Privacy Policy

Last Updated: December 18, 2025

Quick Summary (Full Policy below)

You must be eighteen (18) years or older to use elloo
We collect only the information reasonably necessary to operate the app and improve safety and performance (mobile number, profile, photos, analytics, technical data)
You can access, correct, or delete your data anytime
We do not sell your personal data as defined under applicable data protection laws
You can opt out of personalized ads and tracking
We scan messages and photos with AI for safety and security — never for ads
Use the app at your own risk—AI moderation is best-effort and cannot detect all violations

This summary is for convenience only. The full Privacy Policy below controls in case of any inconsistency.

1. Introduction

elloo app ("we," "us," "our") operates the elloo mobile application. This Privacy Policy explains how we collect, use, and safeguard your information. By using the app, you consent to the practices described here.

Our Community Guidelines describe expected behavior on the platform. They are separate from this Privacy Policy and do not modify how we collect or process your data. You can access the Community Guidelines in the app under My Account > Legal > Community Guidelines.

Territorial Scope: The app is intended for users located in the Philippines. We do not target or market the app to individuals outside the Philippines. Users outside the Philippines access the app voluntarily and acknowledge that Philippine data protection laws apply.

2. Information We Collect

Personal Information You Provide:

Mobile phone number (for OTP verification)
Date of birth (to verify you are eighteen (18) years or older)
Username, age, gender
Sexual orientation (optional - only if you choose to provide it for matching functionality)
Photos you upload
Preferences you set (age range, gender preferences, etc.)

Sensitive Personal Information: Sexual orientation is considered sensitive personal information under the Data Privacy Act. We collect and process it only if you choose to provide it, solely to enable matching functionality and improve your experience on the app. Providing your sexual orientation is entirely optional—you may use the app without disclosing this information, though it may limit matching accuracy.

Automatically Generated Data:

Unique QR code for your profile (used to share your profile with others for adding to favorites). Your QR code contains only a profile identifier and does not include personal information such as your name, phone number, location, or photos. You can share your QR code with other users to allow them to add you to their favorites. Your QR code can be shared by showing your screen or by sharing an image.

Device Permissions:

We request the following permissions to enable app features:

Camera: For profile photos, conversation photos, video calls, and scanning QR codes to add users to favorites (optional)
Photo Library: To upload photos from your device and to scan QR code images from your gallery (optional)
Microphone: For voice and video calls with other users (optional)
Location: To show distance to other users and enable location-based matching (optional - can enter city manually)
Notifications: For alerts about new messages, new matches, favorites available, and account updates (optional - disable in Account Settings)

You can manage these permissions in your device settings. Denying permissions limits certain features but won't prevent core app use.

Location Data: You may specify your location by either entering a city name manually or selecting 'My location', which collects precise GPS location from your device. You can control location permissions through your device settings at any time.

Background Location Tracking: The app does not track your location in the background. Location is only collected when you actively choose the 'My location' option or when the app is open.

User Content:

Messages you send to other users
Photos you share on your profile or in conversations
Video call metadata (call initiation time, call duration, and connection type only)
All content is scanned by automated AI moderation for safety

Video and Voice Calls: Video calls and voice calls are never recorded, stored, or monitored by elloo. Video and voice calls use peer-to-peer connections when supported by both devices and networks. In some cases (such as weak networks or device limitations), relay servers may be used to establish the connection, but call content is never stored on relay servers or our systems. We only retain metadata (call initiation time, call duration, and connection type) for service quality and safety purposes. Metadata does not include call content or location information. We do not store or log IP addresses associated with call content. We cannot provide recordings or transcripts of calls.

Technical Information:

IP address
Device details (model, operating system version)
Operating system type
Usage logs (features used, time spent)
Crash reports and error logs

Third-Party Login Information: If you choose to log in via Google or Facebook, we receive basic profile information (such as name and email address) based on the permissions you grant to those services.

Data We Do Not Collect: We do not collect biometric data, financial information (payment is handled by Apple/Google), or government-issued identification numbers.

Sensitive Personal Information Shared in Conversations: Information you voluntarily share in conversations with other users may include sensitive personal data. You are responsible for what information you choose to disclose. Follow our safety guidelines and exercise caution when sharing personal information. By uploading content or using messaging features, you consent to the processing of any sensitive personal information you voluntarily share.

Screenshots and Recordings: Other users may capture screenshots or recordings of your content. We cannot prevent this and are not responsible for how others use content you share. We are not responsible for any use, misuse, storage, or distribution of your content by other users or third parties.

Website Cookies (If You Visit Our Website): If you visit our website or landing pages, we may use cookies and similar tracking technologies for analytics and performance measurement. You can control cookies through your browser settings.

3. Data Minimization

We only collect the minimum personal data reasonably necessary to operate and improve the app. We do not collect data that is not relevant to the functioning or safety of the service. We do not collect personal data for purposes that are not clearly defined or disclosed in this Privacy Policy. All data collection serves a specific, legitimate purpose as outlined in this Privacy Policy.

4. Definition of Service Providers

"Service Providers" refers to third-party companies or individuals that provide operational, technical, or administrative services that enable the functioning, improvement, security, or support of the elloo app. These include, but are not limited to, cloud hosting providers, analytics providers, payment processors, SMS delivery partners, advertising partners, customer support tools, AI moderation technologies, and other vendors who process personal data strictly on our behalf.

Service Providers may only access personal data as necessary to perform their assigned functions and are contractually obligated to maintain confidentiality, implement adequate security measures, and comply with applicable data protection laws. They are prohibited from using your data for their own marketing, advertising, or unrelated purposes.

5. How We Use Your Information

We use your data to:

Verify you meet the minimum age requirement of eighteen (18) years old
Authenticate your account using OTP codes sent to your mobile number
Match you with other users based on location and preferences
Facilitate social login and account creation through third-party providers
Moderate content and enforce safety rules through automated AI systems that scan for prohibited content such as nudity, hate speech, and scams
Personalize your experience and show advertisements (personalized ads only if you grant tracking permission)
Communicate with you about your account and the service
Comply with legal reporting obligations (e.g., CSAM reporting to authorities)
Prevent fraud, misuse, and unauthorized access
Provide and improve App functionality
Use aggregated and anonymized data to improve the app, develop new features, and analyze usage trends

Data Accuracy: We do not guarantee the accuracy of user-provided data, including age, identity, location, photos, or preferences.

No Guarantee of Content Detection: We do not guarantee that harmful, offensive, or prohibited content will be detected, removed, or prevented. While we employ automated systems and moderation efforts, we cannot ensure all violations will be identified or addressed. We do not assume any duty to monitor user content.

6. Automated Processing and AI Moderation

Automated Processing: We conduct limited automated processing (also known as "profiling") for the purpose of safety moderation, fraud detection, and security. AI moderation may contribute to automated decisions such as temporary restrictions or content warnings. Permanent suspensions always include human review.

What Our AI Systems Do:

Scan text messages and photos for policy violations including nudity, hate speech, harassment, scams, and prohibited activities
Flag potentially harmful content for review
Detect patterns of abuse or fraudulent behavior
Help protect users from harmful interactions

Limitations of AI Moderation:

AI moderation is provided on a best-effort, automated basis. It may not always be accurate and is not guaranteed to identify, prevent, or stop any behavior. Automated systems may occasionally produce false positives (flagging legitimate content) or false negatives (missing violations). We do not warrant that automated systems will identify all prohibited content or prevent harm. Content flagged by automated systems may be temporarily retained for human review, fraud prevention, and compliance with safety obligations. Human review is available for all automated decisions affecting your account. Automated moderation tools operate on a best-effort basis and do not guarantee accuracy, completeness, or prevention of harm.

Data Usage: We never use AI moderation for advertising purposes. Your private messages and photos are scanned only for safety, never to build ad profiles or target ads. AI moderation tools do not use your data for training generalized AI models unless required for safety, quality control, or to comply with legal obligations.

Third-Party AI Tools: Our moderation system may use third-party AI tools to detect policy violations. These tools process content solely for safety and moderation purposes and are bound by contractual obligations to protect your data.

Data Privacy Impact Assessment:

In accordance with the Philippine Data Privacy Act and NPC Circular 2019-01, we maintain a Data Privacy Impact Assessment (DPIA) for our high-risk processing activities, including AI content moderation and processing of sensitive personal information. A summary of our DPIA findings is available upon request by contacting datarequest@elloo.app.

No Duty to Monitor: Although we use automated tools and limited human moderation, we do not have a general obligation or duty to monitor all user activity. Automated systems operate solely to assist with safety and do not guarantee any outcome, level of protection, or response.

Anti-Discrimination in Automated Processing: Our automated systems do not make decisions based on protected characteristics such as race, ethnicity, religion, disability, sexual orientation, or gender identity.

With Other Users: Your username, profile information (age, sexual orientation, photos), available time, interests, and distance away, etc. are shown to other users in search results and to users you interact with. Other users cannot see your mobile number, date of birth, or precise location unless you choose to share it in conversation.

With Service Providers: We share data with third-party service providers who help us operate the app, including:

MongoDB Atlas: Cloud database hosting for user profiles, messages, and app data
Amazon Web Services (AWS): Cloud infrastructure for running app services and secure storage for media files (such as profile photos and images shared in conversations)
ClickSend: SMS delivery for OTP verification and email delivery for account notifications
Google Analytics (Mobile App Analytics SDK): App usage analytics and performance monitoring
Google AdMob (Google LLC): Displays personalized and non-personalized ads based on user preferences (device identifiers and usage data, only if you grant tracking permission)
Meta Audience Network (Meta Platforms, Inc.): Delivers interstitial video ads through AdMob mediation (device identifiers and usage data, only if you grant tracking permission)

We have contracts with all service providers requiring them to protect your data and use it only for the specified purposes. Service providers are prohibited from using your data for their own marketing or advertising purposes.

For Legal Reasons: We may disclose your data if required by Philippine law, court order, or government request.

For Safety: We report necessary information to Philippine authorities (such as the NBI Cybercrime Division) in cases involving Child Sexual Abuse Material (CSAM), credible threats of violence, or other serious criminal activity.

Cross-Border Data Transfer: Your information may be transferred to and processed on servers located outside the Philippines. The following service providers process data outside the Philippines: MongoDB Atlas (cloud database hosting), Amazon Web Services (cloud infrastructure and storage), ClickSend (SMS and email delivery), Google LLC (analytics and advertising), and Meta Platforms, Inc. (advertising services via AdMob mediation). We ensure these transfers comply with the Data Privacy Act's requirements and provide a level of protection comparable to the Philippine Data Privacy Act through:

Standard contractual clauses with service providers
Security measures to protect data in transit and at rest
Verification that receiving countries provide adequate data protection

By using the app, you consent to the transfer, processing, and storage of your information outside the Philippines.

We Do Not Sell or Rent Your Personal Data: We do not sell your personal data as defined under applicable data protection laws or your content to third parties. We never share your private messages or photos with advertisers or data brokers. Sharing limited data with advertising partners for ad delivery and measurement is not considered selling under the Philippine Data Privacy Act or other applicable data protection laws. Any use of your data is strictly limited to providing, operating, and improving the app as described in this Privacy Policy.

8. Legal Basis for Processing (Philippine Data Privacy Act)

Under the Philippine Data Privacy Act of 2012 (RA 10173), we process your data based on:

Consent: Provided by using the App and agreeing to this Privacy Policy.
Legitimate Interests: We process data for our legitimate interests in maintaining platform safety, preventing fraud, protecting users from harmful content, operating the app efficiently, and improving our services, provided such processing does not override your fundamental rights and freedoms. AI moderation serves our legitimate interest in creating a safe environment while respecting user privacy through encryption and limited retention.
Legal Obligation: To comply with Philippine law, including mandatory reporting of CSAM to authorities.

9. Data Retention

While Your Account Is Active: We retain your data for as long as your account remains active and you continue using the app.

After Account Deletion: If you delete your account, your personal data is removed from our active systems within ninety (90) days. Some data may be retained longer for legal, safety, or compliance reasons as specified below.

Specific Retention Periods:

Profile data (username, age, photos): Deleted within ninety (90) days of account deletion
QR codes: Deleted within ninety (90) days of account deletion
Messages: Permanently deleted when either user deletes the conversation or their account
Photos in conversations: Removed within thirty (30) days of deletion from active systems
Moderation records (reports, violations, temporary restrictions, permanent suspensions): Retained for three (3) years for safety and legal compliance, based on statute of limitations for civil claims, fraud prevention, and protection against false claims of wrongful account actions
CSAM reports and evidence: Retained indefinitely for legal compliance and law enforcement purposes
Payment/subscription records: Retained by Apple/Google per their policies; we do not store payment information
Technical logs, crash logs, and device information: Retained for up to twelve (12) months, unless needed longer for security, fraud prevention, or diagnostics
Encrypted backups: Backups containing deleted data are purged within thirty (30) additional days after deletion from active systems
Aggregated/anonymized analytics: May be retained indefinitely (cannot identify individuals)

Legal and Safety Retention: Even after account deletion, we retain only the minimum data necessary for up to three (3) years when necessary based strictly on legal obligations, fraud prevention, and safety requirements to:

Comply with legal obligations
Resolve disputes or enforce our Terms
Prevent fraud and abuse
Protect the safety of users

10. Your Rights Under the Data Privacy Act

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights:

Right to Access: You can request a copy of the personal data we hold about you.
Right to Correction: You can request that we correct inaccurate or incomplete data.
Right to Deletion (Right to be Forgotten): You can request deletion of your personal data, subject to legal retention requirements.
Right to Object: You can object to certain types of processing, such as processing for direct marketing.
Right to Data Portability: You can request your data in a structured, commonly used, machine-readable format to transfer to another service.
Right to Withdraw Consent: You can withdraw your consent at any time (though this may affect your ability to use the app).
Right to File a Complaint: You can file a complaint with the National Privacy Commission if you believe your rights have been violated.

How to Exercise Your Rights:

Send an email to: datarequest@elloo.app
Include in your email:

Your username
Your registered mobile number (for identity verification)
The specific right you wish to exercise (access, correction, deletion, etc.)
Any relevant details about your request

Verification: We may request additional information to verify your identity before processing your request. This protects your data from unauthorized access. Verification typically requires confirmation via OTP sent to your registered mobile number.

Response Time: We will respond to your request within thirty (30) calendar days. For complex requests, we may extend this to sixty (60) days and will notify you if an extension is needed.

Fees: No fees apply for reasonable requests. We may charge a reasonable fee for manifestly unfounded, excessive, or repetitive requests, and will inform you before processing.

Data Protection Officer:

For privacy-related questions contact our Data Protection Officer (DPO):
Acting Data Protection Officer
Email: datarequest@elloo.app

Right to Complain:

If you believe we have violated your data privacy rights, you may file a complaint with:

National Privacy Commission (NPC)
Website: https://privacy.gov.ph
Email: complaints@privacy.gov.ph

11. Tracking and Advertising

We show advertisements to all users. If you grant tracking permission, our advertising partners may show you personalized ads based on your interests and activity.

We do not sell or rent your personal data, and we never share your private messages or photos with advertisers. We do not track you across apps and websites unless you grant permission.

What We Track (Only With Your Permission):

If you grant tracking permission (iOS) or do not opt out (Android), we may process:

Device identifiers (IDFA on iOS, Advertising ID on Android)
Your in-app activity (e.g., features used, ad views, interactions)
Attribution data for measuring ad performance and app installations

This information helps us show more relevant ads. The device identifiers and usage data shared with advertising partners cannot reasonably be used to identify you personally without additional information that is not shared. We implement technical measures to prevent re-identification, including data aggregation and anonymization where feasible. Core app features remain fully available even if you decline tracking.

If You Decline Tracking:

If you deny permission (iOS) or opt out (Android):

You will still see ads
Ads will be non-personalized
We cannot track your activity across other apps or websites
We cannot link your activity with third-party data
Some platform-level advertising technologies may still process limited data as permitted by your device provider

Core features of the app remain the same.

How to Change Your Tracking Choices:

iOS - Apple App Tracking Transparency (ATT):

To change your permission at any time:

Open Settings
Tap Privacy & Security
Select Tracking
Find elloo
Toggle Allow Tracking on or off

Android - Google Advertising Controls:

To opt out of personalized ads:

Open Settings
Go to Google
Tap Ads
Enable Opt out of Ads Personalization

To reset or delete your Advertising ID (Android 12+):

Open Settings
Tap Privacy
Select Ads
Choose Delete advertising ID

Advertising Partners:

We work with advertising partners only for ad delivery and measurement:

Google AdMob (Google LLC): Displays personalized and non-personalized ads. Personalized ads only if you grant tracking permission; non-personalized ads shown if tracking denied.
Meta Audience Network (Meta Platforms, Inc.): Delivers interstitial video ads through AdMob mediation. Only active if you grant tracking permission.

These partners must comply with strict privacy and security obligations. They may not use your personal data for purposes unrelated to ad delivery, measurement, or security.

No Combination With Data Brokers:

We do not:

Share your personal data with data brokers
Sell or rent your personal data
Combine your personal data with external third-party data (unless you grant tracking permission for basic ad attribution)

12. Data Security and Breach Notification

Security Measures We Implement:

Encryption: All data is encrypted in transit (using TLS/SSL) and at rest (using AES-256 encryption)
Access Controls: Only authorized personnel have access to user data, with role-based permissions
Network Security: Firewalls, intrusion detection systems, and regular security audits
Secure Backups: Encrypted backups stored in geographically distributed locations
Vendor Security: All service providers must meet our security requirements and sign data protection agreements

Despite our best efforts, no system is one hundred percent (100%) secure, and we cannot guarantee absolute security. You acknowledge that you provide your information at your own risk.

Data Breach Notification:

If we discover a data breach that poses a risk to your rights and freedoms or if the breach is likely to harm your rights and freedoms, we will:

Within Seventy-Two (72) Hours of Discovery:

Notify the National Privacy Commission (NPC) as required by the Data Privacy Act
Begin investigation to determine the scope, affected data, and impact of the breach

Notification to You:

Send email notification to your registered email address (if you provided one)
Display in-app notification when you next log in

Information We Will Provide:

Nature and description of the breach
Categories and approximate number of affected users and data records
Type of personal data affected (e.g., mobile numbers, photos, messages)
Potential consequences and risks to you
Assessment of possible harm and recommended protective measures
Measures we have taken and are taking to address the breach
Measures we recommend you take to protect yourself
Contact for security concerns: security@elloo.app

What You Should Do If Notified:

Change your password immediately if instructed
Monitor your account for suspicious activity
Report any unauthorized access to us immediately
Follow any additional instructions we provide in the notification

13. Account Deletion

You can permanently delete your account at any time. This action is irreversible.

How to Delete Your Account:

Open the elloo app
Go to: My Account > Delete Account
Read the warning and confirm your choice
Your account will be scheduled for immediate deletion

What Happens When You Delete Your Account:

Your profile becomes invisible to all users immediately
You can no longer log in or access the app
Any unused Elloo Credits expire upon account deletion
Premium subscription benefits remain active until the end of your current paid period
Your username will be released and may become available to other users
All personal data will be removed from active systems within ninety (90) days
Some information may remain in automatic system backups for up to thirty (30) additional days
Encrypted backups will be purged within thirty (30) additional days after deletion from active systems
After backup purging is completed, no copies of your personal data remain in our systems
Some data is retained for up to three (3) years for legal, safety, or compliance reasons (see Section 9)

Cannot Be Undone: Account deletion is permanent. If you wish to use elloo again, you will need to create a new account.

14. Children's Privacy

elloo is intended only for users who are eighteen (18) years of age or older. We do not knowingly collect personal information from anyone under eighteen (18).

If We Discover a User Under 18:

The account will be deleted immediately upon discovery
All associated personal data will be removed from our systems
We will take steps to notify parents or legal guardians if possible and appropriate

For Parents and Guardians:

If you believe your child under eighteen (18) has created an account on elloo, please contact us immediately at support@elloo.app with subject line "Minor Account Report". Include:

Your child's username (if known)
Your child's phone number used for registration (if known)
Your contact information

We will investigate and, if the account can be identified, take immediate action to remove the account and delete all associated data.

15. Severability

If any provision of this Privacy Policy is found to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

How We Notify You of Changes:

The "Last Updated" date at the top of this policy will be revised
For material changes, we will provide at least thirty (30) days' notice before the changes take effect through in-app notification when you next log in

What Constitutes Material Changes:

Changes to the purposes for which we collect or process data
Collection of new categories of personal data
Sharing data with new categories of third parties
Significant changes to data retention periods
Changes that reduce your rights or protections

Your Choices After Changes:

Review the updated Privacy Policy
Continue using the app (which constitutes acceptance of the changes)
Delete your account if you do not agree with the changes

Contact Us

For inquiries and requests, please use the appropriate contact email below:

General inquiries: contact@elloo.app
Customer support: support@elloo.app
Moderation appeals: appeal@elloo.app
Security issues: security@elloo.app
Legal matters: legal@elloo.app
Data privacy requests: datarequest@elloo.app