Privacy Policy – Eloïa

1. Data Controller

LUMALYA LDA
Portuguese law company
(hereinafter "Eloïa", "we", "our")

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

2. Scope

This policy applies to:

• the Eloïa website,
• the Eloïa mobile application,
• all services offered.

The application is strictly reserved for persons aged 18 or over. No data concerning minors is intentionally collected.

3. Personal Data Collected

Depending on the use of services, we may collect the following categories of data:

3.1 Data provided directly by the user

• First name, last name or pseudonym
• Email address
• Date of birth (only to verify age)
• Gender (where applicable)
• Family situation (including whether or not having children)
• Personal preferences and relational intentions
• Responses to questionnaires and analysis tests (behaviors, emotions, affinities, relational perceptions)
• Voluntarily published content (texts, images, messages)

These questionnaires and responses are used to analyze compatibilities and affinities between users, particularly through emotional and behavioral analysis mechanisms, in order to offer relevant connections.

3.2 Automatically collected data

• IP address
• Device type, operating system
• Technical identifiers
• Navigation and application usage data

4. Purposes of Processing

Personal data is processed for the following purposes:

• Creation and management of user accounts
• Service operation and connecting users
• Improving user experience
• Security, moderation and abuse prevention
• Service-related communications (functional emails)
• Compliance with legal obligations

5. Legal Basis for Processing

Processing is based on:

• Performance of the contract (service provision)
• User consent (when required)
• Eloïa's legitimate interest (security, service improvement)
• Legal obligations

6. Identity Verification

As of the date of publication of this policy, no official identity verification (KYC) is required upon registration.

However, Eloïa plans to implement a verified profile badge in the future, accessible on a voluntary basis and reserved for certain premium offers.

Users may, if they wish:

• have their identity verified
• choose to be connected only with verified profiles

Any developments in identity verification will be implemented in compliance with GDPR and will be communicated in advance.

7. Content Moderation

To ensure a respectful and secure environment:

• Text and visual content may be subject to human and/or automated moderation
• Illegal, hateful, violent, sexually explicit content or content contrary to the terms of use may be removed
• Accounts involved may be suspended or deleted

8. AI-Generated Music and Audio Content

All music, sound atmospheres and audio content offered in the Eloïa application are generated or provided by Musikimo LDA, a partner company.

This content is made available exclusively for internal use within the Eloïa application.

It is strictly prohibited to:

• copy, extract or record this audio content
• reproduce or distribute it outside the application
• make any commercial, promotional or external personal use of it

Any unauthorized use constitutes a violation of intellectual property rights.

9. Data Sharing

Personal data is neither sold nor rented.

It may only be shared with:

• Technical service providers (hosting, maintenance, security tools)
• Competent authorities when required by law

All service providers are subject to contractual obligations of confidentiality and GDPR compliance.

10. Data Hosting and International Transfers

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

As of the date of publication of this policy:

• the application servers and databases are hosted on Google Cloud Platform (GCP), in a data center located in France (Paris);
• certain ancillary services, particularly related to website or landing page hosting, may be operated by providers located outside the European Union, particularly in the United States.

In this context, Eloïa ensures that any transfer of personal data outside the European Union is based on appropriate safeguards, in accordance with GDPR, particularly through the use of standard contractual clauses or recognized mechanisms ensuring an adequate level of protection.

Eloïa reserves the right to change its hosting and technical infrastructure choices at any time, depending on the evolution of the service, while maintaining a level of protection in compliance with applicable legal requirements.

11. Data Retention Period

Data is retained:

• As long as the user account is active
• Then deleted or anonymized within a reasonable period after account deletion
• Some data may be retained longer for legal obligations

12. User Rights

In accordance with GDPR, you have the following rights:

• Right of access
• Right to rectification
• Right to erasure
• Right to restriction of processing
• Right to data portability
• Right to object

You may exercise your rights at any time by writing to: contact@eloia-connect.com

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

13. Data Security

Eloïa implements appropriate technical and organizational measures to protect personal data against unauthorized access, loss, alteration or disclosure.

Exchanges between the application or website and servers (API requests, network communications) are protected by encryption protocols.

As of the date of publication of this policy, messages and content stored in databases are not end-to-end encrypted.

Eloïa nevertheless strives to continuously improve its security measures and reserves the right to evolve its protection mechanisms, depending on technical advances, operational constraints and service needs.

14. Policy Changes

This policy may be modified at any time to reflect legal or technical developments.

Users will be informed of any substantial changes.

15. Contact

For any questions regarding this privacy policy:

contact@eloia-connect.com