This document (hereinafter referred to as the "Privacy Policy") outlines the types of personal data collected by the group of companies Adblidai (Adblidai LLC - headquartered at 8 The Green, Ste A, Dover city, Delaware state, USA; Adblidai OU - headquartered at Harju maakond, Tallinn, Lasnamae Iinnaosa, Vaike-Paala tn 2, 11415, Estonia; and Adblidai OU Filialas - headquartered at Perkunkiemio g. 13-91, Vilnius, Lithuania) (hereinafter referred to as the "Company"), the owner and developer of Eluter, through the website and its mobile application (collectively, the "Website"), how we use your data, to whom we disclose it, and your rights as a user regarding the use of your personal data and the exercise of data subjects' rights. We also describe the measures implemented to protect the security of the collected personal data and how users can contact us for information about our privacy practices.

By using the "Eluter" Website, you express, informed, voluntary, and unequivocal consent to include all your personal data provided through the Company's services in databases owned and managed by the Company, as well as the processing of all your personal data for the purposes described in the following sections of this document, subject to the General Terms and Conditions.


The Company declares that it will make every effort to avoid transferring collected data to countries that do not meet the required standards for the Protection of Personal Data and, if such transfers are carried out, will comply with and enforce the requirements set by the regulations of the Protection of Personal Data.


1.1 Personal information is information that can identify you. Therefore, we will only request the strictly necessary data to allow you to use the services the Company offers. For this purpose, the Company may request and process the following data, with the following list not being exhaustive or limited to: Contact Information (such as name, address, phone number, email); national identity document, passport, tax identification; Demographic data (such as nationality, date and place of birth, age, gender); Account information (such as username and passwords); Transactional data (such as your requests, operations, purchases, and sales through the Website; "selfie" photograph and a photograph of your national identity document and/or passport; social media information provided by you; politically exposed person status; credit information related to economic solvency assessments; statement of the origin and legality of funds; information collected for the purposes of fraud prevention, terrorism financing, and anti-money laundering; compliance with information regimes and means of payment; personal data and information collected through cookies and similar technologies and information that the user provides to us in relation to their inquiries or comments. We collect this data at the time of your registration, and we also collect personal information about you when you provide information directly or when you interact with us through the website.

1.2 You are not obligated to provide your Personal Data, but if you do not provide them or if you provide incomplete, false, or inaccurate data, the Company may not be able to provide its management services and you may not be able to use the Services available on the Website, or the possibility of doing so may be significantly hindered or obstructed.


The data we collect may be used for the following purposes: To identify you, so you can register, access, use, and navigate the Website, to communicate with you; send you promotional information and other communications; respond to your inquiries; personalize preferences and visits to the Website, offer content tailored to your interests and how you browse and interact with the Website; process your requests and transactions, compile and maintain a record of the operations you carry out on the Website and follow up on them, manage the Services, including payment processing service; to protect the rights, property, or safety of the Company, or any of our affiliates, business partners, or customers; to operate, evaluate, and improve our products and services; and to comply with applicable legal requirements, industry standards, contractual obligations, and our policies. Through the Website, we may also use third-party analytical services. Web analytics service providers who manage such services use technologies such as cookies, network server logs, and web beacons that help us analyze how users use the Company. Information collected through these means (including IP address) may be communicated to the providers of these analytical services, as well as to other third parties who will use the collected information, among other purposes, to evaluate the use of the Company. If we use your personal data in a way that is different from what is described above, we will specifically notify you at the time of collection.


The personal data we collect through the Company may only be disclosed to third parties as described in this Privacy Policy. Personal data collected through the Company may be disclosed to our subsidiaries, providers, and associated entities for the purposes described above. We will also communicate such personal data to providers who provide services on our behalf in accordance with our instructions and for the purposes detailed in this Policy (such as, but not limited to, payment processing companies; computer system providers; cloud service providers; general technology service providers; call centers or customer service centers; advertising or marketing agencies; data analysis agencies; insurance, legal, and/or financial consultants; agents and representatives, etc.). We do not authorize these service providers to disclose your personal data except for those uses that are strictly necessary for the provision of services on our behalf or to comply with legal obligations. The Company understands the importance of maintaining the confidentiality of all data that may be collected. Therefore, in order to ensure this confidentiality, the Company is committed to entering into confidentiality agreements with each of the parties that carry out the processing of personal data. The Company and those involved in any phase of personal data processing are required to maintain professional secrecy regarding them. Furthermore, we may disclose your personal data (i) to comply with applicable laws or regulations, judicial or administrative processes, or to protect and defend the rights or property of the Company (for example, we may share your Personal Data with any competent state authority or entity, governmental agency, or court, in cases where disclosure is necessary to comply with applicable law or regulation, to exercise, establish, or defend our rights, or to protect your vital interests or those of any other person, among others) (ii) to law enforcement and public authorities or other public officials when lawfully requested, (iii) when we believe such disclosure is necessary or advisable to prevent physical harm and/or economic loss, or (iv) in the context of an investigation into fraudulent or illegal activities, or activities presumed to be fraudulent or illegal. Furthermore, by using the Website, the user agrees and authorizes the transfer of their personal data in the event of the sale or transfer of all or part of our company or our assets (including cases of restructuring, dissolution, or liquidation).


Your personal data collected through the Company may be transferred for the purposes described above to our subsidiaries, associated entities, and service providers, whether in the United States or other countries. When we transfer your personal data to other countries, we will protect them as described in this document. Therefore, in accordance with applicable law, we have implemented measures that ensure an adequate level of protection for data transferred beyond their borders.


5.1 The Company may store information on your computer through the use of "cookies" to improve the quality of the visit to the Website. Cookies are small files that store information about the device of the person accessing a website, such as the IP address, date, and time of access, the IP address of the website you linked to the Services, the filename, or words you have searched for on a website, items and information about the browser and operating system used. They allow the entity that places the cookie on the user's device to recognize them on different websites, devices, and/or browsing sessions. Cookies serve many useful purposes, such as the following:

a) Cookies can remember the user's login credentials, so they don't have to enter those credentials every time they log in to the Website.

b) Cookies help the Company understand which parts of the Website are the most popular, as they help identify which pages and features visitors access and how long they stay on the pages. By studying this type of information, the Company can better tailor the Website and provide Users with a better experience.

c) Cookies help the Company understand which ads Users have seen, so they don't receive the same ad every time they access the Website.

e) Cookies help the Company provide Users with relevant content and advertisements by collecting information about their use of the Website and other websites and applications.

5.2) When you use a web browser to access the Website, you can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so you should review your browser's "Help" menu for information on how to change cookie preferences. Your device's operating system may contain additional controls for cookies.

5.3) However, please note that the Website may be designed to function through cookies and disabling cookies may affect your ability to use the Website or some parts of it.


The collected data will be kept strictly confidential and reserved. In this regard, all your data will be stored in a Company-owned database that is registered with the National Personal Data Protection Registry. To ensure the security of the personal data you provide to the Company, the same criteria and degree of diligence applied by the Company to safeguard its own information will be applied. In particular, we maintain administrative, technical, and physical security measures designed to protect the personal data you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, communication, or use. Therefore, to prevent unauthorized access, maintain data accuracy, and ensure the correct use of the personal data you provide, the Company has established certain physical, electronic, administrative, and security procedures to protect and secure the personal data we collect online. We safeguard your personal data in accordance with established security standards and procedures and continuously assess new technologies to optimize the protective layers of information. The Company guarantees that the internal processes of the databases comply with the legal security and confidentiality obligations imposed by the Personal Data Protection Regulations (in Argentina, Ley de Protección de Datos Personales Nº 25.326 No. 25.326, its regulatory decree No. 1558/2001, and the provisions issued by the Authority of Application, formerly the National Directorate of Personal Data Protection, currently the "Access to Public Information Agency"). However, by using the Website, the user acknowledges that the current technical means of providing security are not impregnable, and that even with all reasonable security precautions, it is possible to suffer manipulation, destruction, and/or loss of information. Finally, if you believe that your interaction with us is no longer secure, please immediately contact us about the issue using the communication channels of the Website.


The Company presumes the accuracy of all information provided by you. Therefore, the Company does not verify, nor assumes the obligation to verify, the accuracy, validity, sufficiency, and authenticity of the data you provide. You are responsible for keeping that information up to date at all times. You can access, modify, delete, and update your personal data at any time you wish by contacting us in accordance with the provisions of the following sections. You can access the information you provided to the Company free of charge at irregular intervals of less than six months unless there is a legitimate interest demonstrated for this purpose, as provided in the Personal Data Protection Regulations. If the data is incorrect and you wish to update and/or delete it, we will correct, update, and/or delete that information at your request at no cost. To exercise the rights of access, rectification, updating, or deletion, in accordance with the provisions of the Personal Data Protection Regulations, you must send an email to: indicating which right you wish to exercise and attaching a digitized copy of your national identity document and/or documentation that allows you to demonstrate your legal situation if you are acting on behalf of a company or a third party, as attached documentation. The information provided by you will be stored for the duration of the relationship with the Company and for a period of 10 (ten) years thereafter, solely for accounting and/or legal purposes.


The Company may contain links to other websites for your convenience and information. Those websites may be operated by companies that are not affiliated with us. The Company is not responsible for the security and privacy practices or the content of third-party websites linked to the Website. The Company does not control or guarantee the accuracy, relevance, suitability, or completeness of the information contained on such sites and is not responsible for the content or activities thereof. If you click on a link to an external site, you will leave the Website and be subject to the privacy and security policies of the owners/sponsors of the external site. The processing of Personal Data carried out by the third parties responsible for the aforementioned websites is not covered by this Privacy Policy, so it is recommended that you carefully read such privacy and security policies.


The Company reserves the right to make modifications or updates to this Privacy Policy without prior notice, to reflect changes in our practices regarding personal data, as required by the Personal Data Protection Regulations. In the event of substantial changes, you will be informed through the Website or email, at the Company's discretion, with the date of the last update of this Privacy Policy indicated at the bottom. Any modification to this Privacy Policy will be effective from the date of its publication on the Website.


You have the right to request and obtain information about your Personal Data. You also have the right to request rectification, updating, and, if applicable, deletion of your Personal Data.

If you wish to contact us to update your data or exercise your rights or have any questions about the scope of this policy and/or any concerns about the privacy and/or security of the information provided to the Company, you can contact us directly through the email address:

For users in Argentina, in compliance with Resolution No. 14/2018 of the Access to Public Information Agency, it is informed that the ACCESS TO PUBLIC INFORMATION AGENCY, in its capacity as the Control Authority of Law No. 25.326, has the authority to handle complaints and claims filed by those affected in their rights by non-compliance with current regulations on personal data protection.


This Privacy Policy is governed and interpreted in accordance with the laws of the State of Delaware, USA. Any dispute arising from it will be subject to the exclusive jurisdiction of the courts of that State.

In the event that any clause of this Privacy Policy is declared null and void, such nullity will not affect the validity of the remaining clauses, which will remain in full force and effect. For all purposes arising from this Policy, the Data Subject establishes their domicile at 8 The Green, Ste A, city of Dover, state of Delaware, USA.

This Privacy Policy was last updated on ________ of August 2023.