Privacy Policy

1. Overview

This Privacy Policy describes how RORO & LILY TRADING LLC, doing business as Elever Labs ("we," "us," or "our"), collects, uses, stores, and shares information about you when you use our website at eleverlabs.com and any mobile applications we publish (collectively, the "Services").

This website is owned and operated by RORO & LILY TRADING LLC, a company registered in the State of Wyoming, United States of America, with a principal place of business at 30 N Gould St, Ste 37783, Sheridan, WY 82801-6317.

By accessing or using our Services, you agree to the collection and use of information as described in this policy. If you do not agree with any part of this policy, please discontinue use of our Services.

2. Information We Collect

2.1 Information You Provide Directly

When you interact with our Services, you may provide:

• Account information — name, email address, username, and password when creating an account.
• Profile data — age, gender, profile photo, and personal preferences you choose to share.
• Health & fitness data — activity logs, workout records, nutrition entries, sleep data, mood check-ins, and goal progress you manually input.
• Communications — messages, feedback, support requests, or survey responses you send us.
• Payment information — billing details processed through Apple App Store or Google Play; we do not store full payment card numbers on our servers.

2.2 Information Collected Automatically

When you use our Services, we automatically collect certain technical information:

• Device information — device type, operating system version, unique device identifiers, and mobile network information.
• Usage data — features accessed, screens viewed, buttons tapped, session duration, and in-app events.
• Log data — IP address, browser type (for web), access times, pages visited, and crash reports.
• Location data — approximate location derived from IP address; precise GPS location only if you grant explicit permission for features that require it (e.g., outdoor activity tracking).
• Cookies & similar technologies — on our website we use essential cookies for session management and analytics cookies to understand aggregate usage patterns.

2.3 Information from Third Parties

We may receive information about you from:

• Apple HealthKit / Google Fit — only with your explicit consent and only the categories you authorize.
• Social login providers — if you choose to sign in with Apple, Google, or another provider, we receive a limited profile (name, email) from that provider.
• Analytics partners — aggregated, de-identified usage statistics to help us improve our apps.

3. Health & Fitness Data

Some of our applications are designed to help you track and improve your physical and mental wellbeing. In that context, we may collect or process data such as:

• Physical activity (steps, workouts, calories, distance)
• Body metrics (weight, height, BMI) — only when manually entered by you
• Sleep patterns and duration
• Mindfulness and meditation session records
• Nutrition logs and water intake
• Mood and mental wellness check-ins
• Heart rate and other biometric data read from Apple HealthKit or Google Fit (with your permission)

How We Handle Health Data

• Health data is used solely to provide and personalize the features you use. It is never used for advertising targeting.
• We do not share your health or fitness data with advertisers, data brokers, or any third party for commercial purposes.
• Health data accessed through Apple HealthKit will not be used for any purpose other than providing health and fitness features within the app.
• You can delete your health data at any time from within the app or by contacting us.
• Health data is encrypted both in transit (TLS 1.2+) and at rest (AES-256).

4. How We Use Your Information

We use the information we collect to:

• Provide and operate our Services, including personalizing your experience and syncing your data across devices.
• Improve and develop new features based on how users interact with our apps.
• Communicate with you — send account-related notifications, respond to support requests, and (with your consent) send product updates.
• Ensure safety and security — detect fraud, abuse, or violations of our Terms of Service.
• Comply with legal obligations — respond to lawful requests from government authorities where required.
• Analytics — understand aggregate usage patterns to make better product decisions (using anonymized or de-identified data wherever possible).

We rely on the following legal bases for processing (where applicable under GDPR): performance of a contract (to provide the Services you requested), legitimate interests (to improve our products and prevent fraud), compliance with legal obligations, and your explicit consent (for health data and optional communications).

5. Sharing & Disclosure

We do not sell, rent, or trade your personal information. We share information only in the following limited circumstances:

5.1 Service Providers

We work with trusted third-party companies that process data on our behalf, including cloud hosting providers, analytics platforms, and customer support tools. These partners are contractually bound to use your information only as directed by us and to maintain appropriate security standards.

5.2 App Store Platforms

When you download our apps through the Apple App Store or Google Play Store, those platforms collect certain data according to their own privacy policies. We encourage you to review Apple's and Google's privacy policies separately.

5.3 Legal Requirements

We may disclose your information if required to do so by law or in good-faith belief that such action is necessary to: comply with a legal obligation, protect and defend our rights or property, prevent fraud or illegal activity, or protect the safety of our users or the public.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

5.5 With Your Consent

We may share your information for any other purpose with your explicit prior consent.

6. Data Retention

We retain your personal information for as long as your account is active or as needed to provide our Services. Specifically:

• Account data — retained until you delete your account, after which it is deleted within 30 days.
• Health & activity logs — retained for the duration of your account; you can delete individual entries at any time.
• Usage and analytics data — retained in anonymized form for up to 24 months.
• Support communications — retained for up to 3 years for quality assurance purposes.
• Legal and compliance records — retained for the period required by applicable law.

To request deletion of your account and associated data, contact us at developer@eleverlabs.com.

7. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

• Access — request a copy of the personal data we hold about you.
• Correction — request that we correct inaccurate or incomplete data.
• Deletion — request that we delete your personal data ("right to be forgotten").
• Portability — request a machine-readable export of your data.
• Objection — object to processing based on legitimate interests.
• Restriction — request that we restrict processing of your data in certain circumstances.
• Withdraw consent — where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at developer@eleverlabs.com. We will respond within 30 days. We may need to verify your identity before fulfilling a request.

In-App Controls

Our apps provide in-app settings that allow you to manage your data directly, including the ability to export, edit, or delete your health and activity records without contacting us.

8. Children's Privacy

If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact us immediately at developer@eleverlabs.com. We will take prompt steps to delete such information from our systems.

We comply with the Children's Online Privacy Protection Act (COPPA) and do not knowingly market to or collect data from children under 13.

9. Security

We implement industry-standard technical and organizational measures to protect your information against unauthorized access, disclosure, alteration, or destruction:

• All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher.
• Personal data stored on our servers is encrypted at rest using AES-256.
• Access to personal data is restricted to authorized personnel only, on a need-to-know basis.
• We conduct regular security reviews and vulnerability assessments.
• We maintain an incident response plan and will notify affected users in the event of a data breach as required by applicable law.

While we take strong precautions, no method of transmission over the internet or electronic storage is 100% secure. We encourage you to use a strong, unique password for your account and to enable two-factor authentication where available.

10. Third-Party Services

Our apps and website may integrate with or link to third-party services. This policy does not cover the privacy practices of those third parties. We encourage you to review their policies:

• Apple HealthKit — governed by Apple's Privacy Policy.
• Google Fit / Google Health Connect — governed by Google's Privacy Policy.
• Apple App Store — governed by Apple's Privacy Policy.
• Google Play Store — governed by Google's Privacy Policy.
• Analytics providers — we use privacy-respecting analytics tools configured to anonymize IP addresses and avoid cross-site tracking.

We are not responsible for the content or privacy practices of any third-party service.

11. International Data Transfers

Our Services are operated in the United States. If you are located outside the United States, please be aware that information you provide may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated.

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we ensure that any transfer of personal data to countries outside your region is done with appropriate safeguards in place (such as Standard Contractual Clauses approved by the European Commission), in compliance with applicable data protection laws including the GDPR.

12. Additional Rights for California Residents

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with specific rights regarding your personal information:

• Right to Know — you may request disclosure of the categories and specific pieces of personal information we have collected about you, and the purposes for collection.
• Right to Delete — you may request deletion of personal information we have collected, subject to certain exceptions.
• Right to Correct — you may request correction of inaccurate personal information.
• Right to Opt-Out of Sale or Sharing — we do not sell or share personal information for cross-context behavioral advertising.
• Right to Non-Discrimination — we will not discriminate against you for exercising your CCPA/CPRA rights.

To submit a verifiable consumer request, contact us at developer@eleverlabs.com with the subject line "California Privacy Request." We will respond within 45 days.

13. 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 for other operational reasons. When we make material changes, we will:

• Update the "Last updated" date at the top of this page.
• Notify registered users via email or an in-app notification at least 14 days before the changes take effect.
• Where required by law, obtain your consent before applying the changes.

Your continued use of our Services after any changes become effective constitutes your acceptance of the revised policy. We encourage you to review this page periodically.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We aim to respond to all privacy-related inquiries within 30 days. For urgent data breach or security concerns, please mark your email subject "URGENT: Privacy".