Privacy Shield framework.

CONTACT INFORMATION / DATA PROTECTION OFFICER

If you have questions, comments or complaints about this Privacy Policy or our privacy practices, or would like to exercise any of your rights and choices under this Privacy Policy or applicable law, you may contact our Data Protection Officer at the following email address: [email protected]

CHANGES TO THIS PRIVACY POLICY

We may occasionally update this Privacy Policy. When we do, we will also revise the "updated date" on the Privacy Policy. For changes to this Privacy Policy that may be materially less restrictive on our use or disclosure of personal information that you have provided to us, the new policy will not apply to information collected prior to the change unless we obtain your consent. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personal information we collect. Your continued use of the Service constitutes your going forward agreement to this Privacy Policy and any updates.

This privacy policy was last updated on October 1, 2020.