Data Processing, Confidentiality and Ownership Policy

All information, databases and personal data that the Client uploads, generates, imports or collects through their ELYA account belong to the Client or their respective owners, as applicable.

ELYA does not acquire ownership rights over the Client's databases, contacts or commercial information by virtue of storing or processing it as part of the service provision.

ELYA does not sell, market or use the Client's databases for its own commercial purposes unrelated to the provision of the contracted services.

ELYA acts as a technology provider and data processor for the information that the Client manages through the platform.

The processing of such information is carried out only to the extent necessary to provide, operate, configure, maintain, support and improve the contracted services, as well as to execute the functionalities and automations instructed or enabled by the Client.

The Client retains control over the information incorporated into the platform and is responsible for having the authorizations, consents, privacy notices and other legal bases necessary to collect and process the personal data of its users, customers, patients, prospects or contacts.

Information managed through ELYA will be treated confidentially.

As part of the service contract, ELYA assumes confidentiality obligations regarding the information to which it may have access during implementation, configuration, support or service provision.

The Client's information will not be disclosed to third parties for purposes other than service provision, except when there is Client authorization, it is necessary for the operation of the technology providers that are part of the service infrastructure, or there is a legal obligation that requires it.

The Client may determine which members of its organization have access to its account according to the functionalities and permissions available in the contracted service.

The Client is responsible for adequately managing its users, passwords, permissions and access mechanisms, as well as promptly requesting the removal or modification of access when a person is no longer authorized.

To provide its services, ELYA may use infrastructure, hosting, messaging, communications, storage, automation, artificial intelligence, payment processing and other technologies provided by third parties.

When such providers require processing information to provide their services, their participation will be limited to the functions necessary for ELYA's operation and will be subject to the privacy, security and data processing conditions applicable to each provider.

The use of such providers does not transfer ownership of the Client's databases to ELYA or to these providers.

The Client retains responsibility and control over requests received from the data subjects whose personal data it manages.

When technically necessary, ELYA may collaborate with the Client to address requests related to access, rectification, deletion, export or other actions on information stored in the platform, according to available functionalities and applicable legislation.

In the event of termination of the commercial relationship, the Client may request the delivery, export or deletion of its information according to the available technical capabilities, the conditions of the contracted service and the retention periods that may be necessary for legal, operational or security obligations.

Termination of the service does not grant ELYA any right to appropriate or commercially use the Client's databases.

We understand that some organizations operate under internal policies, contracts or specific regulations regarding information handling.

When the Client requires additional conditions of confidentiality, access control, information processing or contractual documentation, it may request a prior review with ELYA to determine the technical and operational requirements necessary before implementation.

Our principle is simple:

The Client's data belongs to the Client.

Our role is to provide the technology, configuration and strategy necessary for that information to be used in an organized and secure manner to achieve the Client's objectives, without appropriating it or using it for purposes unrelated to the contracted service.