ELANIIN PRIVACY POLICY

ELANIIN complies with all privacy and data protection laws applicable in the country where it provides its services. Therefore, this Privacy Policy establishes the terms under which ELANIIN uses and protects the information provided by users when using the website or mobile applications of ELANIIN.

ELANIIN is committed to the security of its users' data and respects their privacy rights. When personal information is requested, which can identify the user, it is guaranteed that it will only be used in accordance with the terms of the ELANIIN platform.

Consent

By accessing the website, the user acknowledges and agrees that they have read and understood this Privacy Policy, as well as the information collection and processing practices described below. By providing personal information through this website and mobile applications, each user gives their consent for the collection, use, and disclosure of such information as described in this Privacy Policy.

Likewise, the user understands and accepts that all personal information is provided freely and voluntarily.

If you do not wish to authorize the collection, processing, use, and/or disclosure of your personal information as described in this Policy, please do not use the website or mobile applications of ELANIIN and deactivate your account.

Collected Information

The website and mobile applications may collect any information that the user enters. This includes information that can be used to identify the user as an individual or to contact each user directly.

Personal information may include the information provided, such as name, phone number, mailing address, email address, username, and password, photograph, copy of identification document, data from social networks.

Other types of information that may be collected include details such as IP address, device identification data, website browsing history, geolocation, among others, to the extent that this information pertains to the user.

Purpose of Collected Information

The data required and/or requested on the website and mobile applications will be used for legal purposes associated with the growth, maintenance, and administration of ELANIIN while respecting your privacy. These uses include our internal operations and administration, communication with the user, fulfilling user requests for ELANIIN services, advertising and marketing, monitoring and maintaining the functionality and security of ELANIIN services, and improving, developing, enhancing, and otherwise providing ELANIIN services.

Specifically, we use the information for:

• Communications

ELANIIN uses contact information to send messages, products, informative or marketing materials (such as newsletters or technical documentation); process payments; respond to customer service requests; and provide alerts, such as security updates or changes to our policies. Occasionally, we may offer surveys, contests, or sweepstakes or conduct focused research or studies that may require the user to voluntarily share personal information to participate. These activities generally have additional notices that provide more information about the use of your personal information and may require your consent.

• Business Operations

ELANIIN uses the collected information to operate our business, such as performing accounting activities, auditing, billing, payment reconciliation, and collection. Other business purposes that rely on the use of your personal information include crime or fraud monitoring and prevention, protecting our legal rights, and fulfilling contractual obligations that ELANIIN has with its users.

• General Use

ELANIIN is committed to complying with the legislation of the country where our services are provided or acquired, with special care for the collection and use of personal data from our users. However, the user can be assured that their information is safeguarded under the highest privacy standards of the ELANIIN platform and will only be used with the prior consent of the user.

By accessing our website and mobile applications, accepting our policies, and continuing to use our website and mobile applications, the user provides express consent for the use of voluntarily provided information in accordance with the provisions stated in these policies.

If the user is in the European Economic Area (EEA) or is an individual of European nationality, our legal basis for collecting and using the personal information described above will depend on the specific personal information and the context in which we collect it, as well as the applicable legislation.

However, we may only collect personal information from the user when we have their consent, when we need the personal information to fulfill a contract with the user, when we have a legal obligation to do so, or when the processing is for our legitimate interests (such as processing for administrative purposes, direct marketing, product development or improvement, fraud prevention, or support for information security) and is not overridden by the user's data protection interests or fundamental rights and freedoms.

If ELANIIN requires the user to provide personal information to comply with a legal requirement or to enter into a contract with the user, this will be clarified at the time of collection. It will also be indicated whether such information is mandatory and the consequences if the user decides not to provide the information.

Similarly, if ELANIIN collects and uses your personal information based on our legitimate interests (or those of third parties), we will take reasonable steps to provide clear notice and describe our legitimate interests.

Shared Information

The data obtained will be stored in databases owned by ELANIIN. We work with our affiliated companies, subsidiaries, business partners, and/or service providers to provide ELANIIN services.

We use a wide range of software and tools to process personal information as part of our normal business operations. Our contracts with affiliated companies, subsidiaries, business partners, and/or service providers include provisions to protect your information and limit its use.

When we share your personal information with these companies, we implement appropriate measures to limit the use of your information solely for legal and authorized purposes, and with proper confidentiality and security measures.

By accepting our policies, each user of our platform and the services provided through it authorizes us to share non-personally identifiable information, such as anonymous or aggregated information, with providers for business purposes, including conducting market studies on consumer preferences to improve our products and/or services and assisting in the research and development of new services that may be of interest to our users.

We may disclose personal information as part of an actual or anticipated corporate transaction, such as a reorganization, merger, sale, joint venture, assignment, transfer, or disposition of all or any part of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

ELANIIN will not sell, trade, exchange, distribute, or otherwise transfer or pledge for profit to a third party any personal information in its databases without first obtaining your prior express written consent.

Treatment of Personal Information

ELANIIN will collect personal information provided only for specific purposes described in this policy or in any subsequent privacy notice that may be requested for a specific case. The information being collected for this purpose is relevant, adequate, and not excessive with regard to the purposes being pursued.

Security Measures

ELANIIN's services are designed to provide reasonable and appropriate administrative, technical, and organizational security measures to protect your personal information against risks such as temporary or permanent loss, destruction, and illegal or unauthorized access, alteration, use, or disclosure. We also require our providers to apply similar protections when accessing the personal information we share with them or when using such information.

However, users of ELANIIN's services must also fulfill their part in protecting the data, systems, networks, and services they use.

It cannot be guaranteed that technology, systems, and data transmission are completely secure.

Cookies

A cookie refers to a file that is sent with the purpose of requesting permission to be stored on your computer. By accepting this file, a cookie is created, and it serves to have information about web traffic and also facilitates future visits to a recurring website.

Another function of cookies is to individually recognize the user in order to provide a more personalized service through the website.

This website is capable of using cookies to identify the pages that are visited and their frequency. This information is used solely for statistical analysis, and then the information is permanently deleted.

Please note that you can delete cookies at any time from your computer and change your computer's settings to reject cookies.

Third-Party Links

This website and mobile applications, as applicable, may contain links to other sites that may be of interest to you. Once the user clicks on these links and leaves our page, ELANIIN no longer has control over the redirected site; therefore, ELANIIN is not responsible for the terms, privacy, or data protection on those other third-party sites.

Such sites are subject to their own privacy policies, so it is recommended that you consult them to confirm your agreement with those policies.

Control of Your Personal Information

At any time, you can access, rectify, modify, revoke, or delete the personal information provided on this website.

To exercise the aforementioned rights, please write to the following email address: [email protected]. The user must communicate their desire to unsubscribe from our database to avoid receiving unwanted advertising or information.

Retention of Personal Information

ELANIIN is committed to retaining the information generated by transactions carried out through our platform for a period of 10 years from the date of completion of the transaction.

The personal information during the aforementioned period will be retained by ELANIIN to: provide the requested ELANIIN services as necessary to fulfill legal obligations; as agreed in an individual consent; resolve disputes; and otherwise fulfill the purposes, rights, and obligations described in this privacy policy.

The aforementioned retention periods apply from the start of the business relationship and continue for the same period after the termination of the business relationship. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational guidelines or needs, and historical archiving.

When personal information is deleted from our systems, it will be securely erased or destroyed using appropriate security protocols to prevent reconstruction or reading.

Limitation of Liability

Despite ELANIIN's use of reasonable administrative, physical, and logical security measures to provide adequate protection for personal information, no internet transmission is completely secure or error-free.

Therefore, ELANIIN will not be liable for security breaches that are beyond its control, as well as for losses, lost profits, or business failures.

ELANIIN will also not indemnify losses claimed as a result of failures in its operations, systems, or platforms due to force majeure, acts of God, or actions of a third party.

Unless otherwise provided by law, the liability provided in this article will be limited to direct damages duly proven by the injured party, excluding any indirect, incidental, and/or consequential damages.

Changes to this Privacy Policy and our Privacy Statements

ELANIIN reserves the right to change the terms of this Privacy Policy at any time and without prior notice. Such changes will be posted on this website.

The modifications will apply only to personal information collected after this publication and once your consent has been obtained.

This Privacy Policy was last reviewed on November 1, 2020.