Privacy Policy
Effective date: May 25, 2018The purpose of this Privacy Policy
We recognize that your privacy is very important and take it seriously. The purpose of this Privacy Policy is to describe how Elmy, Inc. ("Elmy," "us," "we," or "our") collects, uses and shares information about you through our online resources (e.g., websites and mobile applications) owned and controlled by us, including www.elmy.com ("Site"). Please read this Privacy Policy carefully to understand what we do.We will post any modifications or changes to this Privacy Policy on this page.
Your use of our Site is also governed by our Terms of Use.
This Privacy Policy is designed to describe:
The purpose of this Privacy PolicyWho we are and how to contact us
Our policy on children's privacy
What Personal Data this Privacy Policy covers
What Personal Data We Collect
What you agree to by using Site
Links to other websites
How we use the Personal Data
How we use cookies
Security of Personal Data
Your rights relating to your Personal Data
California Privacy Rights
Changing our Privacy Policy
Who we are and how to contact us
Elmy, Inc. is a Delaware corporation with a principal place of business at 530 Lytton avenue, Palo Alto, Ca, 94301.If you reside or are located in the European Union ("EU") Elmy is the data controller of all Personal Data (as defined below) collected via the Site and of certain Personal Data collected from third parties, as set out in this Privacy Policy.
If you do not understand any aspects of our Privacy Policy and/or have any questions, complaints etc. concerning your Personal Data protection, please feel free to contact us at support@elmy.com.
We will reply to your letter as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that if you are in the EU the GDPR gives you the right to contact your local data protection supervisory authority.
Our policy on children's privacy
Protecting the privacy of young children is especially important. The services are not intended for children below 16 and we do not knowingly collect or solicit personal information from anyone under the age of 16 or knowingly allow such persons to register with the Site. If you are under the age of 16, please do not submit any personal information through the Site. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information on this Site. If we become aware that we have collected personal information from a child under age 16, we will take steps to remove that information as soon as possible.What Personal Data this Privacy Policy covers
This Privacy Policy covers all information we collect from you through our Site.Some of our Site’s functionality can be used without revealing any Personal Data, though for some features or services Personal Data is required. In order to access certain features and benefits on our Site, you may need to submit, or we may collect, "Personal Data" (i.e., any information that can be used to identify you). Personal Data can include information such as your name, phone number, online identifier and email addresses, among other things.
You are responsible for ensuring the accuracy of the Personal Data you submit to Elmy. Inaccurate information may affect your ability to use the Site, the information you receive when using the Site, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.
What Personal Data We Collect
We gather two types of information about users through the Site:Information relating to your use of our Site;
Personal data provided directly by you or via third parties.
Information relating to your use of our Site.
When users come to our Site, we may track, collect and aggregate information indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited, and which hyperlinks were "clicked." We also collect information from the URLs from which you linked to our Site. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the Site. We may be able to determine from an IP address a user’s Internet service provider and the geographic location of his or her point of connectivity.
We also upload (or may upload) to your computer or other device cookies etc. (“cookies”) and/or store data in HTML5 Local Storage (if you have not limited this possibility in your browser), as well as to receive, store, process and use the information contained in the cookies and/or data in HTML5 Local Storage.
Personal data provided directly by you or via third parties.
We collect Personal Data that you provide to us when you register for an account, update or change information for your account, purchase products or services, send us email messages, and/or participate in other services on our Site. We may use the Personal Data that you provide to respond to your letters, provide you the services you select, send you email messages about Site maintenance or updates etc.
If you register for an account on our Site, you may be required to provide us with Personal Data such as your name, image of you, phone number, address and email.
We may offer you the ability to receive updates either via email or by posting on portions of the Site only accessible to registered users. In order to subscribe to these services, you may be required to provide us with Personal data such as your name, phone number, address and email.
We may receive Personal Data when you send us an email message or otherwise contact us.
We may receive Personal Data when you access or log-in to a third party site, e.g., Facebook, from our Site. This may include the text and/or images of your Personal Data available from the third party site.
We provide you with the ability to pay for services using a credit card through a third party payment processing service provider. Please note that your payment provider collects and processes your credit card information.
What you agree to by using Site
Please understand that by submitting any Personal Data to us, you consent and agree that we may collect, use and disclose such Personal Data in accordance with this Privacy Policy and our Terms of Use, and as permitted or required by law.If you do not agree with these terms, please do not provide any Personal Data to us.
If you refuse or withdraw your consent, or if you choose not to provide us with any required Personal Data, we may not be able to provide you with the services that can be offered on our Site.
Consent can be withdrawn at any time by navigating to your profile page and clicking the box to remove consent or deleting your account.
We keep your Personal Data for no longer than necessary for the purposes for which the Personal Data is processed. The length of time we retain Personal Data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
Links to other websites
For your convenience we may provide links to third party sites that we believe may be of interest to you. We do not disclose your Personal Data to these sites without obtaining your consent. We do not endorse and are not responsible for the privacy practices of such third party sites. If you choose to click on a link to one of these sites, you should review the privacy policy posted on the other site to understand how that site collects and uses your Personal Data. How we use the Personal Data Information relating to your use of our Site. We use information relating to your use of the Site to build higher quality, more useful services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use this information to ensure the security of our services and the Site.Personal data provided directly by you or via third parties. Except as set forth in this Privacy Policy or as specifically agreed to by you, we will not disclose any of your Personal Data. In addition to the other uses set forth in this Privacy Policy, we may disclose and otherwise use Personal Data as described below.
We use Personal Data which you provide to us in order to allow you to access and use the Site and in order to provide any information, products or services that you request from us.
We use Personal data collected when you sign-up for our various email or update services to send you the messages in connection with the site services. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.
When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Policy. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so.
We use various service providers, vendors and contractors (“contractors”) to assist us in providing our products and services to you. Our contractors may have limited access to your Personal Data in the course of providing their products or services to us, so that we in turn can provide our products and services to you. These contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site. Access to your Personal Data by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for us.
We may share your Personal Data with various government authorities in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us. We also may share your Personal Data when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Elmy, the Site, our users, customers, or others; and in connection with our Terms of Use and other documents.
We may disclose and/or transfer your Personal Data to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of Elmy, Inc. to which your Personal Data relates.
How we use cookies
We upload (or may upload) to your computer or other device cookies if you have not limited this possibility in your browser, as well as to receive, store, process and use the information contained in the cookies.When you visit the Services, we may send one or more "cookies" – small data files – to your computer or other device to uniquely identify your browser and let us help you log in faster and enhance your navigation through the Site. A cookie may convey anonymous information about how you browse the Site to us so we can provide you with a more personalized experience, but does not collect personal information about you. A persistent cookie remains on your computer or other device after you close your browser so that it can be used by your browser on subsequent visits to the Site. Persistent cookies can be removed by following your web browser's directions. A session cookie is temporary and disappears after you close your browser.
Our Site uses the following types of cookies for the purposes set out below:
Essential Cookies. These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request to load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies. These cookies allow our Site to remember choices you make when you use our Site, such as remembering your login details and remembering the changes you make to other parts of our Site which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.
Analytics and Performance Cookies. These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not "directly" identify any individual visitor. However, it may render such visitors "indirectly identifiable". This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site.
Targeted and advertising cookies. These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites. Third party advertisers may also use other technologies in addition to cookies placed on the Site (such as JavaScript, or web beacons) to measure the effectiveness of their advertisements and to personalize the advertising content.
Social Media Cookies. These cookies are used when you share information using a social media sharing button or "like" button on our Site or you link your account or engage with our content on or through a social networking website e.g. such as Facebook. The social network will record that you have done this. These cookies may also include certain code that has been placed on the Site to help track conversions from ads, optimize ads based on collected data, build targeted audiences for future ads, and remarket to qualified leads—users who have already taken certain action on the Site.
You can typically reset your web browser to refuse all cookies or to notify you when a cookie is being sent. In order to do this, follow the instructions provided by your browser.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site and some features of the Site may not function properly.
Log file information is automatically reported by your browser each time you access a web page. When you use the Site, our servers automatically record certain information your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information.
Clear GIFs. When you use the Services, we may employ clear GIFs (also known as web beacons or tracking pixels) to anonymously track online usage patterns. No Personal Data from your account is collected using these clear GIFs. We may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients. The information collected is used to make the Site better for our users.
Security of Personal Data
We consider the confidentiality and security of your information to be of the utmost importance. We will use industry standard physical, technical and administrative security measures to keep your Personal Data confidential and secure and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. Because the Internet is not a 100% secure environment we cannot guarantee the security of Personal Data, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mails communications are typically not encrypted and should not be considered secure.Your rights relating to your Personal Data
You have the right under this Privacy Policy, and by law if you are within the EU, to:Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent. This right only exists where we are relying on consent to process your Personal Data. If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.
If you want to exercise any of the rights described above, please contact us at support@elmy.com.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
If your request is clearly unfounded, repetitive or excessive, we may refuse to comply with your request in these circumstances.
California Privacy Rights
Under California’s "Shine the Light" law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.To obtain this information, please send an email message to support@elmy.com with "Request for California Privacy Information" on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.