Privacy Policy

Eloria processes personal data in two distinct capacities, and the rights you can exercise with us depend on which one applies to you.

• As a controller, for the data of the property managers and administrators who hold an Eloria account: account and profile information, authentication data, billing information, and website visitor data. We decide the purposes of this processing, and this Privacy Policy governs it.
• As a processor, for the data of residents, owners, tenants, board members, vendors, contractors and workers of the buildings our customers manage. Here the customer — the property manager, condominium or homeowners association — is the controller. They decide what is collected and why; we process it only on their instructions, to provide the service.

If you are a resident, owner, tenant, vendor or worker and want to access, correct or delete your data, the controller is the administration of your building, and requests are best addressed to them. You may also contact us using the details in Section 9: we will forward your request to the relevant customer and assist them in answering it within the time limits applicable to them.

In Colombia, this relationship is governed by Ley Estatutaria 1581 de 2012 and Decreto 1377 de 2013. Our obligations as a processor (encargado del tratamiento) are set out in the data processing annex to our Terms and Conditions for customers domiciled in Colombia.

We may collect the following categories of information:

• Account and profile information, such as your name and email address.
• Contact information shared via WhatsApp, including your phone number and message content.
• Property and portfolio data you provide while using the service.
• Usage data such as timestamps, feature interactions, and session activity.
• Billing and subscription information required to process payments.

When residents, vendors or workers communicate with the assistant, we store their name, phone number or email address, the unit or building they are associated with, and the content of their messages, on behalf of the customer who operates that channel.

Eloria offers Google Sign-In so property managers can authenticate to the Eloria web application. When you choose to sign in with Google, we access Google user data only as permitted by the Google OAuth scopes you approve.

Google user data we collect:

• Your Google account email address.
• Your Google profile name.
• Your Google account identifier (OpenID subject), used to authenticate your account.

If you connect Google Drive, Eloria may access Google Drive files and folders that you explicitly select in the Eloria Settings page (via Google's file picker), as permitted by the Google Drive permission you authorize. Eloria does not request access to your entire Google Drive. Access is limited to the files and folders you choose, and to files within folders you select.

Google Drive data is used solely to provide the features you request, such as retrieving building documents (for example, common charges statements), storing copies of those documents within Eloria's infrastructure, and making them available to authorized users through the Eloria platform and supported communication channels (such as WhatsApp).

We do not use Google Drive data for advertising, profiling, training generalized AI models, or any purpose unrelated to providing the requested functionality.

How we use Google user data:

• To authenticate you and provide access to the Eloria web application.
• To create or link your Eloria user account to your property management profile.
• To maintain your session and secure access to your account.
• To provide and improve the core functionality of the Eloria service.
• To access Google Drive files and folders you select in Settings, retrieve building-related documents, store copies of those documents within Eloria's infrastructure, and provide them to authorized users through the Eloria platform and supported communication channels.

We do not use Google user data, including Google Drive data, for advertising, interest-based advertising, retargeting, creditworthiness determination, lending, creating databases for resale, training generalized AI models, profiling, or any purpose unrelated to providing or improving Eloria's user-facing features.

We do not sell Google user data.

Eloria's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

Google user data is disclosed only to service providers acting on our behalf to operate Eloria (such as cloud hosting providers), or when required by law. We do not share Google user data with third parties for their own marketing, advertising, analytics, or independent business purposes.

We use the information we collect to:

• Provide, operate, and maintain the Eloria service.
• Respond to resident and vendor communications on your behalf, according to your settings.
• Process subscriptions and manage billing.
• Provide customer support and respond to inquiries.
• Improve reliability, security, and product functionality.
• Comply with applicable legal obligations.

We do not sell, rent, or trade Google user data to third parties.

We do not transfer or disclose Google user data to third parties for targeted advertising, selling to data brokers, providing to information resellers, determining creditworthiness, lending purposes, or serving user-facing advertisements.

We may share information, including Google user data, only in the following limited circumstances and only to the extent necessary to provide or improve the Eloria service:

• Infrastructure and hosting providers that store and process data on our behalf under contractual confidentiality and security obligations (for example, cloud hosting and database providers).
• Payment processors that handle subscription billing when you subscribe to Eloria. These providers receive billing-related information such as your email address and payment details, not your Google authentication tokens.
• Communication providers used to deliver service-related messages when required to operate the platform.
• Artificial intelligence providers that process message content to generate replies, classifications and summaries. These providers act on our instructions and are not permitted to use the content to train generalized models.
• Professional advisors or authorities when required by law, regulation, legal process, or to protect the rights, safety, and security of Eloria, our users, or others.

Any service providers that receive Google user data on our behalf are permitted to use it only to perform services for Eloria and are contractually required to protect it.

If Eloria is involved in a merger, acquisition, or sale of assets, user information may be transferred as part of that transaction. We will notify you of any such change where required by law.

Eloria is operated by Tempo Software SAS, a company incorporated in Uruguay. Our infrastructure and that of our service providers is located in the United States, so personal data processed through the service is stored and processed outside your country of residence.

Where we act as a processor on behalf of a customer, this operation is carried out under the data processing agreement we enter into with that customer, which sets out the purpose and scope of the processing, our obligations towards the controller and towards data subjects, and the confidentiality and security measures we apply.

For customers domiciled in Colombia, that agreement is the data processing annex to our Terms and Conditions, which constitutes the transmission contract required by article 25 of Decreto 1377 de 2013.

We implement administrative, technical, and organizational safeguards designed to protect personal information, including Google user data, against unauthorized access, disclosure, alteration, or destruction.

Google user data is treated as sensitive information and is protected using appropriate technical and organizational security measures.

Our security measures include:

• Encryption of data in transit using industry-standard TLS/HTTPS.
• Encryption of data at rest within our cloud infrastructure where supported.
• Access controls limiting employee and system access to personal data on a need-to-know basis.
• Authentication controls, including secure token-based session management for signed-in users.
• Monitoring and logging of infrastructure activity to detect and respond to security incidents.
• Secure storage of OAuth access tokens and credentials with restricted system access.

No method of transmission or storage is completely secure. While we work to protect your information, we cannot guarantee absolute security.

We retain Google user data and other personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

In general:

• Google account information linked to your Eloria user account is retained while your account remains active. If your account is deleted, we delete or anonymize associated Google user data within 30 days unless we are legally required to retain it for a longer period.
• OAuth authentication information is retained only for as long as necessary to maintain authenticated access and is removed when no longer required.
• Authentication records and session-related data are retained only as long as needed to secure access to the service.
• When you request deletion of your account, we will delete or anonymize Google user data associated with your account within a reasonable timeframe, unless retention is required to comply with legal obligations, resolve disputes, enforce our agreements, or protect against fraud or abuse.
• Documents retrieved from Google Drive may be stored within Eloria's infrastructure to provide the requested functionality, improve performance, and enable delivery to authorized users through the platform and supported communication channels. These stored copies are retained while they are needed to provide the service or until they are deleted by the customer or upon account deletion, unless a longer retention period is required by law.
• Data we process on behalf of a customer is retained while their contract is in force. On termination we delete or return it, except where we must retain it to comply with a legal obligation or to defend a legal claim. A customer may instruct us at any time to delete the data of specific individuals.

You may request deletion of your account and associated Google user data by contacting us using the details in Section 9. We may ask you to verify your identity before processing a deletion request.

You may remove selected Google Drive folders or files, or disconnect Google Drive, at any time from the Eloria Settings page. You may also revoke Eloria's access to your Google account through your Google Account permissions at https://myaccount.google.com/permissions. Revoking access will prevent future Google Sign-In and Google Drive access, but may not by itself delete data already stored in Eloria until you submit a deletion request.

When a retention period expires or deletion is completed, we delete or anonymize the data in accordance with our internal procedures.

Depending on your location, you may have rights to access, correct, delete, or restrict the processing of your personal information.

If you are in Colombia, Ley 1581 de 2012 grants you the right to know, update and rectify your data; to request proof of the authorization granted; to be informed of the use given to your data; to file complaints with the Superintendencia de Industria y Comercio; to revoke your authorization or request deletion where the law allows; and to access your data free of charge.

You can sign out of the Eloria web application at any time, which removes active session tokens from your browser.

To exercise privacy rights or ask questions about your data, contact us using the information below. Where we act as a processor, we will forward your request to the customer who controls the data and assist them in responding.

If you have questions about this Privacy Policy, Google user data, or wish to request access to or deletion of your information, contact Tempo Software SAS:

• WhatsApp: +59897599313
• Email: juan@eloria.app

We will respond to verified requests within 30 days and in accordance with applicable law. Requests subject to Colombian law are handled within the time limits set by articles 14 and 15 of Ley 1581 de 2012.

We may update this Privacy Policy from time to time. If we make material changes to how we collect, use, store, or share Google user data, we will update this page and revise the "Last updated" date above.

Your continued use of Eloria after an update becomes effective constitutes acceptance of the revised policy, except where further consent is required by law.