Ello Privacy Policy

1. Consent

By using the Services, you consent to the use of your Personal Information as described in this Privacy Policy.  The mobile app is intended to be used by students in pre-K to Grade 3, and parents assisting these students. The website is intended to be used by parents. If you are not of legal age to form a binding contract (in many jurisdictions, this age is 18), you may only use the Services and disclose information to us with your parent’s or legal guardian’s express consent. Review this Privacy Policy with your parent or legal guardian to make sure you understand it.  Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent.  We do not actively collect Personal Information for the purpose of sale of such information in a way that specifically identifies the individual (i.e. we don’t sell customer lists).  You may withdraw your consent to our processing of your Personal Information at any time.  However, withdrawing consent may result in your inability to continue using some or all of the Services.  

Intended Use
Ello is primarily used and designed for children under 13 years of age and their parents. It is primarily marketed to their parents and to schools for preschool and K-12 purposes. Managed accounts for parents or teachers are not available at this time.

Ello does not contract with a school or educational authority at this time. As such, Ello does not provide a contract to a Local Educational Agency, nor does it designate itself as a ‘School Official’ under FERPA. Given we do not contract with schools or districts, no responsibility or liability for obtaining verified parental information is transferred to the school or district. Education records are not entered into the product.

Ello does not allow social interactions on its product at this time. As such, users cannot interact with other users, including strangers and/or adults, no social interactions are logged and profile information is not shared for social interactions or displayed publicly. No user created content is displayed publicly and as such, California’s Privacy Rights for California Minors in the Digital World Act does not apply.

2. Collection of Information

Registration Information

When registering for the Services, we may require you to provide certain personally identifiable information, such as your name, email, phone, address, child’s first name, child’s grade and reading level, and child’s interests (these are referred to below as your “Registration Information”).  This child may be in pre-K-12. Your Registration Information, together with any other information we gather through the Services that may be used to identify, contact, or locate you individually, are collectively referred to herein as your “Personal Information.”

Ello does not share any personal information with large language models (LLMs) or any third parties. Any personal information combined with non-personally identifiable information will also be treated as personal information. We do anonymize and aggregate some of this personal data into datasets that are not personally identifiable.

Sensitive Information
Ello does not collect sensitive information such as: Political affiliations, religious beliefs, philosophical beliefs, race or ethnicity, sexual orientation, health data, genetic information, geolocation data, biometric data, criminal history, credit or financial data, trade union and membership information or personal identification (ID) numbers including those of a license, social security, state ID cards or passports.

Data Integration and Profiling
Data collected or maintained by Ello is not augmented, extended or combined with data from third-party sources. Neither Ello nor a third party will verify your identity with additional personal information.

Data

You may be able to create, upload, publish, transmit, distribute, display, store or share information, data, text, graphics, video, messages or other materials using our Services (this is collectively referred to below as “Data”).  Some of this Data may be stored and maintained on our servers.  

You cannot interact with other users through our services at this time, nor can you share data with our users through our services. As such, no information is shared by a user to participate in interactions on our services, and no personal information is displayed to other users or made publicly visible. There are no postings or social interactions to moderate, log, filter or block on our services.

We aim to limit the collection of personal information to only data that is specifically required for the use and product development of Ello. Some behavioral or activity related data is collected such as interaction with app features, on-site purchases and frequency and duration of app or website usage.

Usage and Analytics Information

We may also collect information through the use of commonly-used information-gathering tools, such as cookies, log files, and Web beacons. Collectively, this information is referred to as “Usage and Analytics Information.”  

Cookies

We use standard browser cookies to allow us to remember details of a user session. For example, we may use cookies to make it easier for the user to resume a recent session without re-entering their log-in details.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

Log Files

We use standard browser cookies to allow us to remember details of a user session. For example, we may use cookies to make it easier for the user to resume a recent session without re-entering their log-in details.

As is true of most websites, we gather certain information automatically to analyze trends in the aggregate and administer the Services. This information may include your Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), your browser type, the pages and files you viewed, your operating system, your actions in connection with our Services, and date/time stamps associated with your usage.

Web Beacons

We use web beacons alone or in conjunction with cookies to compile information about your usage of the Services and interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website or Service tied to the web beacon, and a description of a website or Service tied to the web beacon. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. We also use web beacons to operate and improve the Services and our email communications.

3. Facebook Pixel

We use the “advertising pixel” from Facebook Inc. (“Facebook”) on our website. This allows user behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy at https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes. You can opt out to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads. 

4. Use of Information

We use the information we collect in the following ways:

5. Disclosures & Transfers

We will not disclose or transfer your Personal Information to third parties without your permission, except as specified in this Privacy Policy (see further below).

From time to time we may employ third parties to help us provide and/or improve the Services.  These third parties may have access to or process your information as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.

We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities.  We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.

We may also disclose your Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, or a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information. Should this occur, you will be notified by Ello or the successor entity and you may request to delete your data prior to such an event.

The categories of related third parties with whom we may share data with are given as below:

1. Service Providers: Entities that provide services for the use and development of Ello, such as hosting, data storage or analytics.

2. Marketing Partners: Entities involved in displaying advertisements on the platform, which may include ad networks, advertisers, and other advertising-related service providers. You may receive email or text communication from such a third party, or from Ello using the services provided by such a third party. You can choose to unsubscribe from Ello or third party marketing communications at any time. You can request to opt-out of contextual, or personalised advertising by contacting support@helloello.com. You may be asked to participate in third-party sweepstakes, contests, surveys or similar promotions.3. Payment Processors: Entities responsible for processing payments and handling financial transactions.

4. Legal and Compliance Partners: Entities involved in ensuring legal compliance, responding to legal requests, or conducting audits, which may include legal advisors or regulatory authorities.

Response to Legal Requests

In the event that Ello receives a government or legal request for user information, we are committed to providing notice to the affected users unless prohibited by law. We will make reasonable efforts to notify users of such requests promptly, unless we are legally restricted from doing so. Notifications may be delivered through email or phone.
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Exceptions and Limitations:
In situations where providing notice is prohibited by law, poses a risk of harm, or is not reasonably practicable in emergency situations where there is an imminent risk of harm or where immediate action is required, we may respond to legal requests without prior notice.

Who we don’t share data with:

Ello does not have affiliates or subsidiaries with which it shares data.

Currently no third-party, social or federated login is supported. No information is collected from any third-party login providers or shared with third party login providers.

Successor Entities

We may also disclose your Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, or a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information. Should this occur, you will be notified by Ello or the successor entity and you may request to delete your data prior to such an event.

6. Non-US Users

These Services are hosted in the United States and are intended primarily for visitors located within the United States. If you choose to use the Services from other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you may be transferring your Personal Information outside of those regions to the United States for storage and processing.  By providing your Personal Information through the Services, you consent to such transfer, storage, and processing.

7. Security.

The security of your Personal Information is important to us.  We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment.  We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us.  We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.

Personal information is encrypted in transit and at rest. Our data privacy and security practices are internally audited on an annual basis. Multi-factor authentication is required at login and you need to keep your password safe! In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and will notify you of the security incident in accordance with applicable laws and regulations.

You are also responsible for helping to protect the security of your Personal Information.  For instance, never give out your password, and safeguard your user name, password and personal credentials when you are using the Services, so that other people will not have access to your Personal Information. Access to your user account is protected by 2FA. Furthermore, you are responsible for maintaining the security of any personal computing device on which you utilize the Services.  

8. Retention

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you.  We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law.  All retained Personal Information will remain subject to the terms of this Privacy Policy.  Please note that if you request that your Personal Information be removed from our databases, it may not be possible to completely delete all of your Personal Information due to technological and legal constraints.

9. Amendment of this Privacy Policy

We reserve the right to change this Privacy Policy at any time.  If we decide to change this Privacy Policy in the future, we will post or provide legally required notice.  Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted, and any material changes will become effective 30 days from their posting on www.ello.com/privacy or via email to your listed email address.  Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you and your account.  The date on which the latest update was made is indicated at the top of this document.  We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes.  Your continued use of the Services signifies your acceptance of any changes.

Changelog
Past policy versions are publicly available for review as follows:

• Version last updated 5 May 2021: www.ello.com/privacy-may-5-2021

10. Access and Accuracy

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information.  Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances we may not be able to make all relevant information available to you, such as where that information also pertains to another user.  In such circumstances we will provide reasons for the denial to you upon request.  We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate.  As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information.  Having accurate Personal Information about you enables us to give you the best possible service.

11. Notice to California Consumers

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties.  

We have the information you provide us as part of the sign up process which we use to tailor and provide the service.

IF you give us permission, we may then collect audio recordings of your child. This is optional and the service will work without this, although you may miss out on some features.

We use this audio for two reasons, you can give us permission for both or just one of these uses:

1. To provide additional features to your child, such as being able to hear themselves read.
2. To improve our product more generally. The audio data would be anonymized to the extent possible.

12. Children

This section explains our information collection, disclosure, parental consent practices and parental choice procedures with respect to information provided by children under the age of 13 (“Child” or “Children”). This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”), and outlines our practices in the United States regarding Children’s personal information. For more information about COPPA and general tips about protecting Children’s online privacy, please visit OnGuard Online.

Collection: Ello collects information about Children directly from their parents and guardians (“Parents”), who provide us with their Child’s first name, grade, reading level, family situation, home environment, school, activities and interests (“Parent-Supplied Information”). In addition, if Parents enable the “Individual Service Improvement” and/or “General Service Improvement” settings in the Ello App, then Ello may collect spoken audio files of Children while they are reading books during use of the Ello App (“Audio Recordings”). No collected data is excluded from coverage of this Privacy Policy.

Use and Disclosure

Parent-Supplied Information: Ello uses Parent-Supplied Information in order to provide Parents and their Children with custom tailored services, including preparing a custom-tailored box of books for the Child to read and enjoy each month as part of our Subscription Service.  

If Individual Service Improvement is Enabled: If a Parent enables the “Individual Service Improvement” setting in the Ello App, then Ello may store and process Audio Recordings in order to enhance and improve the Services specifically for the Parent’s Child.  Such improvements and enhancements shall consist of:

1. In-app reading support functions for the Child, such as playback features and real time word accuracy analysis.
2. Analytics to measure the Child’s reading proficiency and progress, such as analysis of words spoken per minute, or identification of the most common mistakes made by the Child.
3. Customizations to the Ello App to make it work better for the specific Child, such as training Ello’s models and algorithms to better pick up the Child’s speech patterns. 

Unless a Parent also enables the “General Service Improvement” setting in the Ello App, Ello shall not use Audio Recordings for other purposes without the Parent’s express written consent.

If General Service Improvement is Enabled: If a Parent enables the “General Service Improvement” setting in the Ello App, then we may also use Audio Recordings on an anonymized and aggregated basis to improve our Services generally.

Miscellaneous: All information pertaining to a Child shall also be treated as part of the Parent’s “Personal Information” and may be shared as described in the “Disclosure” section above for business transfers; to vendors and service providers; to comply with legal requirements; and also pursuant to a Parent’s instructions.

Parental Consent: Ello obtains verifiable parental consent before collecting personal information from your Child by requiring you to provide your credit card information (in connection with an actual financial transaction) at the time of subscribing to our Services. If you do not consent, then we will not collect, use or disclose any personal information about your Child, and your Child will not be allowed to use our services in any way.  If you are not using our Services for any other purposes and do not provide consent within a reasonable time from the date the direct notice was sent to you, we will also delete your online contact information from our records.

‍Parental Choices and Controls: At any time, you can refuse to permit us to collect further Personal Information from your Child in association with your account, and can request that we delete from our records the Personal Information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service. You can contact Ello to request access to, change, or delete your Child’s personal information by sending an email to us at support@helloello.com. A valid request to delete personal information will be accommodated within a reasonable time. In addition to the foregoing, we will exercise commercially reasonable efforts to delete personal information belonging to Children when it is no longer needed for the purpose for which it was collected.

Is Ello a safe experience?

We endeavor to provide an age-appropriate and safe experience.
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We aim to ensure any outbound links on the services intended for use by those under 18 are age-appropriate.

You can help by keeping us informed of any changes such as a change of email address or telephone number. We aim to modify any inaccurate data once you give us notice. If you would like to access your information, if you would like to request all the personal information that Ello has shared with third parties, if you would like to request to edit or delete your information at Ello or a third party, if you would like to assign a legacy contact to access your data, if you find any inappropriate content on our services, if you would like to report harassment or cyberbullying, or any unsafe or inappropriate interaction at Ello If you would like to access your information, if you have any questions, comments or suggestions, if you find any errors in our information about you, or if you have a complaint concerning our compliance with applicable privacy laws, please contact us at support@helloello.com or by mail at:

 Ello Technology, Inc.
2447B Mission St, San Francisco, CA, 94110

At this time, the Privacy Policy is only available in English, but should you have any questions, please don’t hesitate to reach out.