Privacy Policy

Thank you for taking the time to read our privacy policy (the "Privacy Policy"). At Adapt Research, Inc (dba 'Elo') ("Elo", "we", "our", or "us"), your privacy is of the utmost importance. We want you to be fully informed about the information we collect, how it is used, shared, and protected, and the choices you have with it and explain the privacy and data practices at Elo.

Elo operates an online service designed to enable our publisher customers ("Customers") to serve ads to their end users ("End Users") through their websites' or mobile applications through interactive chat functionalities (collectively, the "Services").

Elo operates https://elo.ad and https://withgrowl.com (collectively, the "Website"). This privacy policy sets out how we collect, use, process, store, and disclose personal information on our Website and in providing the Services.

We may collect personal information that you provide when you:

• Provide information through our Website.
• Contact us.
• Interact with Customer chatbots that utilize our Services.
• Visit our website where we may use online tracking technologies and other automatic data collection technologies, such as using pixels, web beacons, software developer kits, and cookies. Learn more about our cookie use below.

Customer Information:

In order to serve our Customers, we will collect various information from, or about, our Customers, including:

• Professional contact information including your name, title, company email, company name, phone, company website URL.
• Correspondence, which may include any personal information provided during an email correspondence or Customer service engagement.
• Billing and administrative finance information.
• Automated information, including metadata and analytics for your use of our Website and Services, including cookie IDs, IP address, device information, date/time of visits, new or returning visits, products viewed, page response times, URL clickstreams, how long you stay on our pages, what you do on those pages. Learn more about our cookie use below.

Our Customer's End User Information:

When our Customers use our Services to serve advertisements to their End Users, they may enable us to process various types of personal information on End Users. Below, we provide a list of the commonly processed personal information of End Users. Please note, the below list is not exhaustive of all personal information, and is intended to serve as a sample set.

• Contact information provided by End Users to our Customers, such as name, email address, phone number.
• Communications information provided in End Users' chats, which may include the content of chat messages, prior chat history included in a session, and related app or website context needed to provide the chat experience, such as page URL, page title, page description, and page content extracted from the page where the chat feature is embedded.
• Metadata and analytics collected from advertisements shown to End Users, including advertisements viewed, impressions, URL clickstreams, viewing duration, IP address, cookie ID, date/time of interaction, URL, and information on browser and operating system, including connection type, and identifiers assigned to the browser or device, such as the advertising identifiers assigned by mobile device operating systems.

We may use Customer personal information for the following business purposes:

• To provide and improve our Website.
• To communicate with you.
• To process payments securely.
• For customer support, including email and phone.
• To send our Customers marketing and promotional communications in accordance with individual marketing preferences.
• To authenticate, verify or otherwise ensure compliance with Customer written instructions or to mitigate the risk of fraud.

Subject to the terms of our Customer agreements, we may use End User's personal information for the following business purposes:

• To provide our Services to Customers, including:
  • Contextual ad delivery. We may use various elements of Customer-designated or End User content categories to deliver relevant advertisements. Elo does not profile individuals or use individuals' unique chat information to create behavioral, cross-contextual or interest-based advertising audiences. All advertisements are delivered anonymously to End Users.
  • End User communications. Our Customers may utilize Elo to provide communications support to End Users, including via email or phone/SMS based on End User consent, where legally required, or other marketing preferences.
• To improve our Services, for example, we may modify our user interface based on user behavior. See below for more information on our use of artificial intelligence for Services improvement purposes.

We may use personal information in response to any legal necessity, including intellectual property protection, or if we are required to process information as a result of a court order or other legal or regulatory proceeding.

We may otherwise use personal information with your consent.

We may also use aggregated and/or anonymous information for any purpose.

We utilize various service providers to operate our Website and Services, which may include sharing Customer and/or End User personal information. Some of the types of service providers include:

• Customer relationship management and customer billing software.
• Banking and payment processing providers.
• Cloud hosting and infrastructure providers, including Amazon Web Services and Google Cloud.
• Artificial intelligence providers to support our Services. See below for more information.
• Service providers that help manage and optimize our Website and Services (see 'Cookies and Other Tracking Technologies' below).

In addition, we may share personal information in order to:

• Protect the legal rights of our Customers, our company, our employees, our agents, and our affiliates.
• Protect the safety and security of those who access and use our Website and Services.
• Detect and protect against fraud.
• Comply with law or legal process.
• Conduct due diligence or complete a legal transaction related to the sale of our business or any assets.

We may disclose de-identified, aggregate, or anonymous information for any purpose. This means that the information does not identify specific individuals.

Elo uses various third party artificial intelligence tools to enable and improve our Services, including:

• Training our internal models to create contextual advertising segments. As noted, Elo does not use individual-level information from chat communications in order to profile individuals or create unique (aka 'deterministic') advertising segments.
• Use of third-party service providers. Elo uses third-party AI providers, including OpenRouter, Anthropic, and OpenAI, to enable and improve our Services. Our commercial terms with these providers limit the scope of their personal information processing to supporting our Services, and they are contractually restricted from using the content of our Customers' End User chats for their own model-training or product-improvement purposes.
• Aggregated and anonymous insights. Elo may use artificial intelligence tools to create aggregated insights or engage in other market research activities that benefits our Customers, potential advertisers, or other relevant parties. Any such processing activities will maintain strict confidentiality for End User personal information.

We provide our Customers with the following choices with our use of your personal information:

• Access or correct the personal information we maintain about you.
• Delete the personal information we maintain about you. Please note we may be required by law to retain certain information in compliance with accounting, tax or other legal obligations.
• Opt out of certain uses of your personal information, notably:
  • Marketing Emails: To opt out of marketing e-mail communications, you may click the 'unsubscribe' link in the marketing emails.

You can exercise these rights by contacting us at [email protected].

If you are an End User receiving Elo-delivered advertisements through one of our Customers' websites or mobile applications, and you would like to fulfill your rights to the personal information we maintain about you on behalf of that Customer, we encourage you to exercise these rights by reviewing the Customer's privacy policy to determine the correct contact method for that Customer.

Alternatively, if you email us at [email protected] and identify the Customer that is utilizing our Services, we can forward your request to the appropriate contact.

Like many companies, we use cookies, pixels, and other tracking technologies to collect information about your interactions with our Website. We currently do not enable the use of third party pixel tags or cookies for advertising purposes, but may do so in the future. Please check back periodically if you would like to review and/or opt out of these future uses.

We may utilize the third party cookies for analytics purposes.

We maintain reasonable safeguards to protect against unauthorized access, use, modification, and disclosure of personal information in our custody and control. Despite our efforts, we cannot guarantee that unauthorized access or use will never occur. It is important that you take steps to keep your information safe and secure.

We will retain Customer information indefinitely in order to provide the Services, and End User personal information according to the terms of our Customers written agreements.

Some U.S. states have enacted comprehensive privacy laws. The California Consumer Privacy Act, as amended by the California Privacy Rights Act or "CPRA" (collectively, the "CCPA"), the Virginia Consumer Data Protection Act ("VCDPA"), the Colorado Privacy Act ("CPA"), the Connecticut Data Privacy Act ("CTDPA"), the Utah Consumer Privacy Act ("UCPA"), the Oregon Consumer Privacy Act ("OCPA"), the Texas Data Privacy and Security Act ("TDPSA"), the Florida Digital Bill of Rights ("FDBR"), the Montana Consumer Data Privacy Act ("MTCDPA"), the Iowa Consumer Data Protection Act ("IADPA"), the Delaware Personal Data Privacy Act ("DEPDPA"), the Nebraska Data Privacy Act ("NEDPA"), the New Hampshire Privacy Act ("NHPA"), the New Jersey Data Privacy Act ("NJDPA"), the Tennessee Information Protection Act ("TNIPA"), the Minnesota Consumer Data Privacy Act ("MNCDPA"), the Maryland Online Data Privacy Act ("MDODPA"), the Indiana Consumer Data Protection Act ("INCDPA"), the Kentucky Consumer Data Protection Act ("KYCDPA"), and the Rhode Island Data Transparency and Privacy Protection Act ("RIDTPPA") create additional privacy obligations for businesses.

We disclose the categories of personal information processed and disclosed for business purposes in the sections above. Elo does not 'sell' personal information nor 'share' personal information for cross-contextual behavioral or targeted advertising purposes. Elo advertisements are delivered anonymously to End Users.

In the course of providing our Services, we may collect certain personal information deemed 'sensitive' under US state laws in association with End Users chat communications. Any sensitive personal information collected is promptly deleted from our systems and is not used for profiling or advertising purposes.

Appeal:

You may exercise any privacy requests in the 'Privacy Choices' section above. If we deny your privacy request, you may appeal that decision by emailing us at [email protected]. We will respond to your appeal within a reasonable period of time and as required by law. If, after we have processed your appeal, you are still unsatisfied with our response, you may have the right to file a complaint with your state attorney general.

Authorized Agent:

If you are an authorized agent submitting a request on behalf of another person, you must provide a copy of a lawful power of attorney or written authorization signed by the consumer. If you make a request as an authorized agent, you may receive additional instructions. Depending on the type of request, we may contact you or the consumer as permitted by law.

Right to Non-Discrimination:

We do not discriminate against customers who exercise their privacy rights.

Controller/Business and Processor/Service Provider Designation:

We operate as a Controller (and a 'Business' under the CCPA) with respect to all Customer information collected through our Website. We operate as a 'Processor' (and a 'Service Provider' under the CCPA) with respect to End User information collected via our Services.

Residents of the ("UK") and European Economic Area ("EEA") are provided certain privacy rights under the UK and EU General Data Protection Regulations ("GDPR").

Legal Basis:

Under the GDPR, we process Personal Data under the following legal basis.

Controller and Processor Designation:

Under the GDPR, we are designated as a Controller with respect to Customer information collected through our Website. We operate as a Processor under the GDPR with respect to all End User information collected via our Services.

Cross-Border Data Transfers:

We may transfer to, and store the data we collect about you, in countries other than the country in which the data was originally collected, including the United States, Canada or other destinations outside the EEA and the UK. Those countries may not have equivalent data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in this Privacy Policy and applicable supplemental product privacy policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA or UK.

If you are located in the EEA or UK, we will only transfer your Personal Data if:

• The country to which the Personal Data will be transferred has been granted a European Commission adequacy decision; or
• We have put in place appropriate safeguards in respect of the transfer, for example we have entered into the Standard Contractual Clauses adopted by the European Commission and required additional safeguards with the recipient, or the recipient is a party to binding corporate rules approved by a supervisory authority.

Additional Rights for UK or EEA Residents:

In addition to the rights granted above, if you are a UK or EEA resident, the GDPR grants you the right to lodge a complaint against us with your local data protection authority. You can find your data protection authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

We do not intentionally collect any personal information from children under the age of 18. If you believe we have obtained personal information associated with children under the age of 18, please contact us at [email protected] and we will delete it.

The Website and Services may contain links to other websites or services. We do not exercise control over the information you provide, or is collected by these third party websites. We encourage you to read the privacy policies or statements of the other websites you visit.

We may update this Privacy Policy from time to time as we update or expand our Website and Services. If we make material changes, we will post the updated Privacy Policy on this page with a 'Last Updated' effective date of the revisions. We encourage you to look for updates and changes to this Privacy Policy by checking this page when you access our Website and Services.

If you have any questions about our privacy or security practices, or if you would like to submit a privacy request, you can contact us by email at [email protected] or at:

Adapt Research, Inc (dba 'Elo')
156 2nd St, San Francisco, CA 94105