As ElitePlus, we demonstrate maximum sensitivity to the security and privacy of our users' personal data within the scope of the services we provide via the ElitePlus mobile application ("App").
This Privacy Policy has been prepared to inform you about how your personal data is collected, the purposes for which it is processed, the legal grounds for processing, the parties to whom it may be disclosed, and your rights under applicable US privacy laws (including the California Consumer Privacy Act — CCPA) and other relevant regulations.
As the "Business" (or Data Controller), our Company processes your personal data as explained below and within the limits prescribed by legislation.
1. Personal Data We Collect
Within the scope of your use of the ElitePlus App, we process the following categories of personal data:
•Identifiers (Identity Information): Name, surname, username (nickname), date of birth, gender.
•Contact Information: Email address, mobile phone number.
•Audio-Visual Data & User Content: Profile photo, visual and audio recordings created/shared during interaction, live stream data.
•Transaction Security & Technical Data: IP address, device information (Device ID, model, operating system), access logs, password, and credential information.
•Usage Data & Interactions: Users you follow or who follow you, comments, likes, and in-app interaction data.
•Biometric / Face Data: A facial image and the facial geometry derived from it, captured at the moment of verification solely for age and liveness verification. See Section 2 below for details.
•Location Data: Approximate/precise location, processed only when you manually choose to appear on the map ("check in"). See Section 3 below for details.
2. Face Data (Biometric Data) and Age/Liveness Verification
ElitePlus serves users aged 18 and over only. To confirm that an account belongs to a real person and meets the age requirement, we may ask you to provide a facial image (selfie) during registration or verification.
•Face Data We Collect: Your facial image captured at the moment of verification, and the facial geometry (biometric template) derived from that image.
•Purpose of Use (Limited): Your face data is used only to (a) verify that you are 18 or older and (b) perform a liveness check to prevent fake/bot accounts. We do not use your face data for identification, profile matching/recommendations, advertising, or marketing.
•Sharing: We do not sell your face data, share it for marketing, or transmit it to any third-party artificial intelligence (AI) service. Your face data is processed solely for verification purposes.
•Retention: Your facial image and the derived biometric template are deleted immediately upon completion of the verification process and are not stored permanently on our servers.
•Legal Basis and Consent: This processing relies on your explicit consent and our legal/legitimate interest in enforcing the 18+ age requirement. If you decline verification, you may be unable to use the Services due to the age requirement.
3. Location Data and Visibility on the Map
ElitePlus includes travel plan and check-in features that let you see nearby users on a map. Whether or not you appear on the map is always solely your decision.
•Visibility Is Opt-In: When you create a travel plan or check in, a checkbox lets you choose whether to appear on the map for that action — you can choose to appear or not each time.
•No Automatic Sharing: Unless you actively make this choice, your location is not shown on the map. We do not share your location in the background or automatically; there is no option for automatic visibility/check-ins.
•Control: You can turn off your visibility on the map at any time and revoke location permissions from your device settings. The location data collected is used only to provide this feature.
4. Purposes of Processing Personal Data
Your personal data is processed in accordance with general privacy principles for the following purposes:
•Membership & Account Management: Creating the ElitePlus user registration, editing the profile, and executing the Terms of Service.
•Provision of Services: Enabling you to interact via the App, participating in other users' interactions, and using social interaction features (comments, likes, follows).
•Communication Activities: Membership verification, password resetting, and providing mandatory service-related notifications.
•Security & Fraud Prevention: Preventing unauthorized access, detecting suspicious transactions, and keeping logs to comply with legal security obligations.
•Legal Obligations: Responding to requests from authorized public institutions and fulfilling obligations arising from applicable laws.
5. Methods of Collection and Legal Bases
Your personal data is collected electronically, fully or partially by automated means, during your registration to the ElitePlus App and creation of a profile. We process this data based on the following legal grounds:
•Contractual Necessity: For processes such as establishing the membership agreement, providing the interaction service, and profile creation.
•Legal Obligation: For keeping access logs, notifying authorized authorities when required, and ensuring data security.
•Legitimate Business Interests: For improving App performance and preventing fraudulent transactions, provided that such processing does not harm your fundamental rights and freedoms.
•Explicit Consent (Opt-In): We rely on your explicit consent, obtained separately via our "Consent Text" or pop-ups, for situations requiring international data transfers (e.g., server hosting) and the sending of commercial electronic messages (marketing).
6. Sharing and Transfer of Personal Data
Your personal data may be shared with the following parties in accordance with applicable laws:
•Domestic Recipients (US & Local Authorities): We may disclose data to judicial authorities, law enforcement agencies, and authorized public institutions if required to resolve legal disputes or upon legal request.
•Service Providers & International Transfers: To provide the App's technical infrastructure, use cloud storage services, and process interaction data globally, your data is transferred to technology service providers with servers located worldwide (e.g., AWS, Google Cloud, etc.). This transfer occurs only with your explicit consent or where necessary for the performance of the contract.
•Third-Party AI Services: We do not share your personal data with, or transmit it to, any third-party artificial intelligence (AI) service.
7. Your Rights (US & CCPA/CPRA)
Depending on your jurisdiction (including residents of California), you have the following rights regarding your personal data:
•Right to Know/Access: You have the right to confirm whether we are processing your personal data and to request access to that data.
•Right to Correct: You have the right to request the correction of inaccurate personal data.
•Right to Delete: You have the right to request the deletion of your personal data, subject to certain legal exceptions.
•Right to Opt-Out: You have the right to opt-out of the processing of your data for targeted advertising or the sale of your data (if applicable).
•Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.
To exercise these rights, you may submit your requests in writing to [email protected]. We will respond within the timeframes required by applicable law.
