Privacy Notice
Date of Acceptance: March 3, 2026
Data Controller
Name: Eleven Technologies Inc.
Mailing Address: 1086 San Pablo Cir, Costa Mesa, CA 92626
Email: info@eleventechinc.com
Phone: +15106664000
Website: www.eleventechinc.com
If you are located within the territory of the European Union, the processing of your personal data is governed by Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR).
This document contains all relevant information regarding the processing of personal data in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation (hereinafter: Regulation or GDPR).
EU Representative (Article 27 GDPR)
If the Data Controller offers services to individuals located within the European Union or monitors the behavior of individuals within the European Union, the Data Controller shall appoint a representative within the European Union in accordance with Article 27 of the GDPR.
Principles of Data Processing
The Data Controller processes personal data in accordance with the following principles:
• processed lawfully and fairly
• collected for specified, explicit, and legitimate purposes
• processed in accordance with the principle of data minimization
• kept accurate and up to date
• stored only for a limited period of time
• protected by appropriate technical and organizational security measures
Information on the Use of Cookies
What is a cookie?
When you visit our website, the Data Controller uses so-called cookies. A cookie is a small data file consisting of letters and numbers that our website sends to your browser in order to store certain settings, make the use of our website easier, and help us collect certain relevant statistical information about our visitors.
Some cookies do not contain personal information and are not suitable for identifying individual users. However, some cookies contain a unique identifier — a secret, randomly generated number stored on your device — which can enable the identification of your device. The duration of operation of each cookie is specified in the description of the respective cookie.
Legal Background and Legal Basis of Cookies
We generally distinguish three types of cookies: essential cookies required for the operation of the website, statistical cookies, and marketing cookies.
The legal basis for the processing of statistical and marketing cookies is your consent pursuant to Article 6(1)(a) of the Regulation. For cookies necessary for the operation of the website, the legal basis is the legitimate interest required to ensure the proper functioning of the website pursuant to Article 6(1)(f) of the Regulation.
Main Characteristics of Cookies Used by the Website
Essential Cookies:
If you do not accept the use of these cookies, certain features of the website may not be available to you.
Session Cookie: These cookies store the visitor’s location, the language of the browser, and the currency used for payment. Their lifespan lasts until the browser is closed or up to a maximum of 2 hours.
Cookie Consent Cookie: When arriving on the website, you accept the statement regarding the storage of cookies in the notification window. Its lifespan is 365 days.
Statistical Cookies:
Google Analytics Cookie:
Google Analytics is Google’s analytics tool that helps website and application owners better understand the activities of their visitors. The service may use cookies to collect information and generate reports on website usage statistics without individually identifying visitors to Google. The primary cookie used by Google Analytics is the “__ga” cookie. In addition to generating reports from website usage statistics, Google Analytics – together with certain advertising cookies described above – may also be used to display more relevant advertisements in Google products (such as Google Search) and across the internet.
User Experience Cookies:
These cookies collect information about how users interact with the website, for example which pages they visit most frequently or what error messages they receive from the website. These cookies do not collect information that identifies visitors; therefore, they process only general and anonymous information. The data obtained from these cookies is used to improve the performance of the website. The lifespan of these cookies is limited exclusively to the duration of the session.
Cookie settings may be modified at any time.
Statistical and marketing cookies are used exclusively on the basis of the data subject’s prior consent.
Categories of Personal Data Processed
During Contact
Processed Data:
• name
• email address
• phone number (if provided)
• content of the message
Purpose of Processing: handling contact inquiries
Legal Basis: GDPR Article 6(1)(a) – consent
Retention Period: 1 year from the closure of the contact request
Data Processed for the Purpose of Contract Conclusion and Performance
Several types of data processing activities may occur in connection with the conclusion and performance of a contract. Please note that data processing related to complaint handling and warranty administration will only take place if you exercise one of the aforementioned rights.
Data Processing Activities Related to Contract Conclusion and Performance in Detail
Contact
For example, if you contact us by email, through a contact form, or by phone with a question regarding a product or an order. Prior contact is mandatory.
Processed Data
• Data provided by you during contact: name, email address, phone number (if provided)
• Purpose of Data Processing: handling contact inquiries
• Duration of Data Processing: data is processed only until the contact request is concluded.
• Legal Basis of Data Processing: your voluntary consent given to the Data Controller through initiating contact.
[Processing based on Article 6(1)(a) of the Regulation ]
Order Processing
During order processing, data processing activities are necessary in order to perform the contract.
Processed Data
During the data processing, the Data Controller processes your name, residential address, phone number, email address, the characteristics of the order, the order number, and the date of the order.
If you place an order with our company, the processing of data and the provision of such data are essential for the performance of the contract.
Duration of Data Processing: The data is stored for 5 years in accordance with the civil law limitation period.
Legal Basis of Data Processing: Performance of a contract.
[Processing based on Article 6(1)(b) of the Regulation]
Issuing an Invoice
The data processing activity is carried out for the purpose of issuing invoices in compliance with legal requirements and fulfilling the obligation to retain accounting records. Pursuant to Section 169 (1)–(2) of the Accounting Act, business entities are required to retain accounting documents that directly or indirectly support bookkeeping records.
Processed Data: name, address, email address, phone number.
Duration of Data Processing: Issued invoices must be retained for 8 years from the date of issuance pursuant to Section 169 (2) of the Accounting Act.
Legal Basis of Data Processing: The issuance of invoices is mandatory pursuant to Section 159 (1) of Act CXXVII of 2007 on Value Added Tax, and invoices must be retained for 8 years pursuant to Section 169 (2) of Act C of 2000 on Accounting.
[Processing based on Article 6(1)(c) of the Regulation – legal obligation]
Data Processing Related to Delivery of Goods
The purpose of this data processing activity is to deliver the ordered product.
Processed Data: name, address, email address, phone number.
Duration of Data Processing: The Data Controller processes the data until the delivery of the ordered goods is completed.
Legal Basis of Data Processing: Performance of a contract.
[Processing based on Article 6(1)(b) of the Regulation]
Technical and Log Data
Processed Data: IP address, browser type, device type, operating system, time of visit, page visit data.
Purpose of Data Processing: ensuring system security and proper operation.
Legal Basis of Data Processing: GDPR Article 6(1)(f) – legitimate interest.
Retention Period: up to 12 months.
Marketing and Remarketing Data
If the Data Controller intends to carry out additional data processing, prior information will be provided regarding the essential circumstances of such data processing (legal background and legal basis of the processing, purpose of processing, categories of processed data, and duration of processing).
Processed Data: viewed pages, click data, advertising identifiers, conversion data.
Legal Basis of Data Processing: GDPR Article 6(1)(a) – consent.
Within the territory of the European Union, remarketing activities are carried out exclusively on the basis of prior consent.
Automated Decision-Making and Profiling
The Data Controller does not apply automated decision-making – including profiling – during the processing of personal data that would produce legal effects concerning the data subject or similarly significantly affect them.
If the Data Controller intends to carry out such data processing activities in the future, the data subjects will be informed in advance by modifying this privacy notice.
International Data Transfers
The Data Controller operates in the United States; therefore, personal data originating from the European Union may be transferred to a third country.
Such data transfers are carried out in accordance with Chapter V of the GDPR, in particular Articles 44–49.
The legality of such transfers may be ensured by the following safeguards:
• the application of Standard Contractual Clauses (SCC) adopted by the European Commission (Article 46 GDPR), or
• compliance with the EU–US Data Privacy Framework (Article 45 GDPR), where applicable.
Data subjects have the right to request information regarding the safeguards applied to such data transfers.
Data Processors
The Data Controller may engage the following types of data processors:
• hosting service providers
• IT service providers
• email marketing service providers
• advertising platform providers
Data processors act on the basis of written agreements concluded with the Data Controller.
Rights of the Data Subject
During the period of data processing, you are entitled to the following rights: the right to request access, the right to request rectification, the right to request erasure, the right to request restriction of processing, the right to object, the right to data portability, the right to withdraw your consent, and the right to lodge a complaint with the competent supervisory authority.
The data subject may contact the EU supervisory authority of their place of residence.
If you wish to exercise your rights, this will require your identification, and the Data Controller will necessarily need to communicate with you. Therefore, for the purpose of identification, you may be required to provide certain personal data (however, identification may only be based on data that the Data Controller already processes about you). In addition, complaints related to data processing submitted by you will be available in the Data Controller’s email account within the period specified in this notice regarding complaints.
If you have previously placed an order with us and wish to identify yourself for the purpose of complaint handling or warranty administration, please also provide your order identification number. Using this information, we will be able to identify you as a customer.
The Data Controller will respond to complaints related to data processing within a maximum of 30 days.
Access to Personal Data
You have the right to obtain confirmation from the Data Controller as to whether or not your personal data is being processed. If such processing is taking place, you have the right to access the personal data being processed and to receive information from the Data Controller regarding the following:
• the purposes of the data processing;
• the categories of personal data processed concerning you;
• information about the recipients or categories of recipients with whom the personal data has been or will be shared by the Data Controller;
• the planned period for which the personal data will be stored, or if this is not possible, the criteria used to determine that period;
• your right to request from the Data Controller the rectification, erasure, or restriction of processing of personal data concerning you, and in the case of processing based on legitimate interest, the right to object to such processing; as well as the right to lodge a complaint with a supervisory authority;
• if the data was not collected from you, any available information regarding its source;
• the existence of automated decision-making (if such a procedure is applied), including profiling, and at least in such cases, meaningful information about the logic involved and the significance and expected consequences of such processing for you.
Purpose of Exercising the Right
The purpose of exercising this right may be to establish and verify the lawfulness of data processing. Therefore, in the case of repeated requests for information, the Data Controller may charge a reasonable fee for providing the requested information.
The Data Controller provides access to personal data by sending the processed personal data and related information to you via email after verifying your identity. If you have a registered account, access may also be provided by allowing you to view and verify the personal data processed about you by logging into your user account.
Please indicate in your request whether you are requesting access to your personal data or information related to the data processing.
Right to Rectification
You have the right to request that the Data Controller correct inaccurate personal data concerning you without undue delay.
Right to Restriction of Processing
You have the right to request that the Data Controller restrict the processing of your personal data if one of the following conditions applies:
• You contest the accuracy of the personal data. In this case, the restriction applies for a period that allows the Data Controller to verify the accuracy of the personal data. If the accuracy of the data can be verified immediately, the restriction will not be applied.
• The processing is unlawful, but you oppose the deletion of the data for any reason (for example, because the data is required for the establishment, exercise, or defense of legal claims). In such a case, instead of requesting the deletion of the data, you request the restriction of its use.
• The Data Controller no longer needs the personal data for the purposes of the processing, but you require the data for the establishment, exercise, or defense of legal claims.
• You have objected to the processing, but the legitimate interests of the Data Controller may justify the processing. In such cases, processing shall be restricted until it is determined whether the legitimate grounds of the Data Controller override your legitimate interests.
If processing is restricted, such personal data may only be processed – with the exception of storage – with the consent of the data subject, or for the establishment, exercise, or defense of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest.
The Data Controller will inform you in advance of the lifting of the restriction of processing (at least 3 business days before the restriction is lifted).
Right to Erasure – Right to be Forgotten
You have the right to request that the Data Controller erase personal data concerning you without undue delay if one of the following grounds applies:
• the personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
• you withdraw your consent and there is no other legal basis for the processing;
• you object to processing based on legitimate interest and there are no overriding legitimate grounds for the processing;
• the personal data has been processed unlawfully and this has been established based on a complaint;
• the personal data must be erased in order to comply with a legal obligation under applicable law.
If the Data Controller has made the personal data concerning you public for any lawful reason and is required to erase it for any of the reasons listed above, the Data Controller shall, taking into account available technology and the cost of implementation, take reasonable steps – including technical measures – to inform other data controllers processing the data that you have requested the deletion of any links to, or copies or replications of, the personal data concerned.
The right to erasure shall not apply where processing is necessary:
▪ for exercising the right of freedom of expression and information;
▪ for compliance with a legal obligation requiring processing under applicable law (for example, data processed for invoicing purposes where the retention of invoices is required by law), or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
▪ for the establishment, exercise, or defense of legal claims (for example, if the Data Controller has an outstanding claim against you that has not yet been fulfilled, or if a consumer or data protection complaint is in progress).
Right to Data Portability
If the processing of personal data is carried out by automated means or if the processing is based on your voluntary consent, you have the right to request that the Data Controller provide you with the data that you have supplied to the Data Controller. The Data Controller will provide this data to you in XML, JSON, or CSV format. Where technically feasible, you may also request that the Data Controller transmit this data in such format directly to another data controller.
Right to Withdraw Consent
You have the right to withdraw your consent to data processing at any time. In such cases, the provided data will be deleted from our systems. Please note, however, that if an order has not yet been fulfilled, the withdrawal of consent may result in our inability to complete the delivery to you.
Furthermore, if a purchase has already been completed, we may not delete invoicing-related data from our systems due to accounting regulations. In addition, if you have an outstanding debt to us, we may continue to process your data based on our legitimate interest related to the enforcement of claims, even after the withdrawal of consent.
Right to Object
You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data based on legitimate interests. In such a case, the Data Controller shall no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
Where personal data is processed for the purposes of direct marketing, you have the right to object at any time to the processing of your personal data for such purposes, including profiling to the extent that it is related to such direct marketing. If you object to the processing of personal data for direct marketing purposes, the personal data shall no longer be processed for such purposes.
Data Security Measures and Submission of Complaints
The Data Controller declares that it has implemented appropriate security measures to protect personal data against unauthorized access, alteration, transmission, disclosure, deletion, or destruction.
Within the limits of its organizational and technical capabilities, the Data Controller takes all reasonable steps to ensure that its data processors also implement appropriate data security measures when processing your personal data.
If you believe that the Data Controller has violated any legal provisions related to data processing or has failed to comply with any of your requests, you may contact the EU supervisory authority of your place of residence in order to initiate the termination of the presumed unlawful data processing.
You are also informed that in the event of a violation of legal provisions related to data processing, or if the Data Controller fails to comply with any of your requests, you may initiate civil proceedings against the Data Controller before a court.
Modification of the Privacy Notice
The Data Controller reserves the right to modify this privacy notice, provided that such modification does not affect the purpose or legal basis of the data processing. By continuing to use the website after the modification enters into force, you accept the amended privacy notice.
If the Data Controller intends to process the collected data for a purpose different from the purpose for which it was originally collected, you will be informed in advance about the purpose of the new processing and the following information:
▪ the period for which the personal data will be stored, or if this is not possible, the criteria used to determine that period; and your right to request access to your personal data, rectification, erasure, or restriction of processing, and in the case of processing based on legitimate interest, your right to object to such processing;
▪ where processing is based on consent or a contractual relationship, your right to request the right to data portability;
▪ where processing is based on consent, your right to withdraw consent at any time, and your right to lodge a complaint with a supervisory authority;
▪ whether the provision of personal data is based on a legal or contractual obligation or is a prerequisite for entering into a contract, and whether you are obliged to provide the personal data, as well as the possible consequences of failing to provide such data.
Data processing may only begin after this information has been provided, and where the legal basis of the processing is consent, your consent must also be given in addition to receiving this information.
