Ela gives you a number of options regarding what information you will provide us:
• When you register to create an account with Ela (whether through Ela App or website);
• When you participate on a Community Group or other communication mechanism; and
• When you update a Ela App or the Website with information relevant to your fertility or menstrual cycle or pregnancy,
• When you submit an information form or call back form or use book appointment feature on the Ela Website or App
• When you call us and provide your details over a call to the representative
Finally, we may use information that you include in emails or other communication methods to us to assist us in providing the Service, we may provide this info to other medical service providers / doctors/ clinics/ hospitals so as to enable them to provide you the services and we may publish that information on an anonymous basis. In addition, the text of any posting on any one of the forums, bulletin boards, or other similar publically accessible systems offered by Ela (including any marketplace or services) becomes the property of Ela ,and may be republished by Ela in its sole discretion and will be made available to other people through the internet. In each case, we will collect and record the information you have provided.
Other than names, cell phone number and email addresses provided at your discretion, we don't generally require you to give us any “Personally Identifying Information” about yourself, although of course all the information about your health is extremely private. Furthermore, when you use one of the Ela Apps, we may record information regarding the use of that Era App, including your cell phone number, and if such facilities are enabled on your cell phone, your location and similar information.
Finally, in order to provide the best possible service and to allow us to make certain internal reports and make recommendations, we collect aggregate information about the use of the app or website or wearable, including information about users accessing the Website or using the Ela App, such as Internet protocol addresses, time zone, information about your mobile service provider, which allows us to infer your general location, information about the mobile device you use to access the App, including the hardware model, operating system and version, unique device identifiers and mobile network information,browser type, browser language, referring / exit pages and URLs, other browser history, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, and the date and time (“Activity Information”).
WE DO NOT RENT OR SELL YOUR PERSONAL INFORMATION TO ANY THIRD PARTIES. WE DON’T SHARE YOUR INFORMATION (OTHER THAN FORUM POSTS) TO SOCIAL NETWORKS OR OTHER PUBLIC OR SEMI-PUBLIC PLACES UNLESS INSTRUCTED BY YOU TO DO SO. However, we may share your personal information with third parties in an aggregate and anonymous format combined with the information we collect from other users.
We share your personal information with employees, affiliates, vendors, partners and third parties as required to offer the Services. This includes, but is not limited to, processing transactions, maintaining your account, responding to court orders and legal investigations, for litigation purposes, complying with audits or other investigations, and reporting to credit bureaus.
We may share your personal information as necessary in order for Ela to provide you Services, and possibly to tell you about products and services of interest to you. We also may decide to share your information for joint marketing purposes with other companies.
We will share your information with any party when required by law or by a government request to do so or to combat fraud or criminal activity.
We make your profile available to other users according to the privacy settings you set for yourself as part of your profile. Your user name will be identified to us and to any recipient of messages you send through the Services including on forums. We also use your name, email address and other information on our system to notify you of new product releases, service notifications, and to solicit your feedback and input. In the event that we decide to allow you to submit other information about yourself, the availability of that information to other users will also be controlled by privacy settings you may set for yourself.
You understand and agree that we may access, preserve, and disclose any information we may have about you and the contents of your account if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to avoid liability, to comply with legal process, such as a search warrant, subpoena, statute, or court order, or to protect our rights and property, or that of our affiliates or the public. Ela is not required to question or contest the validity of any search warrant, subpoena or other similar governmental request that it receives. Ela may maintain copies of your content indefinitely, even after you terminate your account.
We may use this information to verify your identity, verify your address, or manage risk. We may also use information to perform and improve our Services, contact you, conduct research, and provide anonymous reporting for medical research. For example, we may use information to provide customer service and support, process transactions, resolve disputes, collect payments, prevent illegal activities, customize the Services and recommendations, reduce risk to all parties involved in our transactions, and verify the accuracy of information.
We may use information to deliver targeted marketing, products, or service update notices, and promotional offers based on your communication preferences. We may combine your information with information we collect from other companies and use it to improve and personalize the Services, content, and advertising. We may also do so in order to improve our prediction methodologies and algorithms.
Be advised that if you send messages or post material on or forums or elsewhere containing personal information, that information may be collected and used by others. The Services provide a number of tools that you can use to control the availability of your profile and other personal information, but forum posts will be available to the general public. You can edit your profile and other information at any time through each of the Ela Apps and/or the Website.
You can terminate your account at any time which will remove your profile and other personal information from view. Ela, however, may (but is not obligated to) keep information about you that is on its system following your termination and your forum posts will continue to be available online.
You are able to modify, correct, erase, and update your Personal Data by writing us at [email protected]
You have a right to access your Personal Data you insert into the App and ask us about what kind of Personal Data we have about you. You can do this by using the app settings or by writing us at [email protected]
Individuals residing in the countries of the European Union have certain statutory rights in relation to their personal data introduced by the General Data Protection Regulation (the “GDPR”). Subject to any exemptions provided by law, you may have the right to request access to Personal data (including in a structured and portable form), as well as to seek to update, delete or correct Personal data:
Please keep in mind that in case of a vague access, erasure, objection request or any other request in exercise of the mentioned rights we may engage the individual in a dialogue so as to better understand the motivation for the request and to locate responsive information. In case this is impossible, we reserve the right to refuse granting your request.
Following the provisions of GDPR we might also require you to prove your identity (for example, by requesting an ID or any other proof of identity) in order for you to invoke the mentioned rights, specifically if you exercise them in respect to special categories of Personal Data like data about health. This is made to ensure that no rights of third parties are violated by your request, and the rights described in this section are exercised by an actual Personal Data subject or an authorized person.
Please note that we will grant your request within 30 days after receiving it, but it may take us up to 90 days in some cases, for example for full erasure of your Personal Data stored in our backup systems – this is due to the size and complexity of the systems we use to store data.
If you remove data from your account, you will no longer see it in the App, but some backups of the data may remain in our archive servers for a reasonable period of time due to technical solutions we use. However, we undertake to delete any such backups within a reasonable period of time.
If you choose to delete the App, deactivate your account, we retain your Personal data for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
You may decide to provide us with another person's email address so that person may be invited to join Ela or so that we may facilitate your communication with other people through the Services. You may also provide us with another person's contact information for purposes of delivering information through the Ela Apps. We use this information to contact and, if necessary, remind that person that he or she has been invited to join Ela or received content through one of the Ela Apps. All invitees are provided with the option not to receive further invitations from Ela. We may disclose such information if required to do so in order to comply with legal process, as described above.
We take reasonable steps in order to ensure compliance of such third parties with any applicable laws that might govern processing of your Personal Data. For example, for the EU residents’ Personal Data we make reasonable efforts to ensure that such third parties are GDPR compliant and have GDPR compliant privacy policies in place.
The Services may contain links to other web sites, and content in the Ela Apps may be hosted by other web sites. These other sites maintain their own policies regarding cookies and the collection and use of personal information. It is up to you to review those policies yourself.
We use industry standard security measures to protect your information so that it is not made available to unauthorized parties. If you have any questions regarding which measures and techniques we use, feel free to contact us. We store and process your information maintaining physical, electronic and procedural safeguards. We maintain physical security measures to guard against unauthorized access to systems and use safeguards such as firewalls and data encryption. We enforce physical access controls to our buildings, and we authorize access to personal information only for those employees who require it to fulfill the responsibilities of their jobs.
We take all reasonable and appropriate measures to protect all collected Personal Data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data that we process and risks associated with special categories of Personal Data we collect (information about health). Among others, we utilize the following information security measures to protect your Personal Data:
1. Pseudominization and tokenization of certain categories of your Personal Data; 2. Encryption of your Personal Data in transit and in rest; 3. Systematic vulnerability scanning and penetration testing; 4. Protection of data integrity; 5. Organizational and legal measures. For example, our employees have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of the App. We impose strict liability on our employees for any disclosures, unauthorized accesses, alterations, destructions, misuses of your Personal Data. 6. Conducting periodical data protection impact assessments in order to ensure that the App fully adheres to the principles of ‘privacy by design’, ‘privacy by default’ and others. We also commit to undertake privacy audit in case of Company’s merger or takeover.
We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable and appropriate steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.
General age limitation. We are committed to protecting the privacy of children. The App / Website is not intended for children and we do not intentionally collect information about children under 13 years old. The App does not collect Personal Data from any person the Company actually knows is under the age of 13. If you are aware of anyone under 13 using the App, please contact us at [email protected] and we will take required steps to delete such information and (or) delete her account.
Age limitation for EU residents. Due to requirements of the GDPR you shall be at least 16 years old in order to use the App. To the extent prohibited by applicable law, we do not allow use of the App by the EU residents younger than 16 years old. If you are aware of anyone younger than 16 using the App, please contact us at [email protected] and we will take steps to delete such information and (or) delete his/ her account.
To communicate with our Data Protection or Grievance Officer, please email at [email protected]
Please contact care at elawoman.com if you would like to receive a copy of this document showing changes from previous versions.