Privacy Policy – Eloïa

1. Data Controller

LUMALYA LDA
Portuguese company
(hereinafter referred to as "Eloïa", "we", "our")

General contact : contact@eloia-connect.com
Administration contact : admin@eloia-connect.com

2. Scope of Application

This Privacy Policy applies to:

• the Eloïa website;
• the Eloïa mobile application;
• all services and functionalities offered.

The application is strictly reserved for individuals aged 18 years or older.

No data relating to minors is intentionally collected. If an account belonging to a minor is identified, it may be removed without prior notice.

3. Personal Data Collected

Depending on the use of the services, Eloïa may collect different categories of personal data.

3.1 Data Provided Directly by the User

• first name, last name, or username;
• email address;
• date of birth;
• gender (where applicable);
• family status;
• personal preferences and relationship intentions;
• answers to compatibility questionnaires and tests;
• content voluntarily published (texts, images, videos, messages, audio content);
• communications with customer support or administration.

Questionnaires and responses completed within the application are used to analyze compatibility and affinities between users, notably through behavioral, emotional, and relational analysis mechanisms.

3.2 Automatically Collected Data

When using the application or website, certain technical data may be automatically collected, including:

• IP address;
• device type;
• operating system;
• technical identifiers;
• language used;
• browsing data;
• interactions with features;
• connection data;
• usage statistics.

3.3 Analytics and Marketing Data

Eloïa uses analytics and audience measurement tools provided by third-party partners, including Amplitude and AppsFlyer, in order to:

• analyze application usage;
• measure technical performance;
• understand user behavior;
• improve functionalities;
• measure the effectiveness of marketing and advertising campaigns;
• prevent fraudulent behavior.

In this context, certain technical and behavioral data may be collected, including:

• navigation events;
• interactions within the application;
• download sources;
• advertising identifiers;
• device type;
• operating system;
• statistical usage data.

This data is used exclusively for analysis, service improvement, and security purposes.

Eloïa does not sell users' personal data.

4. Purposes of Data Processing

Personal data is processed for the following purposes:

• creation and management of user accounts;
• operation of the platform;
• connecting users with one another;
• compatibility and affinity analysis;
• improvement of user experience;
• moderation and security;
• fraud and abuse prevention;
• management of premium subscriptions;
• service-related communications;
• statistical analysis and marketing performance measurement;
• compliance with legal obligations.

5. Legal Basis for Processing

Personal data processing is based notably on:

• performance of the contract between Eloïa and the user;
• the user's consent where required;
• Eloïa's legitimate interests;
• compliance with applicable legal obligations.

6. Identity Verification

As of the publication date of this policy, no official identity verification is required during registration.

However, Eloïa may later introduce a verified profile system available on a voluntary basis, particularly within certain premium features.

Users may notably:

• verify their identity;
• choose to interact only with verified profiles.

Any future identity verification process will be implemented in compliance with the GDPR.

7. Content Moderation and Security

In order to maintain a respectful and secure environment:

• certain content may be subject to human and/or automated moderation;
• unlawful, fraudulent, hateful, violent, misleading, or Terms-violating content may be removed;
• certain behaviors may lead to temporary or permanent account suspension.

Reports submitted by users may also be reviewed to ensure platform security.

8. Intellectual Property and User-Generated Content

Users remain solely responsible for the content they publish, share, or distribute on the Eloïa platform, including texts, photographs, videos, music, audio recordings, or any other content.

By publishing content on the platform, users guarantee that they possess all rights, authorizations, licenses, or consents necessary for its use and distribution.

It is strictly prohibited to publish, share, or distribute copyrighted content without prior authorization from the rights holders, including:

• music;
• concert excerpts;
• videos;
• films;
• television programs;
• streaming platform content;
• artistic works;
• third-party content.

Users also agree not to publish content that infringes upon:

• intellectual property rights;
• image rights;
• privacy rights;
• human dignity;
• or applicable laws.

Eloïa does not systematically pre-screen user-generated content.

However, any content reported as unlawful or infringing third-party rights may be removed without prior notice.

9. AI-Generated Music and Audio Content

Music, soundscapes, and audio content made available within the Eloïa application may be generated, operated, or provided by Musikimo LDA or authorized partners.

Such content is intended exclusively for internal use within the Eloïa application.

It is strictly prohibited to:

• copy, record, or extract such content;
• reproduce or distribute it outside the application;
• use it for commercial or external promotional purposes.

Any unauthorized use may constitute a violation of intellectual property rights.

10. Prohibited Behaviors

In order to preserve the authenticity and security of the platform, Eloïa notably prohibits:

• escorting or prostitution-related activities;
• paid sexual solicitation;
• promotion or sale of commercial sexual content;
• fake profiles or identity theft;
• scams or financial solicitations;
• spam;
• manipulative or fraudulent behaviors;
• hateful, discriminatory, or unlawful content;
• abusive redirections to Telegram, WhatsApp, OnlyFans, or any other external platform;
• behaviors intended to misuse or divert the normal operation of the platform.

Eloïa reserves the right to suspend or remove without prior notice any account violating these rules.

11. Data Sharing

Personal data is neither sold nor rented.

Data may only be shared with:

• technical service providers;
• analytics providers;
• security partners;
• maintenance providers;
• administrative or judicial authorities where required by law.

All providers acting on behalf of Eloïa are bound by contractual confidentiality and GDPR compliance obligations.

12. Data Hosting and International Transfers

Users' personal data is hosted and processed through technical infrastructures operated by recognized service providers.

As of the publication date of this policy:

• the main application servers and databases are hosted on Google Cloud Platform (GCP), notably within data centers located in the European Union;
• certain third-party services may involve transfers of personal data outside the European Union, particularly to the United States.

In this context, Eloïa ensures that such transfers are based on appropriate safeguards in accordance with the GDPR, notably through standard contractual clauses or mechanisms recognized by the European Commission.

Eloïa reserves the right to modify its hosting and technical infrastructure choices at any time according to the evolution of the service, while maintaining a level of protection compliant with applicable legal requirements.

13. Data Retention Period

Personal data is retained:

• for the entire duration of active use of the user account;
• then deleted or anonymized within a reasonable period after account deletion;
• certain data may be retained longer where required by law or necessary to ensure platform security.

Data relating to reports, fraud, or violations of the Terms of Use may be retained for an additional period where necessary to protect Eloïa's legitimate interests.

14. Users' Rights

In accordance with the GDPR, each user notably has the following rights:

• right of access;
• right to rectification;
• right to erasure;
• right to restriction of processing;
• right to object;
• right to data portability;
• right to withdraw consent at any time where processing is based on consent.

Users may exercise their rights by contacting: contact@eloia-connect.com

Users also have the right to lodge a complaint with the competent data protection authority.

15. Data Security

Eloïa implements reasonable technical and organizational measures to protect personal data against:

• unauthorized access;
• loss;
• alteration;
• disclosure;
• or misuse.

Communications between the application, website, and servers are protected through secure encrypted transmission protocols.

As of the publication date of this policy, content stored within databases may not necessarily benefit from end-to-end encryption.

Eloïa nevertheless continuously strives to improve its security systems.

16. Cookies and Similar Technologies

The Eloïa website may use cookies and similar technologies in order to:

• ensure proper website functionality;
• measure audience traffic;
• analyze service usage;
• improve user experience.

Users may manage cookie preferences through browser settings or tools provided on the website.

17. Changes to the Policy

This Privacy Policy may be modified at any time in order to reflect:

• technical developments;
• legal developments;
• changes to the services provided.

Users will be informed of any substantial modifications.

18. Contact

For any questions relating to this Privacy Policy:

contact@eloia-connect.com