Last Updated: 6 January 2025.
Elvie’s commitment to privacy
At Elvie, we are as committed to protecting and respecting your privacy as we are to creating cutting edge, smart technology for women. This Privacy Policy (Policy) sets out how we collect, store and process your personal information, as well as providing information regarding our use of cookies and similar technologies. When we say ‘personal information’, we not only mean information that can identify you (such as your name or email address) but also any information that could reasonably be linked back to you (such as your device information).
We operate the www.elvie.com website where you can view and order products, read updates and information about our products and women's health in general, and browse instructions and guidance on how to use our products (Site). We also operate Apps, including product specific Apps for pairing with our products (Apps).
This Privacy Policy applies to the Site, our Apps and when you otherwise interact with us in person (including by phone) or in other ways such as when you contact customer care (collectively, our Products & Services). We also explain in this Policy how you can exercise your rights relating to your personal information, including the right to object to certain types of processing we carry out.
Please ensure that you have read this Policy and understood how we collect, store and process your personal information before accessing our Products & Services.
Who is responsible for your personal information
The legal entity responsible for the information that we collect through our Product & Services is Chiaro Technology Limited, which trades as Elvie (we / us). If you have any questions about this Policy, please see the Contact Us section at the bottom.
We are an independent controller in respect of your personal information, which means we are responsible for how your personal information is used in accordance with this Policy. We also rely on trusted service providers to process data on our behalf, such as our cloud service providers, as described below.
Personal information we collect
We collect personal information that you voluntarily provide to us directly through your interactions with our Products & Services. This can include information you provide to us when you order and pay for a Product through our Site, correspond with us by phone, e-mail or otherwise, submit reviews, set up an account on an App, or when you pair and use one of our connected/smart Products with the appropriate App. We may also automatically collect information (e.g. through Cookies and Similar Technologies) through your use of and interactions with our Products & Services and process personal information that is generated from the information we collect, for example to identify pumping patterns.
The information we collect and receive can include:
Account Information such as your Elvie Account and related account details, including email address, devices registered, username and account status.
Contact Information such as your name, phone number, e-mail address and shipping address.
Transaction Information such as the Products you order from our Site, as well as the date and time of your transaction.
Payment Information such as your credit or debit card information or other method of payment, billing address and other information such as date and time of your transaction.
User Information such as your gender or the gender of your baby, the year you were born and the number of children you have had and other information you may provide to us about yourself or your baby.
Health and Lifestyle Information where you choose to share this information such as your pregnancy status or previous births, breast feeding/pumping sessions.
Device Information from which your device could be identified or about your device, such as your device’s operating systems and hardware and software versions, device identifiers, internet protocol (IP) address, browser type and version, time zone setting, country and language. Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may however help us determine an approximate location.
Usage Information about your use of our Products & Services such as the time, frequency and duration of use, information about the features you use and the pages you view on the Site and the Apps, your results when you use our Products & Services, data about the performance of our Products & Services and any problems you experience, including error reports, and your navigation through our Site.
Customer Support Information you give us when you contact us for help, such as your name, the content of your chats and other communications with us. When you contact us for customer support, chat sessions with our representatives may be monitored and recorded.
Communications Information which includes your preferences and subscriptions, such as your preferences about how the Site and Apps are displayed, whether you have subscribed to any newsletters and your preferences set for notifications and marketing communications.
You are not required to provide the personal information that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our Products & Services or respond to requests you may have.
Single sign-on (SSO) services: If you choose to log into our Apps using single sign-on (SSO) services such as Google and Apple, these services authenticate your identity and allow us to collect certain limited personal information.
Combining data: We may link or combine the personal information you provide to us with the information we collect automatically. This allows us to provide you with a personalised experience.
Aggregated data: We may derive aggregated data from your personal information. For example, we may aggregate Usage Information to calculate the average number of pumping sessions across all users of Elvie Pump in a month. However, because this data has been through a process to de-identify personal information so that it can no longer be associated with a person, the aggregated data cannot directly or indirectly reveal your identity and is no longer personal information.
Why we collect your personal information and our legal basis for processing
We use the information we collect only when we have a valid reason and legal basis to do so. We determine the legal bases based on the purposes for which we collect your information. The legal bases we rely on may include the following:
to provide a Product or Service you’ve asked for under a contract we have entered into, or which we are about to enter;
where it is necessary for our legitimate interests provided that your interests and fundamental rights and freedoms do not override those interests;
where we need to comply with a legal or regulatory obligation or to protect your vital interests;
where we ask for your consent to process your information for specific purposes and you have the right to withdraw your consent at any time. Some of the personal information that we collect about you or your baby may be special categories of data (such as what type of birth you had). We may use your special categories of data where you have provided your explicit consent which you may withdraw at any time.
Elvie uses personal information to provide our Products & Services to you and (where you choose to do so) to personalise them, to improve, develop and design existing and new Products & Services, to communicate with you and to promote safety and security. We may also use personal data for other purposes with your consent. Further details about the purposes for which we use your personal information are as follows here.
Reasons we share your personal information
We do not share your personal information with others except as described in this Policy (like to provide, maintain and secure our Apps, or if we’re required to do so by law). We do not sell any of your information to anyone.
We share your information as follows:
With Service Providers who act on our behalf. As with most companies, we use third parties to help us provide elements of our Products & Services, such as hosting providers, payment card processors, fraud prevention, shipping and fulfilment partners and customer contact centre support. For example, we share certain Contact Information with our shipping and delivery providers so that they can deliver Products ordered by you to your shipping address. These providers process your personal information on our behalf for the purposes set out in this Policy. These providers are subject to contractual obligations governing privacy, data security and confidentiality.
With our group companies. We may share your information with our group companies (Chiaro USA, Inc. and Chiaro Europe BV), including companies that we may acquire or merge with in the future, but only to the extent necessary to fulfil purposes set out in this Policy, or otherwise as authorised by you. If we are involved in a merger, acquisition, or sale of assets, we may share your personal information with the acquiring or receiving entity. The categories of information we disclose and our legal basis for doing so depends on the circumstances, but would include our legitimate interest in operating, selling and expanding our business, including through such transactions.
For other legal or regulatory process. We may share your personal information if we believe it is reasonably necessary where required by law, to comply with legal processes, to permit us to pursue available remedies, including commencing or responding to any claims, to enforce or apply our terms, to protect the security or integrity of our services, to protect the rights, property, interests or safety of our Products & Services, our employees, customers or users or for risk management purposes. The categories of information we disclose and our legal basis for doing so depends on the circumstances, but generally it is to comply with legal obligations, to protect vital interests or act in our legitimate interest to provide a secure and safe service and preventing fraud and unauthorised use of our products and services, violations of our terms and policies or other harmful or illegal activity, and in protecting our and others’ rights, property and interests, and responding to legal requests from governmental and law enforcement agencies.
Social media. We may use "lookalike" analytics functions, such as "Facebook Lookalike Audiences", to identify new potential customers on the basis that they might share some characteristics with you. If you interact with us through social media, such as if you access our Site or download our Apps in response to an advert on a social media platform, we may therefore share certain personal information with social media platforms to enable them to identify users similar to you, such as users that have liked the same pages or content as you. We may also use social media features such as the Facebook “Like” button, and transfer data collected via social media widgets to the social media platform who will then process the data in accordance with their own privacy policies.
Other than as set out above, we may also share statistics and insights developed by us from your personal information. These statistics and insights are derived from Aggregated Data, such that it would not be possible to identify you (directly or indirectly) or even single you out from this information.
Keeping your information secure
We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
The specific security measures used are based on the sensitivity of the personal information collected. While we cannot guarantee that loss, misuse or alteration of data will not occur, we have measures in place designed to protect against inappropriate access, loss, misuse, or alteration of personal information under our control. For example:
We work to limit access to your personal information to those employees, agents, contractors and other third parties strictly on a “need to know” basis.
We use secure server software to encrypt personal information, and we only use service providers that meet and commit to our security standards.
Our security team regularly reviews our security and privacy practices and enhances them as necessary to help protect the integrity of our systems and your personal information.
Third party websites, services and apps
Some of the correspondence you receive from us may contain links to third-party websites, online services or mobile applications that are not affiliated to or operated by us, including those of our Partners. We are not responsible and accept no liability for the content, security or privacy practices of those other operators.
Your rights and access to your personal information
We provide you with rights and choices about the personal information we collect and hold about you. The specific choices available to you may vary depending on your location and applicable law.
Right of access: You have a right to request access to your personal information and to be provided with a copy of your personal information, including the categories of your personal information we collect and disclose.
Right of deletion: You have the right, in certain cases, to request that we delete your information, provided there are valid grounds for doing so and subject to applicable law. See How to exercise your rights for information on how to delete your personal information.
Right of correction: You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay, though we may need to verify the accuracy of the new data you provide to us.
Right to object (legitimate interest): Where we process your personal information based on legitimate interests, you can object to this processing where you feel it impacts on your fundamental rights and freedoms. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object.
Right to object (marketing): We do not send marketing communications from KWS to our end-users or end-users of our Partners.
Right of portability: You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
Right to restrict processing: You have the right, in certain cases, to temporarily restrict the processing of your information by us, provided there are valid grounds for doing so.
Right to withdraw consent: Where you have previously provided your consent, you have the right to withdraw consent at any time where we are relying on consent as the legal basis upon which to process your personal information. However, this will not affect the lawfulness of the processing based on consent before its withdrawal.
Right to complain: If you are concerned that we have not complied with your legal rights or applicable privacy laws, you have the right to lodge a complaint with our supervisory authority, the UK Information Commissioner (www.ico.gov.uk), which is the regulator responsible for data protection in the United Kingdom. You can also lodge a complaint with your local supervisory authority for data protection.
How to exercise your rights
You may review and edit some of the personal information you have submitted to us through the appropriate functionality on the Apps.
You can close your Elvie Account by using the in-app account deletion function. This will delete your Account Information and all other personal information associated with and submitted through the Apps across all Elvie Apps immediately and cannot be undone. Please note that by closing your Elvie Account, personal information you have submitted to Elvie, or which has been collected by Elvie, outside of the App will not be deleted, such as if you have subscribed to our newsletter or submitted reviews via the Site.
If you want to exercise any of your rights and are not able to do so by using the in-app account deletion function, please contact us using the contact details at the end of this Policy.
Before we process such requests, we may ask you to verify your identity (like by responding to an email from us or providing us with certain information) if warranted for a particular disclosure. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. No payment is usually required to exercise your rights. However, we may request payment where allowed by law (for example, if your request is manifestly unfounded or excessive).
There may be situations where we cannot grant your request — for example, if you ask us to delete your Transaction Data and Elvie is legally obligated to keep a record of that transaction to comply with law, or if your request jeopardizes the privacy of others, or is frivolous or vexatious.
If you are a California resident, refer to the California residents section below for more information on your legal rights.
Our retention of personal information
As explained above, you can close your Elvie Account by using the in-app account deletion function. This will delete your Account Information and all other personal information associated with and submitted through the Apps across all Elvie Apps immediately and cannot be undone. Please note that by closing your Elvie Account, personal information you have submitted to Elvie, or which has been collected by Elvie, outside of the App will not be deleted, such as if you have subscribed to our newsletter or submitted reviews via the Site.
Otherwise, we retain personal information for as long as necessary to fulfil the purposes we collected it for, or for other legitimate purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements or protecting our rights.
Retention periods vary significantly depending on the different data types, the purposes for which they were collected and the context of our interactions with you. To determine the appropriate retention period, we consider:
the amount, nature and sensitivity of the data;
the potential risk of harm from unauthorised use or disclosure of the data;
the purposes for which we process the data and whether we can achieve those purposes through other means;
applicable legal, regulatory, tax or accounting requirements.
We require any third party service providers we use to delete personal information once it is no longer necessary for them to provide the services or to satisfy any legal, regulatory, tax, accounting or reporting requirements.
International transfer of personal information
The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in. If you are located in the UK or European Economic Area (EEA), your personal information may be processed outside of the UK or EEA including in the United States. We transfer your personal information in the following ways:
As we explain above, we use third party service providers to help us provide our Products & Services, such as hosting providers or payment card processors.
We may also share your personal information within our group of companies (in the US and the Netherlands).
Countries where we and our service providers operate may not offer the same level of data protection as your home country. Elvie complies with laws on the transfer of personal data between countries to help ensure your data is protected. We use specific contracting frameworks approved by the UK Government and European Commission which are designed to give personal information protection essentially equivalent to that in the UK and EEA.
Cookies and Other Technologies
Our Products & Services (namely, our Site and Apps) use cookies and similar technologies (such as Local Storage Objects, web beacons, scripts and pixels) to distinguish you from other users.
A cookie is a small piece of text sent to your browser by a website you visit. Cookies and similar technologies help us to provide you with a good experience when you browse our Products & Services and also allows us to monitor and analyse how you use and interact with our Products & Services so that we can continue to improve them. It also helps us and our advertising partners to determine products and services that may be of interest to you, in order to serve you targeted advertisements on other properties.
Our Cookies Notice explains the cookies we use and why.
The cookies and other technologies we use are designed to help you get the most from our Products & Services but if you do not wish to receive them, most browsers allow you to change your cookie settings. Please note that if you choose to refuse all cookies you may not be able to use the full functionality of our Products & Services. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, please use the "Help" option in your browser for more details.
Please note that deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs).
If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org or the Network Advertising Initiative's online sources at www.networkadvertising.org.
Tracking Technologies used in our emails
Our emails may contain tracking technologies that provide us with information about your interactions with our emails, including identifying if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you.
Most popular email clients will allow you to block these technologies by disabling certain external images in emails. You can do this through the settings on your email client – these generally give you the option of choosing whether emails will display "remote images", "remote content" or "images" by default.
Some browsers also give you the option of downloading and installing extensions that block tracking technologies.
Do Not Track
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. There is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” click here.
Interest Based Advertising
We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history and use of the Site. We may share, or we may permit third party online advertising networks, social media companies and other third party services to collect information about your use of the Site over time so that they may play or display ads of the Site, our products and services and similar products and services, on other websites, apps or services you may use (including Google and Facebook).
Typically, but not always, this information is collected through cookies and similar tracking technologies. These third parties may collect mobile identifiers, such as the ID for Advertising for iOS (IDFA), Google Advertising ID, as well as your device's IP address, information about other applications on your device, your location, information about your use of the Site and information about which adverts you have seen or clicked on.
We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
We may also use certain forms of display advertising and other advanced features through Google Universal Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Site. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by visitng NAI’s online resources at www.networkadvertising.org/choices.
Chiaro Technology partners with Rakuten Advertising, who may collect personal information when you interact with our site. The collection and use of this information is subject to the privacy policy located here. https://rakutenadvertising.com/legal-notices/services-privacy-policy
You may be able to limit the use of these identifiers for interest-based advertising on a particular device through the settings on your device by selecting "limit ad tracking" (iOS) or "opt out of interest based ads" (Android). You may also be able to opt-out of some, but not all, interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit:
a) the Network Advertising Initiative’s online resources, at www.networkadvertising.org/choices;
b) the DAA’s resources at www.aboutads.info/choices; and/or
c) Your Online Choices at www.youronlinechoices.eu.
Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices online resources will only opt you out from receiving interest-based ads on that specific browser or device, but you may still receive interest-based ads on your other devices. You would need to perform the opt-out on each browser or device you use.
Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or devices, or use another operating system, you will need to opt-out again.
Please note that opting out of interest-based advertising does not mean you will no longer see advertising on your device – it just means that adverts may no longer be tailored to your interests.
Links to third party sites
Our Products & Services may, from time to time, contain links to and from third party websites, including those of our partner networks, advertisers, partner merchants, news publications, and retailers. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
Our policy towards children
Our Products & Services are not directed at persons under 18 and we do not knowingly collect personal information from any persons under 18 (although we may collect your baby's personal information in connection with providing our Products & Services, as explained above). If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.
Location-specific rules
California residents
This additional section applies to California residents because of the specific privacy laws in that state. Elvie provides notice of our privacy practices to California residents in this Policy, including the personal information we collect, the source of the personal information and the purposes of use, as well as whether Elvie discloses that personal information and if so, the categories of third parties to whom it is disclosed.
California consumers have a right to know of, access, correct and delete their personal information under the California Consumer Privacy Act. In particular, you have the right to request from us:
the categories of personal information we have collected about you;
the specific pieces of personal information we have collected about you;
the categories of sources from which the personal information was collected;
the categories of personal information we have disclosed for a business purpose or sold/shared;
the categories of third parties to whom the personal information was sold/shared, disclosed for a business purpose, or otherwise disclosed; and
the business or commercial purpose for collecting or selling/sharing the personal information.
California consumers also have a right to opt out of the sale or sharing of their personal information by a business, and a right not to be discriminated against for exercising their California privacy rights.
To submit a request, please see the Contact Us section at the bottom. We will confirm your request and, if necessary, may request additional information from you to verify your identity and process your request. If we are unable to verify your identity, we may deny your request. You can also designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
We do not sell or share personal information
Elvie does not sell or share the personal information of California consumers as those terms are defined under California law, and does not discriminate in response to privacy rights requests or provide a lesser degree of service. Apple also does not use or disclose sensitive personal information for any purposes that would require a user to exercise a right to limit according to California law.
California residents “Shine the Light” law
We do not share your Personal Information with any unaffiliated third parties for their own marketing purposes.
See above for how we respond to Do Not Track signals.
Nevada residents
Nevada residents have the right to direct a business not to sell certain kinds of personal information that the business has collected about them. We do not sell personal information. If you are a Nevada resident and wish to submit a request relating to this right, please see the Contact Us section at the bottom. Elvie does not sell your personal data including as “sale” is defined in Nevada.
Contact us
We work hard to ensure that the processing of your personal information is carried out fairly and lawfully. If you have any questions regarding our privacy practices, need information or require assistance, please contact us at:
Email: privacy@elvie.com
If you are a resident of the EEA and wish to contact our representative in the EEA, you can find their contact details here.
If you are located in the US, you can also call us on: +1 (929) 239-3212.
If we are unable to deal with any issues you raise with us, you also have the right to lodge a complaint with your national data protection authority. Further information about how to contact your local data protection authority is available here.
Changes to this Policy
We may modify this Policy at any time. When we do, we will update the ‘Last updated’ date on this Privacy Policy. In some cases, such as when we make material or substantive changes to our policies and practices, we will also notify you of the relevant changes by email or within the Products & Services, as appropriate. We encourage you to periodically review this page for the latest information on our privacy practices.
If you object to any changes, you may delete your personal information as described in How to exercise your rights.