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.
2. 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.
3. 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).
4. 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.
5. 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.
