Privacy Policy

ElmElara (“ElmElara,” “we,” “us,” or “our”) respects your privacy and is committed to handling personal information responsibly.

This Privacy Policy explains how ElmElara may collect, use, disclose, protect, and retain personal information when you visit our website, create an account, purchase products, enroll in or access courses, contact us, subscribe to communications, or otherwise interact with ElmElara.

Because some ElmElara courses may be designed for or used by children, this Privacy Policy includes additional information about children’s privacy, parental rights, and the safeguards that may apply to children’s personal information.

Please read this Privacy Policy carefully. If you do not agree with our privacy practices, please do not use the ElmElara website or services.

1. Information Covered by This Privacy Policy

This Privacy Policy applies to personal information collected through ElmElara websites, services, and other online activities that link to this Privacy Policy, including, as applicable:

• The ElmElara website
• Online course enrollment and access
• Beauty product purchases
• Customer accounts
• Customer support
• Contact forms
• Newsletter and marketing subscriptions
• Communications with ElmElara
• Other online services operated by ElmElara that link to this Privacy Policy

This Privacy Policy does not apply to websites, applications, platforms, or services that ElmElara does not own or control. Third-party services may have their own privacy policies and terms, and we encourage you to review them before providing personal information.

2. Personal Information We Collect

The personal information we collect depends on how you interact with ElmElara and which products or services you use.

Information You Provide Directly

Depending on the circumstances, you may provide information such as:

• Name
• Email address
• Mailing or shipping address
• Billing address
• Phone number
• Account or login information
• Course enrollment information
• Product order information
• Course participation or progress information
• Customer service communications
• Newsletter subscription information
• Information submitted through contact forms
• Information provided when exercising a privacy right
• Other information you voluntarily provide to us

We seek to collect information that is reasonably necessary for the purpose for which it is collected.

Information We Collect Automatically

When you visit or use our website or services, certain information may be collected automatically, depending on the technologies we use. This may include:

• IP address
• Browser type
• Device type
• Operating system
• General geographic information
• Pages or content viewed
• Referring website or page
• Approximate dates and times of access
• Website interactions
• Technical identifiers
• Security and diagnostic information
• Other information reasonably necessary to operate, secure, and improve our services

The actual information collected automatically depends on the technologies and services implemented on the applicable website or platform.

3. Payment Information

When you purchase a beauty product or course, payment information may be processed by a third-party payment provider.

Depending on the payment provider used, ElmElara may receive information such as:

• Payment status
• Transaction amount
• Order information
• Payment method type
• Transaction identifiers
• Limited payment-related information necessary to administer the transaction

Unless we specifically state otherwise, ElmElara does not intend to store complete payment card numbers on its own systems.

Payment providers may collect and process payment information under their own privacy policies and terms.

4. Information Related to ElmElara Courses

ElmElara provides online educational courses. The information associated with a course may vary depending on the course, enrollment process, learning environment, and technology used to provide the course.

Depending on the particular course, we may collect or receive:

• Course enrollment information
• Course purchase information
• Account information
• Course access information
• Course progress or participation information
• Lesson completion information
• Quiz or assessment activity
• Information necessary to maintain course security and functionality
• Customer support communications
• Technical information associated with course access

Not every course or learning environment collects all of these categories of information.

Unless a particular course page or service states otherwise, ElmElara courses are primarily text-based and interactive and are not represented as video-based courses or as including downloadable course materials.

If a particular course uses additional features, technologies, or third-party platforms that collect additional information, ElmElara will provide applicable notices and disclosures.

5. Courses Used by Children

Some ElmElara courses may be designed for or used by children or other minors.

When a parent or legal guardian purchases or enrolls a child in a course, the parent or guardian may provide information necessary to complete the purchase, establish an account, obtain parental consent where required, and administer the course.

Depending on the course and platform, this may include:

• Parent or legal guardian name
• Parent or legal guardian email address
• Billing information
• Account information
• Purchase information
• Course enrollment information
• Information necessary to provide customer support
• Information necessary to administer parental rights or consent

Depending on how a particular course operates, some information may also be provided directly by a child through the course, account, learning platform, or other technology.

ElmElara does not assume that all information associated with a children’s course is provided exclusively by a parent or legal guardian.

Because children’s privacy obligations depend on the actual audience, information collected, technology used, and circumstances of collection, ElmElara will evaluate each children’s course and related technology based on the information actually collected and how it is used.

6. Children’s Privacy

ElmElara takes children’s privacy seriously.

The federal Children’s Online Privacy Protection Act and its implementing regulations (“COPPA”) generally apply to online services directed to children under 13 that collect personal information from children and to certain general-audience services that have actual knowledge that they are collecting personal information from children under 13.

Other federal, state, or local privacy laws may also apply depending on the service, the child’s location, the information collected, and the circumstances of collection.

Where a children’s course or service is subject to COPPA or another applicable children’s privacy law, ElmElara will implement the requirements applicable to that service and processing activity.

Depending on the circumstances and applicable law, these requirements may include:

• Providing parents or legal guardians with appropriate privacy notices
• Obtaining verifiable parental consent before collecting, using, or disclosing children’s personal information when required
• Limiting collection to information reasonably necessary for the applicable activity
• Providing parents or legal guardians with applicable access and deletion rights
• Allowing parents or legal guardians to withdraw consent or request that further collection or use stop when required
• Limiting disclosures to third parties as required by law
• Maintaining reasonable security safeguards
• Establishing reasonable retention and deletion procedures
• Providing applicable choices regarding the collection, use, or disclosure of children’s information

ElmElara will not intentionally require a child to provide more personal information than is reasonably necessary to participate in the applicable activity.

The FTC amended the COPPA Rule in 2025. ElmElara will apply the requirements of the amended rule to covered services and processing activities to the extent applicable.

7. Information That May Be Collected Through a Child’s Course

Depending on the course and technology used to provide it, a child’s participation may generate or involve information such as:

• Course progress
• Lesson completion
• Quiz or assessment activity
• Course participation
• Account or access information
• Technical information
• Security and authentication information
• Information necessary to provide customer support
• Information reasonably necessary to maintain course functionality

ElmElara does not represent that every children’s course, account, or learning environment collects the same information.

The specific information collected will depend on the actual course and technology used to deliver it.

Before launching or materially changing a course intended for children, ElmElara should review the applicable enrollment process, learning platform, account requirements, cookies, analytics, integrations, advertising technologies, and third-party services to determine what information is actually collected and what legal requirements apply.

8. Parental Rights and Children’s Privacy Requests

Where applicable law provides parents or legal guardians with rights concerning a child’s personal information, ElmElara will provide those rights as required by law.

Depending on the circumstances, a parent or legal guardian may have the right to:

• Request information about personal information collected from their child
• Review applicable personal information collected from their child
• Request deletion of applicable personal information
• Request that further collection or use of applicable information stop
• Withdraw previously provided consent where applicable
• Ask questions about how applicable information is collected, used, or disclosed
• Exercise other rights provided by applicable law

ElmElara may use reasonable procedures to verify the identity of a person making a request and, where required, verify that person’s relationship to or authority concerning the child.

To submit a request concerning a child’s personal information, contact:

Privacy Email: info@elmelara.com

Please identify yourself as the child’s parent or legal guardian and provide sufficient information for ElmElara to understand and, where required, verify the request.

9. How We Use Personal Information

Depending on the service and applicable circumstances, ElmElara may use personal information to:

• Provide and operate our website
• Process product purchases
• Process course enrollments
• Provide access to courses
• Manage customer accounts
• Provide customer support
• Respond to questions and inquiries
• Communicate about purchases, accounts, courses, or enrollments
• Send requested newsletters or marketing communications
• Provide information about ElmElara products, courses, or services
• Maintain and improve our website and services
• Understand how our services are used
• Maintain website and course functionality
• Detect and prevent fraud, abuse, or unauthorized activity
• Maintain the security and integrity of our systems
• Maintain business and transaction records
• Comply with applicable legal obligations
• Enforce our agreements and policies
• Exercise or defend legal rights
• Carry out other purposes disclosed when information is collected or otherwise permitted by law

We will not use personal information for materially incompatible purposes unless permitted or required by applicable law or with appropriate consent where required.

10. Marketing Communications

If you voluntarily subscribe to an ElmElara newsletter or other marketing communication, we may use your contact information to send communications about:

• New beauty products
• New courses
• Learning resources or tips
• Brand updates
• Promotions or special offers
• Other ElmElara news

You may unsubscribe from marketing emails by using the unsubscribe mechanism included in the applicable communication.

Unsubscribing from marketing communications does not necessarily stop transactional or service-related communications, such as:

• Purchase confirmations
• Course or account notices
• Security communications
• Customer service communications
• Important legal or policy updates

ElmElara will handle marketing involving children in accordance with applicable children’s privacy and advertising requirements. ElmElara will not use children’s personal information for targeted advertising or other purposes in a manner prohibited by applicable law.

11. Cookies and Similar Technologies

ElmElara may use cookies, pixels, local storage, analytics tools, or similar technologies to operate, secure, understand, and improve our website and services.

Depending on the technologies actually used, these technologies may:

• Keep the website functioning
• Maintain security
• Remember preferences
• Maintain account sessions
• Understand website usage
• Improve website performance
• Measure communications or marketing effectiveness
• Understand how visitors interact with our services

The technologies used by ElmElara may change over time.

Where required by applicable law, ElmElara will provide appropriate notice and choices concerning non-essential cookies and similar technologies.

Because some ElmElara courses may be used by children, ElmElara will consider children’s privacy requirements when selecting, configuring, and using analytics, advertising, cookies, pixels, and similar technologies.

ElmElara will not knowingly use a technology to collect, use, or disclose children’s personal information in a manner prohibited by applicable children’s privacy law.

12. Analytics

ElmElara may use analytics services to understand how visitors use our website and services.

Depending on the actual tools used, analytics information may include:

• Browser type
• Device type
• Operating system
• General geographic information
• Pages visited
• Referring pages
• Approximate time spent on pages
• Website interactions
• Technical identifiers
• Other usage or technical information

Analytics practices depend on the specific tools and providers used by ElmElara.

ElmElara will take reasonable steps to configure analytics and similar technologies in accordance with applicable legal requirements, including requirements that may apply to children’s services.

ElmElara will review analytics and tracking technologies used in connection with children’s courses to determine whether they may collect children’s personal information and whether their use is permitted under applicable law.

13. How We Share Personal Information

ElmElara may disclose personal information when reasonably necessary to provide requested products or services, operate our business, protect users and our systems, or comply with legal obligations.

Depending on the services we use, personal information may be disclosed to the following categories of recipients.

Service Providers

ElmElara may use third-party service providers to perform services on our behalf, including providers for:

• Website hosting
• Course or learning-platform services
• Payment processing
• Customer support
• Email delivery
• Account management
• Security
• Technology services
• Analytics
• Other business operations

Where appropriate, ElmElara will seek contractual or other reasonable measures requiring service providers to process personal information only for authorized purposes and to maintain appropriate safeguards.

Legal and Safety Purposes

ElmElara may disclose personal information when reasonably necessary to:

• Comply with applicable law
• Respond to lawful legal process or governmental requests
• Protect our rights or property
• Protect users or other people
• Prevent fraud, abuse, or unauthorized activity
• Investigate suspected unlawful activity
• Enforce our agreements or policies
• Exercise or defend legal rights

Business Transactions

If ElmElara becomes involved in a merger, acquisition, financing, reorganization, sale of assets, bankruptcy proceeding, or similar business transaction, personal information may be transferred as part of that transaction, subject to applicable law.

Third-Party Marketing or Advertising

If ElmElara uses third-party advertising, marketing, or similar technologies that involve disclosure of personal information, ElmElara will evaluate those activities under applicable privacy laws, including laws concerning children’s personal information, targeted advertising, sales, sharing, and opt-out rights.

ElmElara will not knowingly disclose children’s personal information to third parties for targeted advertising or another purpose when applicable law requires parental consent or otherwise prohibits the disclosure unless the required legal requirements have been satisfied.

14. Sale, Sharing, and Other Transfers of Personal Information

ElmElara does not intend to sell personal information for monetary consideration.

However, privacy laws may define terms such as “sale,” “sharing,” “targeted advertising,” or similar activities more broadly than ordinary language.

Accordingly, ElmElara will evaluate its actual data practices under applicable law and will provide any required disclosures, notices, consent mechanisms, or opt-out rights.

ElmElara will not knowingly engage in a sale, sharing, targeted advertising activity, or similar disclosure involving children’s personal information when prohibited by applicable children’s privacy law.

If ElmElara’s privacy practices materially change, we will update this Privacy Policy and provide any additional notices or choices required by applicable law.

15. Children’s Information and Third-Party Services

A children’s course may use third-party technologies to provide or support the course.

Depending on the course, these technologies may include:

• Learning platforms
• Website hosting providers
• Payment providers
• Customer-support systems
• Email or communication providers
• Security providers
• Analytics providers
• Other technology services

The actual third parties used by ElmElara may vary by course and may change over time.

Before using a third-party service in connection with a children’s course, ElmElara should evaluate:

• What information the service collects
• Whether the service receives information directly from children
• How the service uses the information
• Whether the service shares information with additional parties
• Whether advertising or analytics technologies are involved
• How long the service retains information
• What deletion mechanisms are available
• What contractual protections apply

Where children’s personal information is subject to COPPA or another children’s privacy law, ElmElara will take reasonable steps to ensure that applicable third-party disclosures and processing comply with the law.

16. Public Disclosure and Interactive Features

ElmElara will not intentionally enable children to publicly disclose personal information through a course feature unless the applicable feature and disclosure are permitted under applicable law and the required protections are in place.

If a course includes interactive, community, discussion, messaging, profile, commenting, or similar functionality, ElmElara will evaluate whether the feature creates additional privacy or children’s privacy obligations.

Parents and guardians should review the features of a course before allowing a child to participate.

17. Data Security

ElmElara takes reasonable administrative, technical, and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, misuse, or destruction.

Security measures may include, as appropriate:

• Access controls
• Authentication measures
• Administrative safeguards
• Technical safeguards
• Vendor security requirements
• Monitoring and security procedures
• Secure transmission or storage practices
• Procedures for responding to suspected security incidents

The security measures used by ElmElara may vary depending on the type and sensitivity of information and the service involved.

No method of transmitting or storing information online can be guaranteed to be completely secure.

For children’s personal information, ElmElara will maintain reasonable safeguards appropriate to the nature and sensitivity of the information and applicable legal requirements.

If you create an ElmElara account, you are responsible for maintaining the confidentiality of your login credentials. Please notify ElmElara promptly if you believe your account has been accessed without authorization.

18. Data Retention and Deletion

ElmElara retains personal information only for as long as reasonably necessary to fulfill the purpose for which it was collected, provide requested services, comply with legal obligations, maintain appropriate business records, resolve disputes, enforce agreements, prevent fraud or abuse, maintain security, or otherwise fulfill a legitimate and lawful purpose.

Retention periods may depend on:

• The type and sensitivity of the information
• The purpose for which it was collected
• Whether the information is necessary to provide a service
• Legal, tax, accounting, or recordkeeping requirements
• The need to resolve disputes or enforce agreements
• Security, fraud-prevention, or abuse-prevention needs
• Whether the information is subject to a deletion request or other legal requirement

ElmElara does not intend to retain personal information indefinitely when it is no longer reasonably necessary for the purpose for which it was collected.

Children’s Information

For children’s personal information subject to COPPA or another applicable children’s privacy law, ElmElara will retain information only for as long as reasonably necessary to fulfill the specific purpose for which it was collected or as otherwise permitted or required by law.

ElmElara will maintain reasonable procedures for deleting children’s personal information when it is no longer reasonably necessary for the applicable purpose, subject to legal, security, fraud-prevention, or other lawful retention requirements.

ElmElara should maintain an internal retention schedule identifying the applicable retention period or deletion criteria for children’s information and other categories of personal information.

19. Your Privacy Choices and Rights

Depending on where you live and which privacy laws apply, you may have rights concerning your personal information.

Depending on the circumstances, these rights may include:

• Requesting access to personal information
• Requesting correction of inaccurate personal information
• Requesting deletion of personal information
• Requesting information about how personal information is processed
• Obtaining a copy of certain personal information
• Opting out of certain marketing communications
• Opting out of certain processing activities where required by law
• Exercising other rights provided by applicable law

Not every right applies in every circumstance.

ElmElara may need to verify your identity before completing certain requests. We will use reasonable procedures designed to prevent unauthorized disclosure of personal information.

Where applicable law provides a right to appeal a privacy-request decision, ElmElara will provide information about how to submit an appeal.

To submit a privacy request, contact:

Privacy Email: info@elmelara.com

20. Texas Privacy Rights

ElmElara operates in Texas and may be subject to the Texas Data Privacy and Security Act (“TDPSA”) depending on the nature and scope of ElmElara’s business and the applicable statutory requirements.

Where the TDPSA applies to ElmElara and to a particular individual or processing activity, eligible Texas residents may have rights concerning their personal data, including, subject to statutory exceptions and limitations:

• The right to confirm whether ElmElara is processing personal data
• The right to access personal data
• The right to correct inaccuracies
• The right to delete personal data
• The right to obtain a copy of certain personal data in a portable format
• Certain rights to opt out of applicable processing activities

The TDPSA provides additional protections concerning sensitive data and the personal data of known children.

ElmElara may verify a requester’s identity as reasonably necessary to process a request securely.

Where applicable, ElmElara will respond to qualifying privacy requests within the time required by applicable law.

If ElmElara declines a request where applicable law provides a right to appeal, ElmElara will provide instructions for submitting an appeal.

To submit a Texas privacy request or appeal:

Privacy Email: info@elmelara.com

ElmElara will process qualifying requests in accordance with applicable Texas law.

21. California and Other State Privacy Rights

Privacy laws vary among states and may apply differently depending on the size and activities of a business.

If ElmElara is subject to a state privacy law and that law provides applicable rights to an individual, ElmElara will provide the disclosures, rights, notices, and mechanisms required by that law.

Depending on the applicable law, rights may include:

• Access
• Correction
• Deletion
• Data portability
• Information about categories of personal information collected
• Information about purposes and categories of processing
• Opting out of certain processing
• Opting out of certain targeted advertising
• Opting out of certain sales or sharing of personal information
• Limiting certain uses or disclosures of sensitive personal information
• Appeal rights
• Other rights provided by applicable law

Additional state-specific notices or request mechanisms may be provided when required.

22. Third-Party Websites, Platforms, and Services

ElmElara may link to or integrate with third-party websites, platforms, applications, payment processors, learning environments, or other services.

ElmElara does not control the privacy practices of third parties that operate independently from ElmElara.

Your use of a third-party service may be governed by that service’s own privacy policy, terms of service, and other applicable policies.

For example, a payment processor or learning platform may collect and process information directly under its own privacy practices.

We encourage parents, guardians, students, customers, and other users to review the privacy practices of third-party services before providing information to them.

23. International Users

ElmElara is operated from the United States unless otherwise stated.

If you access ElmElara from outside the United States, your information may be processed in the United States or in other locations where ElmElara or its service providers operate.

Privacy and data-protection laws in those locations may differ from the laws where you live.

By using ElmElara services from outside the United States, you understand that your information may be transferred to and processed in the United States or other locations where ElmElara or its service providers operate, subject to applicable law.

Where another jurisdiction’s privacy law applies to ElmElara, ElmElara will provide the rights and protections required by that law to the extent applicable.

24. Sensitive Personal Information

ElmElara does not generally need sensitive personal information to provide ordinary beauty products or educational services.

Unless ElmElara specifically requests information for a legitimate and disclosed purpose, please do not submit:

• Social Security numbers
• Government identification numbers
• Financial account credentials
• Medical records
• Detailed medical information
• Passwords for unrelated services
• Other highly sensitive personal information

If you voluntarily provide sensitive personal information, ElmElara will handle it in accordance with applicable law and this Privacy Policy.

ElmElara does not intend for children’s courses to require children to provide sensitive personal information unless the collection is reasonably necessary for a legitimate and disclosed purpose, legally permitted, and appropriately protected.

25. Account Security

If you create an ElmElara account, you are responsible for keeping your login credentials confidential.

You should:

• Use a strong and unique password
• Avoid sharing your password with unauthorized individuals
• Log out of shared devices when appropriate
• Notify ElmElara promptly if you believe your account credentials have been compromised
• Notify ElmElara if you believe unauthorized activity has occurred in your account

ElmElara will take reasonable measures to protect account information, but no online account or transmission can be guaranteed to be completely secure.

26. Privacy Requests and Verification

To protect personal information, ElmElara may take reasonable steps to verify the identity of a person submitting a privacy request.

The verification process may depend on:

• The nature of the request
• The sensitivity of the information involved
• The account associated with the request
• The applicable privacy law

ElmElara will not require unnecessary information solely for verification.

For requests concerning a child, ElmElara may also need to verify the requester’s identity and, where required by law, the requester’s relationship to or authority concerning the child.

If ElmElara cannot reasonably verify a request, we may be unable to complete the request where applicable law permits or requires verification.

27. Children’s Privacy Requests and Parental Consent

Parents and legal guardians may contact ElmElara regarding a child’s personal information using the contact information below.

Depending on the circumstances, ElmElara may require information reasonably necessary to verify:

1. The identity of the requester;
2. That the requester is the child’s parent or legal guardian; and
3. The identity of the child or account involved.

Where parental consent is required by applicable law, ElmElara will use a legally permitted method for obtaining and documenting that consent.

Where a parent or legal guardian withdraws consent or requests deletion, ElmElara will take the actions required by applicable law, subject to lawful exceptions and retention requirements.

28. Changes to This Privacy Policy

ElmElara may update this Privacy Policy from time to time to reflect changes in:

• Our products or services
• Course offerings
• Technology
• Data practices
• Third-party providers
• Privacy laws or regulatory requirements
• Business operations

When we make changes, we will post the updated Privacy Policy on the ElmElara website and update the Effective Date.

If a change is material and applicable law requires additional notice or consent, ElmElara will provide the notice or obtain the consent required by law.

We encourage you to review this Privacy Policy periodically.

29. Contact Us

If you have questions about this Privacy Policy, want to exercise an applicable privacy right, or have a question about children’s privacy, please contact ElmElara:

ElmElara
Privacy Email: info@elmelara.com
Website: www.elmelara.com
Location: Texas, USA

For a request concerning a child’s personal information, please identify yourself as the child’s parent or legal guardian and provide enough information for ElmElara to understand and, where required, verify the request.

30. Important Information for Parents and Guardians

ElmElara wants parents and guardians to understand that the information collected through a children’s course can depend on the particular course and technology used to provide it.

Before a child participates in an ElmElara course, parents and guardians should review the applicable course information and understand:

• What information the course requires
• What information may be collected during participation
• Whether an account is required
• Whether parental consent is required
• How the child’s information will be used
• Whether third-party services are involved
• Whether analytics or advertising technologies are used
• How long information may be retained
• How parents can request access or deletion
• How parents can withdraw consent where applicable

ElmElara will evaluate children’s courses and associated technologies before launch or material changes to help ensure that the actual collection, use, disclosure, security, and retention of children’s information are consistent with applicable law and ElmElara’s privacy commitments.

Parents or legal guardians with questions about a child’s information may contact ElmElara using the contact information above.