PRIVACY POLICY
Welcome to Ellam! This Privacy Policy is here to help you understand how we treat any personal information that you share with us when you use Ellam Mobile Apps! This Privacy Policy explains how we collect, use, disclose, and protect visitors’ and users’ information. Any discussion of your use of the Service in this Policy is meant to include your visits and other interactions with the Sites and Services, whether or not you are a user of this Community.

WHO ARE WE?
This Mobile App (“Site”) is operated by Ellam (“Ellam, ''we”`,''us” and/or “our”), the data controller responsible for your personal data is Ellam with whom you contract as a customer, member or membership applicant (“Ellam”, “we”, “us” and/or “our”).

WHAT IS THIS PRIVACY POLICY IS FOR?
This privacy policy (“Privacy Policy”) applies to personal data that we collect from you as a user of this App or as a visitor, member, subscriber, or customer (“you” or “your” being interpreted accordingly). It provides information on what personal data we collect, why we collect personal data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the applicable data protection and privacy laws, including the General Data Protection Regulation (“GDPR”)

USER DATA POLICY


WHAT DO WE MEAN BY PERSONAL INFORMATION?
‘Personal Data’ as used in this Privacy Policy means any information that relates to you from which you can be identified. Personal information means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.

Personal Information does not include “User Metrics data” which we define as encrypted information or aggregated data we collect about a service, features or users which does not contain personally-identifying information. Usage Data helps us understand trends in the usage of the Service so that we can better consider new features or otherwise tailor the Service. In addition to collecting and using Usage Data ourselves, we may share Usage Data with third parties, including our customers, partners, and service providers, for various purposes, including to help us better understand our customers’ needs and improve the Service as well as for advertising and marketing purposes. We do not share Usage Data with third parties in a way that would enable them to identify you personally.

By using our App or submitting your personal data you are taken to accept the terms of this Privacy Policy, so please read it carefully.

PERSONAL DATA WE COLLECT AND HOW WE USE IT ?


• INFORMATION YOU VOLUNTARILY PROVIDE TO US WHILE REGISTRATION:
We collect some Personal Information about users while they Register their Account or contact us through Enquiry Forms, their contact details including their First Name, Surname, Gender, Birthday, Email Address and Contact Number which will be kept confidential from other users and will be shared with others only after the user's consent & permission. You may also provide at your own discretion certain related information like your social media websites URL's, a list of your interests, the date you started using the Service and a description of you.

Personal Data may include, but is not limited to, below :
• Your name and email address, profile picture
• Your website URL and name
• Company name
• Phone number
• Age
• Location
• Address

Reason for Use : These details are used to have the unique identity of each user in Ellam Community.
While Sign Up, users accept these "Terms and Policy" before providing such details.

• INFORMATION COLLECTED FROM DEVICE
When Users of the Community access the app, we do collect some personal information of the User's Device like Email Address and Contact Numbers, which is done only after User's consent. This App asks permission if the user allows accessing these details and only after the consent these details are used in the Application.

Reason for Use: These details are used to add connections with mutual users of the Device and Ellam Community.

It can include below details:

• - Device Modifier which is Users' device Unique Id
• - Microphone and Audio Permission
• - Access to Camera and Gallery
• - Device Advertising ID
• - Bluetooth Permission
• - Audio Modifier to manage volume of the audio being listened within the app



• BLUETOOTH ACCESS
Our Mobile Apps may take permission to access Bluetooth of the device in order to connect on Audio / Video Call or Listen Musics across the app.

• LOCATION / GPS ACCESS
We are first taking consent from Users before allowing the app to access their location.

Reason for Use : Access of Location is used for the purpose of filtering the content across the app based on selected Location, set default location of the app as per the user's requirement, for check-In purpose, create content for any specified location etc.

• ACCESS TO CAMERA / GALLERY / MICROPHONE
Members of the Mobile Apps can upload Audio, Photos, Videos, Audios and capture images/videos in the Mobile Apps. To do so, the mobile app will access the Camera, Microphone and Gallery of the Device. We take consent from users before accessing the Camera, Gallery / SD card of the Device, Microphone, etc.

• DEVICE IDENTIFIER
When you access our Service using any mobile devices, we may access, collect, monitor, and/or remotely store one or more “device identifiers,” of the device. A device ID ( device identification) is a distinctive number associated with a smartphone or similar handheld device , these are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may convey information to us about how you browse and use the Service. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

It is basically used for sending Push Notifications in the Device.

STORAGE
When the user saves files through the Mobile Apps like Images, Videos, Audios, it gets stored in the internal storage / Gallery of the Device.

• ACCESS TO PASSWORD / PROTECTED AREAS
Only users with login passwords can access the password-protected areas of Ellam Community. The user identity shall be provided by us while the user shall define the login password, which shall be encrypted and stored on the server. We strongly recommend that the password is retained confidential.

• ANALYTICS INFORMATION
We use third-party analytics tools like Firebase to help us measure user traffic for the Service. These tools collect information sent by your browser as part of pages request, including the web pages you visit, your browser add-ons, and other information that assists us in improving the Service. We may collect and use this analytics information together with your Personal Information to build a broader profile of our individual users so that we can better serve you. We also use it to monitor aggregate app’s usage metrics such as total number of visitors and pages viewed.

ADVERTISEMENT
We display Advertisement across the app using third party Ads like Facebook Ads . In this case, we use Facebook Placement Id to fetch Facebook Ads in the App. We do not manage other features like the targetting of Ads to users, these are being managed by Facebook Team itself using their own privacy policy.

• INFORMATION WE MAY COLLECT FROM THIRD PARTIES
We may receive information about you from other sources. For example, if you use third-party software through the app, they may transfer information to us for fulfillment. For example, if you access our app or Service through a third-party connection or log-in or connect to our service using social media account (e.g. Facebook, Twitter, etc.) that third party with may pass certain information about your use of its service to Ellam. This information could include, but is not limited to, the user User Token, User ID associated with your account or any information that you have permitted the third party to share with us, and any information you have made public in connection with that third-party service. Information will be saved as Encrypted form.

• EXTERNAL WEBSITE’S LINK
Our Service and Application may contain links to other websites except our services. These may include links like Facebook, Youtube, Twitter, Vimeo or any external website links . Please be aware that we are not liable for the privacy practices or content of such external websites and applications operated by third parties.

In addition, you agree that we are not responsible and do not control any third parties that you authorize to access your user content or related data. If you are using a third-party website or service and you allow such a third party access to your User Content, you do so at your own risk. This Policy applies only to information collected by our Service.

• COOKIES
We may log information using cookies, which are small data files stored on your browser by Ellam. We may use both session cookies, which expires when you close your browser, and persistent cookies, which stay on your browser until deleted, to provide you with a more personalized experience on the app and community.

Note that disabling cookies on your mobile device or browser may prevent us or our business partners from tracking your browser’s activities in relation to the Service. However, doing so may disable many of the features available through the Service.

A cookie is a small text file that is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website. The cookie will collect information relating to your use of the Website, information about your device such as the device’s IP address and browser type, demographic data and if you arrived at our Website via a link from a third-party site, the URL of the linking page.

We also have the option for users to remember your information so that you will not have to re-enter it during your visit or the next time you visit our app.

• ACCOUNT DELETION RIGHTS
The users of the Ellam Community do have the right and access to delete their Account from the Platform. If done so, all the relevant data collected and saved on the server would be permanently removed from the database as well as the Server and there will no further details saved at our end.

It is basically used for sending Push Notifications in the Device.

In addition, you agree that we are not responsible and do not control any third parties that you authorize to access your user content or related data. If you are using a third-party website or service and you allow such a third party access to your User Content, you do so at your own risk. This Policy applies only to information collected by our Service.

PAYMENT PROCESS
We do not have a native Payment Process within the app but have Payment through webview. Users can purchase paid packages created within the app, purchase products, etc through different payment methods. But, we do not store or save any Payment Account like Paypal, Credit / Debit Card details at our end. These details are added by the user while making the payment and are only saved by respective Payment Methods (which are the third party) like PayPal , PayU Money, etc. We do not save any details at our end. We just save order details, billing addresses which are internally added by the Users while making the purchase. This is being done only after user's consent.

How do we use the information we collect?
We use the information we collect to provide our products to you and make them better, develop new products, and protect our users. For example, we may log how often people use two different versions of a product, which can help us understand which version is better.

We also use the information we collect to offer you customized content, including:
1. Send you updates (such as when certain activity, like shares or comments), marketing materials and other information that may be of interest to you. For example, depending on your email notification settings, we may send you weekly updates that include posts you may like. You can decide to stop getting these updates by updating your account settings (or through other settings we may provide).
2. Help your friends and contacts find you on this app. For example, if you sign up using a Facebook account, we may help your Facebook friends find your account on this app when they first sign up. Or, we may allow people to search for your account using your email address.
3. Respond to your questions or comments.

The information we collect may be “personally identifiable” (meaning it can be used to specifically identify you as a unique person) or “non-personally identifiable” (meaning it can’t be used to specifically identify you).

What choices do you have about your information?
Our goal is to give you simple and meaningful choices over your information. If you have an account, many of the choices you have on this are built directly into the product or your account settings. For example, you can:

1. Access and change the information in your profile page at any time.
2. Link or unlink your account from an account on another service (e.g., Facebook or Twitter). For some services (like Facebook), you can also choose whether or not to publish your activity on to that service.
3. Your mobile device may provide you with choices around how and whether location or other data is shared with us.

How do we share the information we collect?
People use this website to find their inspirations, make them a reality, and inspire others in the process. When you post public updates, anyone can view them. You may also provide us with profile page information that anyone can view. The other limited instances where we may share your personal information include:

1. When we have your consent. This includes sharing information with other services (like Facebook or Twitter) when you’ve chosen to link to your account to those services or publish your activity to them. For example, you can choose to publish your posts to Facebook or Twitter.
2. If we believe that disclosure is reasonably necessary to comply with a law, regulation or legal request; to protect the safety, rights, or property of the public, any person; or to detect, prevent, or otherwise address fraud, security or technical issues.
3. We may engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Policy.

We might also share aggregated or non-personally identifiable information with our partners or others who are linked with our Services.

PROTECTION OF INFORMATION
We at Ellam, are committed to secure the personal information shared by the Users. We use various technologies that helps to secure User’s personal details and other related information in various ways. We have standard and high quality SSL Certificates installed at our server which transmits data in encrypted form. Database is secured under security Layer which is Private Subnet. Any external attack can not break our protective firewall and security layer thus, informations and details like Images and other Contents are protected using Cloud Fronts.

OUR POLICY ON CHILDREN’S INFORMATION
We are not directed to children under 13. If you learn that your minor child has provided us with personal information without your consent, please contact us.

NOTE TO USERS
1. During the collection of information on the Profile Pages on the app, you are required to provide your applicable contact information (such as name, e-mail address or phone number).
2. All the sensitive information is collected only when you provide us with your consent. We would discontinue our services if your consent is not received (you affirm your consent by accepting our terms and conditions).
3. Users are responsible to manage the information they provide us. You can amend your personal information in case of any changes. If you provide any information that is untrue, inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date or incomplete), Ellam has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, we may, at its sole discretion, discontinue the provision of the Services to you.

GDPR COMPLIANCE
IF YOU’RE A USER OR VISITOR IN THE EUROPEAN ECONOMIC AREA THESE RIGHTS ALSO APPLY TO YOU. WE ARE COMPLIANT WITH THE APPLIANCE OF GDPR (GENERAL DATA PROTECTION REGULATION 2016/679) COMPLIANCE.

Data Protection Officer
We have a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. You may contact this officer if you have any questions about our privacy practices or the ay in which we have been managing your personal information This Data Protection Officer can be reached at the following address:

Ellam Sosyal Medya
bilgi@ellam.com.tr

HOW DO WE MAKE CHANGES TO PRIVACY POLICY?
We may change this policy from time to time, and if we do we’ll post any changes on this page. If you continue to use this app after those changes are in effect, you agree to the revised policy. If the changes are significant, we may provide more prominent notice or obtain your consent as required by law.