Privacy Policy

DIGIELO PRIVACY POLICY

Effective Date: 08-11-2025

Last Updated: 04-29-2026

This Privacy Policy explains how DigiElo collects, uses, discloses, retains, and protects personal information when you use the Services. DigiElo’s privacy program is built around verified credentials, user-controlled identity, selective disclosure, consent-based proximity activation, and privacy-by-design.

CONTENT

1. Privacy Overview
2. Information We Collect
3. How We Use Information
4. Consent and User Controls
5. Location and Proximity Privacy
6. Verified Credentials and Sensitive Information
7. Elo AI and Automated Features
8. How We Share Information
9. Third-Party Services
10. Retention
11. Account Deletion
12. Security
13. Children and Minors
14. Regional Privacy Rights
15. California Notice
16. EU and UK Notice
17. Cookies, Analytics, and Similar Technologies
18. App Privacy and Data Safety Disclosures
19. Changes to This Privacy Policy
20. Privacy Contact

1. Privacy Overview

Using DigiElo may involve account information, location or proximity signals, verified credential data, profile information, partner profiles, booking details, Elo AI interactions, device information, safety reports, and app activity.

DigiElo aims to collect only what is reasonably needed for the Services, to explain how information is used, and to give users meaningful controls over proximity activation, identity reveal, Elo personalization, profile visibility, and data deletion.

2. Information We Collect

Depending on how you use DigiElo, we may collect the categories of information below.

• Account information: name, username, email address, phone number, passwordless login information, account settings, age confirmation, region, support messages, and account status.
• Verification and credential information: phone verification status, credential status, verified attributes, verification timestamps, credential issuer information, credential presentation records, account trust signals, device security signals, and related verification metadata.
• Profile and user content: profile photos, display name, bio, interests, professional information, résumé-style details, preferences, social-energy settings, posts, stories, messages, notes, reviews, and other content you choose to provide.
• Location and proximity information: approximate location, coarse location, proximity signals, nearby-device signals, Bluetooth-related signals, geofence events, Hot Zone activity, Hello Zone activation, partner or venue proximity, booking-related location context, and safety signals.
• Elo AI interactions: prompts, messages, preferences, suggestions, match explanations, interaction feedback, compatibility signals, AI-generated summaries, safety signals, and settings used to personalize Elo.
• Partner profiles, bookings, events, and business activity: partner profile interactions, business listings, booking requests, booking confirmations, event RSVPs, offers, redemption activity, service preferences, and related communications.
• Device, usage, and security data: device type, operating system, app version, IP address, identifiers, crash logs, diagnostics, performance data, fraud signals, security logs, login activity, permission status, and abuse-prevention data.
• Payment and transaction data: purchase history, subscription status, transaction identifiers, billing events, refunds, payment processor data, and tax-related information. DigiElo may not receive full payment card numbers if processed by a third-party payment provider or app marketplace.
• Communications: support messages, feedback, surveys, safety reports, legal requests, consent records, and communications with DigiElo.

If identity verification, camera verification, or liveness checks are used, we may collect images, video frames, liveness signals, identity-document information, or verification-provider results, subject to required notices and consent.

3. How We Use Information

DigiElo may use personal information to create and maintain accounts; provide verified credentials; secure accounts and prevent fraud; provide Elo AI features; support Hello Zone and Hot Zone; enable consent-based profile unlocking; support partner profiles, bookings, events, and offers; personalize relevant discovery; process purchases and subscriptions; send service, safety, booking, and account notifications; respond to support requests; moderate content and enforce rules; detect stalking, harassment, scraping, impersonation, fraud, spam, and abuse; improve, test, debug, and develop DigiElo; comply with law; and protect users, third parties, DigiElo, and platform integrity.

DigiElo does not use verified credentials to guarantee a user’s character, intentions, suitability, or offline safety.

4. Consent and User Controls

Some features require your consent or settings choice before use, including location-based discovery, proximity activation, profile visibility, verified credential presentation, camera or liveness verification, notifications, Elo personalization, partner or booking interactions, direct chat, and profile unlocking.

You may change many settings in the app or your device settings. Disabling permissions may limit or disable some features.

If you withdraw consent, DigiElo will stop the related processing where required, subject to legal, safety, fraud-prevention, backup, compliance, and dispute-resolution limits.

5. Location and Proximity Privacy

DigiElo may use location or proximity data to provide Hot Zone, Hello Zone, verified presence, local discovery, partner discovery, booking relevance, event discovery, offers, safety controls, and fraud prevention.

DigiElo does not intend to create public movement trails. DigiElo may blur, delay, jitter, aggregate, or limit location signals to protect privacy and safety.

Other users should not receive your precise location unless you clearly choose a feature that shares more precise location with a specific participant for a specific purpose. Any such feature should be temporary, optional, and revocable.

DigiElo may reduce or disable proximity visibility where safety signals, sensitive locations, repeated intersections, or abuse patterns are detected.

6. Verified Credentials and Sensitive Information

DigiElo may process sensitive information where needed for verified credentials, identity assurance, safety, fraud prevention, or legal compliance.

DigiElo aims to verify and disclose only the minimum information needed for a feature. For example, DigiElo may show that a user has a verified credential without revealing the underlying raw data.

Where required by law, DigiElo will request additional consent before collecting or using sensitive information such as precise location, biometric-related information, identity-document data, or sensitive profile information.

7. Elo AI and Automated Features

Elo may process information from your account, profile, verified credentials, preferences, interactions, proximity settings, booking activity, and app behavior to provide suggestions, prompts, explanations, safety filters, and relevance signals.

Elo suggestions are not guarantees and may be wrong. DigiElo may use human review, automated review, testing, logging, safety filters, and quality controls to improve Elo and protect users.

If DigiElo uses a third-party AI provider to process personal information, DigiElo will disclose that use where required and will use reasonable contractual and technical safeguards.

DigiElo does not use Elo to make final employment, credit, housing, insurance, medical, legal, or emergency decisions.

8. How We Share Information

DigiElo may share information with:

• Other users: only as allowed by your settings, consent, interactions, profile visibility, credential presentation, booking activity, or feature use.
• Service providers: cloud hosting, security, analytics, crash reporting, customer support, payment processing, identity verification, credential infrastructure, notification delivery, AI processing, fraud prevention, and other vendors that help operate DigiElo.
• Partners, businesses, hosts, employers, or service providers: when you interact with a partner profile, make a booking, RSVP to an event, redeem an offer, apply for an opportunity, contact a business, or otherwise direct DigiElo to share information.
• Legal and safety recipients: law enforcement, courts, regulators, emergency contacts, legal advisors, or other parties where DigiElo believes disclosure is required or appropriate to comply with law, enforce terms, protect safety, prevent fraud, or defend rights.
• Business transfer recipients: a buyer, investor, financing party, successor, or advisor in connection with a merger, acquisition, financing, reorganization, sale, or transfer of assets.
• Aggregated or de-identified data recipients: DigiElo may use or share aggregated or de-identified information that does not reasonably identify you for analytics, safety, research, product improvement, or business purposes.

DigiElo does not sell personal information in the ordinary sense of selling user data for money. Some privacy laws define “sale,” “sharing,” or targeted advertising broadly. Where those laws apply, DigiElo will provide required notices and opt-outs.

9. Third-Party Services

DigiElo may link to or integrate with third-party services, including app marketplaces, payment processors, verification providers, partners, businesses, booking providers, event hosts, analytics providers, AI providers, or websites.

Third-party services may have their own terms and privacy policies. DigiElo is not responsible for third-party privacy practices.

10. Retention

DigiElo keeps personal information only as long as reasonably necessary for the purposes described in this Privacy Policy, including providing services, maintaining accounts, supporting verified credentials, processing bookings, preventing fraud, enforcing Terms, resolving disputes, complying with law, and protecting safety.

Some data may expire sooner by feature design, such as temporary proximity signals, temporary chats, stories, session identifiers, or safety logs. Actual retention periods may vary by feature, legal obligation, account status, safety need, and technical backup cycle.

Deleted information may remain for a limited time in backups, audit logs, legal holds, fraud-prevention systems, safety records, transaction records, or where retention is required or permitted by law.

11. Account Deletion

If DigiElo allows account creation, users may request account deletion through the app using: Profile & Settings → Account → Delete Account, where available.

Users may also request deletion by visiting the Data Deletion Request page at https://digielo.com/data-deletion or by emailing info@digielo.com with the subject line “Deletion Request.” Include your account email or username, request type, and your country or state of residence.

When you delete your account, DigiElo will delete or de-identify personal information associated with your account unless retention is reasonably necessary for legal compliance, fraud prevention, safety, dispute resolution, transaction records, security, backups, or enforcement.

Deleting the app from your device does not automatically delete your account.

12. Security

DigiElo uses reasonable administrative, technical, and organizational safeguards designed to protect personal information. These may include encryption, access controls, credential security, monitoring, vendor review, and incident-response procedures.

No system is perfectly secure. DigiElo cannot guarantee that information will never be accessed, disclosed, altered, or destroyed. You are responsible for keeping your device, account, passkeys, and login methods secure.

13. Children and Minors

DigiElo is not intended for children under 18. DigiElo’s default service is intended for adults unless DigiElo launches a separate age-appropriate experience with required safeguards.

If DigiElo learns that it collected personal information from a child under 13 without required consent, DigiElo will take appropriate steps to delete or restrict that information.

14. Regional Privacy Rights

Depending on where you live, you may have rights to access personal information; correct inaccurate information; delete personal information; export information; restrict or object to certain processing; withdraw consent; opt out of certain sale, sharing, targeted advertising, or profiling; and appeal a privacy- rights decision.

To exercise rights, contact info@digielo.com or visit https://digielo.com/privacy. DigiElo may verify your request before responding. Some information may be exempt from deletion or access where allowed by law.

15. California Notice

If you are a California resident, California privacy law may provide additional rights regarding personal information, sensitive personal information, sale, sharing, targeted advertising, correction, deletion, access, portability, and non-discrimination.

DigiElo may collect the categories of personal information described in this Privacy Policy, including identifiers, account information, commercial information, internet or app activity, geolocation information, user content, sensitive information where enabled, and inferences used for app functionality.

DigiElo uses this information for the purposes described in this Privacy Policy. DigiElo does not knowingly sell personal information for money. If DigiElo engages in activity considered “sale” or “sharing” under California law, DigiElo will provide required opt-out rights.

16. EU and UK Notice

If EU or UK privacy law applies, DigiElo may process personal information based on consent, contract necessity, legitimate interests, legal obligations, vital interests, public interest where applicable, or another lawful basis.

You may have rights to access, correct, delete, restrict, object, export, or withdraw consent. You may also have the right to lodge a complaint with a supervisory authority.

DigiElo may transfer information to countries outside your region. Where required, DigiElo will use appropriate safeguards for international transfers.

17. Cookies, Analytics, and Similar Technologies

DigiElo’s website or app may use cookies, local storage, analytics tools, crash reporting, diagnostics, or similar technologies to operate the Services, remember settings, improve performance, secure accounts, prevent fraud, and understand usage.

Where required, DigiElo will provide controls or notices for non-essential cookies, analytics, or similar technologies.

18. App Privacy and Data Safety Disclosures

DigiElo may provide data safety, app privacy, permission, and marketplace disclosures through app distribution platforms. Those disclosures are summaries of DigiElo’s data practices. This Privacy Policy provides more detail.

DigiElo’s app-marketplace privacy disclosures should match the actual data collected by DigiElo and its third-party SDKs, service providers, analytics tools, verification providers, AI providers, payment providers, booking providers, and security tools.

If DigiElo changes its data practices, DigiElo may update this Privacy Policy and the corresponding app- marketplace privacy or data-safety disclosures.

19. Changes to This Privacy Policy

DigiElo may update this Privacy Policy from time to time. If changes are material, DigiElo will provide notice through the app, website, email, or another reasonable method.

The Effective Date shows when this Privacy Policy was last updated.

20. Privacy Contact

For privacy questions, data rights requests, deletion requests, safety reports, legal notices, or general support, contact DigiElo at info@digielo.com.

Mailing address: DigiElo, Inc., 2810 N Church St #130253, Wilmington, Delaware 19802.

Privacy page: https://digielo.com/privacy

Data deletion page: https://digielo.com/data-deletion