Privacy Policy

Ellinopoula commits to strong and transparent privacy practices. Our Privacy Policy explains:

• What Personal Data we collect and why we collect it
• How we use Personal Data
• Who we share Personal Data with
• The choices we offer, including how to access, update, and remove Personal Data

Please read this Privacy Policy carefully. By using or accessing the Service (defined below), you acknowledge that you have read, understood, and agree to be bound to all the terms and conditions of this Privacy Policy, and the “Terms of Use” or other customer agreement between you and Ellinopoula that is applicable to the particular Service you are using or accessing (collectively, “User Agreements”).

If you do not agree to this Privacy Policy and the applicable User Agreement, please exit, and do not access or use, the Service.

We have kept this simple for your understanding, but if you’re not familiar with terms like “cookies” or “IP addresses,” feel free to contact us. Your privacy is really important to us, so whether you’re new to Ellinopoula or a long-time user, please take the time to get to know our practices. Click on any of the links below to go straight to one of the following sections:

• Introduction
• Transfers of Personal Data
• EU Residents
• EU-U.S. Privacy Shield Participation
• Notice of What Information We Collect and How We Use It
• Types Of Personal Data We Collect
• Mechanisms for Collection of Personal Data
• Use of Personal Data
• Online Behavioral Advertising
• Processing Grounds
• How and With Whom Does Ellinopoula Share Personal Data?
• Your Privacy Choices
• Opting Out of Behavioral Advertising and Tracking Tools
• Emails
• Information Shared With Third Parties
• Security
• Data Retention
• Interactions With Others
• What Rights and Choices Do You Have Regarding Your Personal Data?
• Accessing, Correcting, and Deleting Your Personal Data and Other Data Subject Rights
• Closing Your Account
• California Privacy Rights
• Enforcement and Recourse
• Privacy Shield Inquiries
• Changes to the Privacy Policy
• Children

• What If You Have Questions Regarding Your Personal Data?

INTRODUCTION

This Privacy Policy (“Privacy Policy”) sets forth the privacy practices of Ellinopoula Ltd and its current and future Ellinopoula Affiliates (collectively, “Ellinopoula”) for all Ellinopoula software and applications (including, without limitation, mobile software and applications) (collectively, the “Software”); the Ellinopoula website located at www.ellinopoula.com, and any other Ellinopoula websites or services that link to this Privacy Policy, (collectively, the “Websites”); and all other Ellinopoula products or services provided or otherwise made accessible on or through the Software or the Websites or that otherwise link to or reference this Privacy Policy. The Software, the Websites, and any other Ellinopoula products or services that link or refer to this Privacy Policy are collectively referred to as the “Service.” This Privacy Policy describes how Ellinopoula collects, discloses, stores, transfers, and uses information that could individually identify our users (“Personal Data”) in connection with our Service.

This Privacy Policy does not apply to the practices of third parties, as explained in more detail below. In this Privacy Policy, “we,” “us,” “our,” and other similar references mean Ellinopoula, “you” and “your” and other similar references mean any user of the Service, and “Ellinopoula Affiliates” means any parent, subsidiary, member, officer, director, employee, agent, or contractor of Ellinopoula or any entity under common control with Ellinopoula.

This policy applies (i) immediately to new users who use or access the Service on or after the Effective Date and (ii) on the Effective Date to users who use or access the Service before the Effective Date.

Please contact us if you have any questions or comments about our privacy practices. You can reach us online at support@ellinopoula.com  or by mail at the address listed in the “What If You Have Questions Regarding Your Personal Data?” section below.

TRANSFERS OF PERSONAL DATA

The Service is hosted and operated in the United States (“U.S.”), with development, support and maintenance operations in other countries, through Ellinopoula and its service providers. If you do not reside in the U.S., laws in the U.S. (and other countries) may differ from the laws where you reside. By using the Service, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Ellinopoula in the U.S. and will be hosted on U.S. servers, and you authorize Ellinopoula to transfer, store, host and process your information to and in the U.S., and possibly other countries.

EU PERSONAL DATA

If you are located in the EU, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) related to your Personal Data, as further described below. Ellinopoula will be the controller of your Personal Data processed in connection with the Service, unless you access the Service through an Ellinopoula account that is controlled by a third party (e.g. your employer).

NOTICE OF WHAT INFORMATION WE COLLECT AND HOW WE USE IT

Types of Personal Data We Collect

Ellinopoula collects Personal Data about you when you provide it directly to us, when third parties such as our business partners (e.g. companies with whom we integrate our Service), service providers (such as our advertising service providers) provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Service. We collect the following Personal Data from you in connection with the Service:

• Contact Information: information we collect to identify or contact you, we collect typical “business card information” such as your first and last name, zip/postal code, email address.
• Financial Account Information: information that you provide in connection with your purchase of the Service (or a purchase made through the Service), including credit card number, credit card expiration date, credit card verification code. You must only provide us with Financial Account Information for credit cards that you have the lawful right to access. 
• Transaction Information: information related to transactions you conduct on the Service and your interactions with the Service (for example the functionality you use and the links clicked on the Service).
• User Account Information: information that identifies you to the Service, such as your user name, email address, password, and IP address. For example, we use this information to authenticate you when you log in to the Service, and use the IP address to help maintain your web session security while using the Service. 

• Partner Information: information that our business partners, such as our content-providing partners, share with us -- for example, if you use their services to purchase, preview, and/or otherwise use their content when using our Service.
• Log Data: information automatically recorded by the Service about how a person uses our Service, such as IP addresses, device and browser type, operating system, the pages or features of our Website or Service to which a user browsed, the time spent on those pages or features, the frequency with which the Service is used by a user, search terms used by a user, the links on the Service that a user clicked on or used, and other statistics.

We also collect usage and performance information that is not Personal Data or that we aggregate or de-identify so that it no longer personally identifies an individual. We also associate some data that is not Personal Data with Personal Data.

We collect Personal Data when a user (i) creates an account (a “User Account”); (ii) logs into the Service; (iii) interacts with the Service; (iv) uploads or generates User Content; (v) communicates with us; and (vi) responds to a communication or interaction from us. Some of the methods and tools we use to collect Personal Data are:

Unique Identifiers: We use unique identifiers such as cookies, e-mail or your pseudonymized customer ID to track individual usage behavior on our Service, such as the length of time spent on a particular page and the pages viewed during a particular log-in period. Unique identifiers collect information about a user’s use of our Service on an individual basis.

Mobile Device Identifiers: Mobile device identifiers are identifiers stored on your mobile device that track certain data and activities occurring on or through your device. Mobile device identifiers enable collection of Personal Data (such as media access controls) as well as non-personally identifiable information (such as usage and traffic data).

Cookies and Other Tracking Tools: We and our third party service providers collect information about you, your device, and your use of the Service through cookies and other tracking tools and technological methods (collectively, “Tracking Tools”). Tracking Tools collect information such as computer or device operating system type, IP address, browser type, browser language, mobile device ID, device hardware type, the website or application visited or used before or after accessing our Service, the parts of the Service accessed, the length of time spent on a page or using a feature, and access times for a webpage or feature. These Tracking Tools help us learn more about our users and analyze how users use the Service, such as how often users visit our Service, what features they use, what pages they visit, what emails they open, and what other sites or applications they used prior to and after visiting the Service.

Cookies:  Like many websites and mobile application operators, we collect certain information through the use of “cookies,” which are small text files that are saved by your browser when you access our Service. Cookies can either be “session cookies” or “persistent cookies”. Session cookies are temporary cookies that are stored on your device while you are visiting our Website or using our Service, whereas “persistent cookies” are stored on your device for a period of time after you leave our Website or Service. We use persistent cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Service, and how your use of the Service varies over time. We also use persistent cookies to measure the effectiveness of advertising efforts. Through these cookies, we may collect information about your online activity after you leave our Service. For more information on cookies, including how to control your cookie settings and preferences, visit http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm, https://ico.org.uk/for-the-public/online/cookies/ and http://www.allaboutcookies.org/.

More information for how we use cookies you can find on our Cookie Policy.

Social Media Widgets: Some parts of our Service may include social media features, such as the Facebook “like” button, and widgets, such as the “share this” button. These social media features are either hosted by a third party or hosted directly on our Service. When you use these tools, the party that provides the tool, the third party that operates the social media services, and/or we may receive Personal Data about you. By using these tools, you acknowledge that some information, including Personal Data, from your social media services will be transmitted to us, and that information is therefore is covered by this Privacy Policy, and some information, including Personal Data, may be shared with the third party services, and that information is therefore governed by their privacy policies.

Use of Personal Data

Ellinopoula uses Personal Data to: (i) provide, administer, and improve our Service; (ii) better understand your needs and interests; (iii) fulfill requests you make; (iv) personalize your experience; (v) provide Service announcements; (vi) provide you with information and offers from Ellinopoula, Ellinopoula Affiliates, and our business partners; (vii) protect, investigate, and deter against fraudulent, harmful, unauthorized, or illegal activity and (viii) comply with legal obligations.

For example, we use Personal Data to:

• Operate and improve the Service
• Target offers to users
• Evaluate eligibility of customers for certain offers, products, or services
• Evaluate the types of offers, products, or services that may be of interest to users
• Provide user support
• Communicate with users regarding support, security, technical issues, commerce, marketing, and transactions
• Facilitate marketing, surveys, contests, sweepstakes, and promotions
• Administer the Service, User Accounts, and transactions with respect to User Accounts
• Enforce our contracts, administering and carrying out our obligations under contracts, and complying with the law
• Publish aggregated data about usage trends, which may be derived from Personal Data
• Complete corporate transactions such as mergers, sales of assets, or bankruptcies

PROCESSING GROUNDS

We will only use your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity, and our “legitimate interests” or the legitimate interest of others, as further described below.

• Contractual Necessity: We process the following categories of Personal Data because we need to process the data to perform under our User Agreement with you, which enables us to provide you with the Service. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Service that require such data:
• Contact Information
• User Account Information
• Financial Account Information
• Transaction Information
• User Content
• Legitimate Interest: We process the following categories of Personal Data when we believe doing so furthers the legitimate interest of us or third parties:
• Contact Information
• Financial Account Information
• User Account Information
• Transaction Information
• User Content
• Log Data

Examples of these legitimate interests include:

• Operation and improvement of our business, products, and services
• Marketing of our products and services
• Provision of customer support
• Protection from fraud or security threats
• Compliance with legal obligations
• Completion of corporate transactions
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

HOW AND WITH WHOM DOES ELLINOPOULA SHARE PERSONAL DATA?

We share Personal Data with vendors, third party service providers, and agents who work on our behalf and provide us with services related to the Service. These parties include:

• Third parties who act for us or provide services for us, such as billing and credit card payment processing, maintenance, sales, marketing, administration, support, data enrichment, hosting, and database management services
• Outside professional advisors (such as lawyers and accountants) for purposes related to the operation of our business such as auditing, compliance, and corporate governance
• Ellinopoula Affiliates, including persons or entities that acquire some or all of Ellinopoula or our assets

We also share Personal Data with third party service providers and agents when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:

• Social media services (if you interact with them through your use of the Service)
• Third party business partners who you access through the Service
• Other parties authorized by you
• The owner and administrator(s) of the Service account that you use, or of the email address that you used to register with the Service (see “Use of Third-Party E-mail Address” immediately below).

We also share Personal Data when we believe it is necessary to:

• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
• Protect us, our business or our users, or third parties, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
• Maintain the security of our products and services

We also share information with third parties when you have given us consent to do so.

Business Transfers

Ellinopoula may sell, transfer, or otherwise share some or all of its business or assets, including your Personal Data, in connection with a business deal (or the evaluation of a potential business deal) such as a merger, consolidation, acquisition, reorganization, or sale of assets or in the event of bankruptcy. You acknowledge that such transfers may occur and that any acquirer or successor of Ellinopoula or its assets may continue to use your Personal Data as set forth in this Privacy Policy. You will be notified via email and/or a prominent notice on our Website or Service of any change in ownership or resulting change in uses of your Personal Data, as well as any choices you may have regarding your Personal Data.

YOUR PRIVACY CHOICES

Opting Out of Behavioral Advertising and Tracking Tools

You can opt-out of certain Behavioral Advertising activities by doing one or more of the following. Please note that you will need to opt-out of each browser and device for which you desire to apply these opt-out features.

• Service Provider Opt Out: You can opt-out directly from some Advertising Service Providers and providers of Tracking Tools by using their opt-out tools. Some of these service providers, and links to their opt-out tools, are:
• Google Analytics: with a privacy policy at http://www.google.com/policies/privacy/partners/ and opt out at https://tools.google.com/dlpage/gaoptout.
• Web Browser Controls: You can prevent the use of certain Tracking Tools, such as cookies, on a device-by-device basis using the controls in your web browser. These controls can be found in the Tools > Internet Options (or similar) menu for your browser, or as otherwise directed by your browser’s support feature. Through your web browser, you may be able to:
• Delete existing Tracking Tools
• Disable future Tracking Tools
• Set your browser to provide you with a warning each time a cookie or certain other Tracking Tools are being set
• Do Not Track: Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. The Service does not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Service and after you leave our Service.

Information Shared with Third Parties: Except as set forth in this Privacy Policy, you will be notified when your Personal Data may be shared with third parties, and will be able to prevent the sharing of this information. To the extent permitted or required by applicable law, you can opt-out of having your information shared with a third party that is not our agent, by contacting us at support@ellinoopula.com. However, please note that opting-out of information sharing or collection may affect your ability to use some features of the Service.

SECURITY

We believe the security of your information is a serious issue and we are committed to protecting the information we receive from you. We use commercially reasonable security measures to protect against the loss, misuse, and alteration of your information under our control based on the type of Personal Data and applicable processing activity, such as data encryption in transit and enforcement of least privilege and need-to-know principles.

To the extent the Service requires you to provide any Financial Account Information, such as when you purchase subscriptions to the Service, that information will be collected and processed by third-party PCI-compliant service providers. We do not store Financial Account Information transmitted through the Service, provided that we do store (or our payment processor on our behalf will store) just the last four digits of your credit card number, if you provide this to us, to comply with credit card processing requirements of authorizations, charges and chargebacks.

DATA RETENTION

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with the Service, and thereafter as set forth in our Service agreement with you (typically 30 days after termination of the Service, or sooner upon request (except as required by law)). In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. Upon disposal, we will destroy or render unreadable any such Personal Data. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

INTERACTIONS WITH OTHERS

This Privacy Policy applies only to the Service. It does not apply to products, services, or sites that are provided by or operated by third parties, even if such products, services or sites are linked or redirected to or from the Service (“Third-Party Sites”), regardless of whether or not such link or redirection is authorized by Ellinopoula. Third-Party Sites may have their own policies regarding privacy, or no policy at all. The fact that we link to a Third-Party Site is not an endorsement, authorization, or representation that we are affiliated with that third party. Ellinopoula is not responsible for Third-Party Sites, and you use them at your own risk. We encourage you to read the privacy policies and terms of the Third-Party Sites that you visit or use.

WHAT RIGHTS AND CHOICES DO YOU HAVE REGARDING YOUR PERSONAL DATA? 

Accessing, Correcting, and Deleting Your Personal Data and Other Data Subject Rights

You have certain rights with respect to your Personal Data, and we want to help you review and update your information to ensure it is accurate and up-to-date.We may limit or reject your request in certain cases, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, if it is not required by law, or if the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question. In some cases, we may also need you to provide us with additional information, which may include Personal Data, to verify your identity and the nature of your request. We will take reasonable steps to respond to all requests within 30 days (or less!).

If you are an Ellinopoula Account holder, you can accomplish most of the following by logging into your User Account. For more information as to tools available to you and your account administrator, please contact us directly at support@ellinopoula.com if you have any additional requests or questions:

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. 
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
• Erasure: You can request that we erase some or all of your Personal Data from our systems. Please note that if you request the deletion of information required to provide the Service to you, your User Account will be deactivated and you will lose access to the Service.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

For the following, please email us at support@ellinopoula.com:

• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Service.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

You also have the right to lodge a complaint about Ellinopoula’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Closing Your Account

You may close an account, and upon termination of your User Account, we will take reasonable steps to provide, modify, or delete your Personal Data as soon as is practicable. However, Ellinopoula may nevertheless retain your Personal Data to protect the business interests of Ellinopoula, Ellinopoula Affiliates, vendors, and other users, and some information may remain in archived/backup copies for our records or as otherwise required by law. Those interests include without limitation the completion of transactions, maintaining records for financial reporting purposes, complying with our legal obligations, resolving disputes, and enforcing agreements.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of Personal Data that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the proceeding calendar year. In particular, the law provides that companies must inform consumers about the categories of Personal Data that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by Ellinopoula pursuant to Section 1798.83 of the California Civil Code, please contact as set forth above.

ENFORCEMENT AND RECOURSE

We take our privacy commitments very seriously. We will conduct internal audits of our compliance with this Privacy Policy, and work to ensure that our employees and service providers also adhere to the Privacy Policy. If you have any questions or concerns regarding privacy related to the Service, please send us a detailed message to support@ellinopoula.com, and we will try to resolve your concerns.

CHANGES TO THE PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, you will be notified via email (if you have an account where we have your contact information) or otherwise in some manner through the Service that we deem reasonably likely to reach you (which may include posting a new privacy policy on our Website—or a specific announcement on this page or on our blog). Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting) or on the Effective Date set forth in the modified Privacy Policy. In all cases, your continued use of the Service or Website after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

CHILDREN

Accounts are held by adults, and not their children. When an adult registers we collect information about your child, which you choose to provide, within the context of your Account. The information about your child is used in playlist and content generation. The information we collect is:

• a nick name
• date of birth
• gender
• Level of Greek Language ability

Information about your child is used in playlist generation and is necessary to match them with appropriate content

Ellinopoula are held by parents, as such, this Site is not directed to members under 18. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, s/he should contact us at support@ellinopoula.com. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.

WHAT IF YOU HAVE QUESTIONS REGARDING YOUR PERSONAL DATA?

Please contact us if you have any questions or comments about our privacy practices or this Privacy Policy. You can reach us online at support@ellinopoula.com, or by mail at:

Ellinopoula Ltd.
Attention: Privacy Officer
4400 Keller Ave

Suite #140
Oakland CA, 94605

USA