Privacy Policy

including our Consumer Health Data Privacy Notice

Operated by ClientValley OÜ (Estonia)

Last Updated: 15 July 2026 · Effective Date: 15 July 2026

EELO IS A SELF-HELP WELLNESS APP. IT IS NOT A HEALTHCARE PROVIDER, AND WE ARE NOT A COVERED ENTITY OR BUSINESS ASSOCIATE UNDER HIPAA. THE INFORMATION YOU ENTER IS NOT PROTECTED HEALTH INFORMATION UNDER HIPAA. IT IS, HOWEVER, SENSITIVE, AND WE TREAT IT AS CONSUMER HEALTH DATA UNDER APPLICABLE UNITED STATES STATE LAW.

1. Introduction

This Privacy Policy explains how ClientValley OÜ ("EELO," "we," "us," or "our") collects, uses, shares, and protects information about you when you use the EELO application and related services (the "Service").

EELO is currently offered only to adults aged 18 or over who are located in the United States.

This Privacy Policy also serves as our Consumer Health Data Privacy Notice for the purposes of the Washington My Health My Data Act, the Nevada consumer health data law, and comparable laws. Section 6 addresses consumer health data specifically.

2. Who We Are and How to Contact Us

The controller of your personal information is:

ClientValley OÜ, a private limited company registered in Estonia, operating the product EELO.

14802223

Tallinn, Estonia

eeloocd@gmail.com

We have not appointed a Data Protection Officer. If we are required to appoint one, or choose to, we will update this Policy with their contact details.

3. A Summary of Our Approach

• We collect the minimum we need to run the Service.
• Where end-to-end encryption is applied, the content of your entries is encrypted on your device, and we cannot read it.
• We do not sell your personal information, and we do not share it for cross-context behavioral advertising.
• We do not use your health-related entries to train advertising profiles, and we do not disclose them to advertisers or data brokers.
• You can request access to, correction of, or deletion of your information at any time.

4. Information We Collect

4.1 Information you provide directly.

• Account information: your email address, and your password or authentication credentials. If you sign in with a third-party provider such as Apple or Google, we receive the identifiers that provider shares with us.
• Practice content (consumer health data): the fears, triggers, habits, challenges, steps, notes, written reflections, distress or intensity ratings, completion records, timestamps, and other content you enter when using the Service. This content can reveal information about your mental health, so we treat it as sensitive.
• Support communications: information you send us when you contact support, provide feedback, or report a problem.

4.2 Information collected automatically.

• Device and technical data: device type, operating system and version, browser type, language, and general technical diagnostics.
• Usage data: app version, feature usage, session activity, crash and error logs, and performance data.
• Approximate location: derived from your IP address, used for security, fraud prevention, and to confirm that the Service is being used in a jurisdiction where we offer it. We do not collect precise GPS location.

4.3 Payment information.

Subscriptions are processed by third-party payment providers or by the app store through which you purchase. We do not collect or store your full payment card number. We receive limited transaction data, such as subscription status, plan, renewal date, and an anonymized transaction or receipt identifier.

Apple App Store (Apple Inc.) and RevenueCat, Inc.

4.4 Information we do not collect.

• We do not collect information from anyone we know to be under 18.
• We do not collect precise geolocation.
• We do not collect biometric identifiers.
• We do not purchase personal information from data brokers.

5. End-to-End Encryption, and Why We Cannot See Your Answers

Your practice content is end-to-end encrypted. It is encrypted on your own device, using a key derived from your credentials, before it is transmitted to or stored on our infrastructure.

WE CANNOT SEE YOUR ANSWERS. WE CANNOT READ, DECRYPT, ACCESS, REVIEW, MONITOR, ANALYZE, RESTORE, OR RECOVER THE CONTENT YOU ENTER, AND NO EMPLOYEE, CONTRACTOR, OR ADMINISTRATOR OF CLIENTVALLEY OÜ CAN DO SO. OUR SERVICE PROVIDERS HOLD ONLY ENCRYPTED DATA THAT THEY CANNOT READ. WE COULD NOT PRODUCE YOUR CONTENT IN READABLE FORM EVEN IF WE WERE ASKED OR LEGALLY COMPELLED TO DO SO.

Because we cannot read your entries, we also cannot detect distress, risk, or crisis in them, and we cannot intervene. EELO is not monitored and is not an emergency service.

5.1 Your recovery code.

Because the encryption key is derived from credentials only you hold, EELO issues you a recovery code when you set up encryption. It is the only way to regain access to your encrypted content if you forget your password or lose access to your device. You must store it somewhere safe, offline, and private.

WE DO NOT HOLD OR STORE YOUR RECOVERY CODE OR YOUR ENCRYPTION KEY, AND WE CANNOT RETRIEVE, RESET, OR REISSUE THEM. IF YOU LOSE BOTH YOUR PASSWORD AND YOUR RECOVERY CODE, YOUR ENCRYPTED CONTENT IS PERMANENTLY AND IRREVERSIBLY LOST, AND CANNOT BE RECOVERED BY US, BY YOU, OR BY ANYONE ELSE. THIS IS THE INTENDED CONSEQUENCE OF ENCRYPTION THAT PROTECTS YOUR PRIVACY, NOT A DEFECT.

Anyone you give your recovery code to may be able to read all of your content. Keep it private.

5.2 What is not encrypted in this way.

Some information must remain readable to us in order to run the Service, and is therefore not end-to-end encrypted. This includes your email address, your authentication data, your subscription status, and technical and diagnostic logs. This information is still protected by encryption in transit and at rest, and by access controls.

6. Consumer Health Data Privacy Notice

This section applies to "consumer health data" as defined by the Washington My Health My Data Act, the Nevada consumer health data law, and comparable United States state laws. It applies to all users, and it applies specifically to residents of Washington and Nevada.

6.1 What consumer health data we collect.

The practice content described in Section 4.1, including the fears, triggers, habits, challenges, reflections, distress ratings, and completion records you enter, together with the fact that you use a mental wellness application at all, may constitute consumer health data because it can reveal information about your mental health status or your attempts to seek mental wellness support.

6.2 How we collect it.

We collect consumer health data only when you voluntarily enter it into the Service, or when it is generated by your use of features you choose to use. We do not collect consumer health data from any third party, and we do not infer health data from data brokers or from external sources.

6.3 Why we collect it.

• To provide the core functionality of the Service to you, that is, to store and display your own entries back to you and to track your own progress.
• To operate, secure, maintain, and troubleshoot the Service.
• For no other purpose, unless we obtain your separate, specific, informed consent first.

6.4 Who we share it with.

WE DO NOT SELL CONSUMER HEALTH DATA. WE DO NOT SHARE CONSUMER HEALTH DATA FOR ADVERTISING, MARKETING, PROFILING, OR ANY CROSS-CONTEXT BEHAVIORAL ADVERTISING PURPOSE. WE DO NOT DISCLOSE IT TO DATA BROKERS.

The only parties that may process consumer health data are our infrastructure service providers, acting solely as processors under contract and solely to host and operate the Service on our behalf. They are listed in Section 8. Where end-to-end encryption is applied, those providers hold only encrypted data that they cannot read.

We may also disclose data where required by law, as described in Section 8.3.

6.5 Your consumer health data rights.

You have the right to:

• Confirm whether we are collecting, sharing, or selling your consumer health data, and to access that data.
• Obtain a list of all third parties with whom we have shared your consumer health data.
• Withdraw your consent to the collection and sharing of your consumer health data.
• Have your consumer health data deleted, including from our archives and backups, subject to the technical limits described in Section 10 and to any legal retention obligation.

To exercise these rights, contact us at the privacy contact address in Section 2. We will not discriminate against you for exercising them. You may appeal a denial, and if your appeal is denied, you may contact your state Attorney General.

6.6 Separate Consumer Health Data Privacy Policy. This Section 6 is our Consumer Health Data Privacy Policy for the purposes of the Washington My Health My Data Act and comparable laws. We link to it separately and conspicuously from the general Privacy Policy wherever the Washington My Health My Data Act requires, we collect consumer health data only after you have provided valid consent, and we will obtain a separate, specific authorization from you before any sale of consumer health data (we do not sell it). You have a private right of action under the Washington My Health My Data Act if we fail to comply.

7. How We Use Information, and Our Legal Bases

We use information for the following purposes, and, where the EU General Data Protection Regulation applies to our processing, on the following legal bases:

• To provide the Service and perform our contract with you. Legal basis: performance of a contract.
• To process your consumer health data and other special category data. Legal basis: your explicit consent, which you may withdraw at any time. Withdrawing consent means we can no longer provide the core features of the Service to you.
• To authenticate you, secure accounts, and prevent fraud, abuse, and unauthorized access. Legal basis: legitimate interests and legal obligation.
• To operate, maintain, debug, and improve the Service, using aggregated or de-identified data wherever possible. Legal basis: legitimate interests.
• To process payments and manage subscriptions. Legal basis: performance of a contract and legal obligation.
• To communicate with you about the Service, including service messages and support. Legal basis: performance of a contract and legitimate interests.
• To send marketing communications, only if you have opted in. Legal basis: consent. You may opt out at any time.
• To comply with law and to establish, exercise, or defend legal claims. Legal basis: legal obligation and legitimate interests.

WE DO NOT USE YOUR PRACTICE CONTENT TO TRAIN ARTIFICIAL INTELLIGENCE OR MACHINE LEARNING MODELS, AND WE DO NOT USE IT FOR ADVERTISING, PROFILING, OR AUTOMATED DECISION-MAKING THAT PRODUCES LEGAL OR SIMILARLY SIGNIFICANT EFFECTS.

7.1 A note on artificial intelligence.

Artificial intelligence tools were used to help build EELO, including to help write its software and its educational content. This is a fact about how the product was made. It is not a description of how your data is processed.

YOUR ENTRIES ARE NOT SENT TO ANY ARTIFICIAL INTELLIGENCE SYSTEM, ARE NOT USED TO TRAIN ANY MODEL, AND ARE NOT ANALYZED BY ANY MODEL. THEY ARE END-TO-END ENCRYPTED, AND WE CANNOT READ THEM, SO WE COULD NOT SUBMIT THEM TO SUCH A SYSTEM EVEN IF WE WANTED TO.

Because AI tools were used to create the content of the app, that content may contain errors or inaccuracies. Please see our Terms of Service, which explains this and disclaims reliance on it.

8. How We Share Information

8.1 We do not sell your information.

WE DO NOT SELL YOUR PERSONAL INFORMATION, AND WE DO NOT SHARE IT FOR CROSS-CONTEXT BEHAVIORAL ADVERTISING, AS THOSE TERMS ARE DEFINED UNDER CALIFORNIA AND OTHER UNITED STATES STATE PRIVACY LAWS. WE HAVE NOT DONE SO IN THE PRECEDING TWELVE MONTHS.

8.2 Service providers (processors).

We share information with vendors that process it on our behalf, under contract, and only on our instructions:

• Supabase (Supabase, Inc.): authentication, database, file storage, and server functions. Processes your email address, authentication data, encrypted user content, wrapped encryption keys, and subscription status. Hosted in the United States (US East region).

• Netlify (Netlify, Inc.): web hosting for our website and application assets. Processes standard web-server log data such as IP address and request metadata. Served from a global content delivery network with primary infrastructure in the United States.

• Resend (Resend, Inc.): transactional email, such as account-confirmation and password-reset messages. Processes your email address and email delivery metadata. Hosted in the United States.

• Apple (Apple Inc.): app distribution, in-app purchases, and subscription billing, acting as merchant of record, and, where you use Sign in with Apple, authentication. Processes purchase and subscription records and, for Sign in with Apple, your name and email address or Apple private-relay address. Operated on Apple infrastructure in the United States and globally.

• Google (Google LLC): authentication, where you choose Sign in with Google. Processes your name, email address, and Google account identifier. Hosted in the United States.

• RevenueCat (RevenueCat, Inc.): management of subscription status and entitlements. Processes an app user identifier, subscription and entitlement status, and purchase receipts. Hosted in the United States.

• Porkbun (Porkbun LLC): domain registration and DNS. Processes domain and DNS records only, not user content. Located in the United States.

We do not use any third-party analytics, advertising, or crash-reporting services. If we add one in the future, we will update this list before or when we begin using it.

8.3 Legal and safety disclosures.

We may disclose information if we believe in good faith that disclosure is reasonably necessary to: comply with a law, regulation, legal process, or governmental request; enforce our Terms of Service; detect, prevent, or address fraud, security, or technical issues; or protect the rights, property, or safety of ClientValley OÜ, our users, or the public. Where encryption prevents us from reading content, we cannot produce that content in readable form.

8.4 Business transfers.

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will require the recipient to honor this Privacy Policy, or we will give you notice and an opportunity to delete your information before it becomes subject to a materially different policy.

8.5 Aggregated and de-identified data.

We may create and use aggregated or de-identified data that cannot reasonably be used to identify you. We will not attempt to re-identify it, and we will require others not to.

9. Retention

We retain personal information only as long as necessary for the purposes described in this Policy:

• Account and practice content: for as long as your account is active.
• After you delete your account: we retain your personal information for as long as your account is active. When you delete your account, we delete or de-identify your personal information within a commercially reasonable period, except where we must retain it to comply with law, resolve disputes, or enforce our agreements.
• Backups: residual copies may persist in our routine encrypted backups for a limited period after deletion, in the ordinary course of backup rotation, after which they are overwritten.
• Billing records: retained as required by tax and accounting law, generally seven (7) years under Estonian law.

10. Deletion

You may delete your account and your data at any time from within the app, or by contacting us. Deletion is permanent and irreversible.

Please note that deleting the app from your device does not delete your account or your data. You must use the deletion feature or contact us.

11. Security

We implement technical and organizational measures designed to protect your information, including encryption in transit, encryption at rest, end-to-end encryption for practice content where applied, access controls, and least-privilege access for personnel.

HOWEVER, NO METHOD OF TRANSMISSION OR STORAGE IS COMPLETELY SECURE. WE CANNOT AND DO NOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR INFORMATION. YOU USE THE SERVICE AT YOUR OWN RISK, AND YOU ARE RESPONSIBLE FOR SAFEGUARDING YOUR CREDENTIALS, RECOVERY CODE, AND DEVICE.

If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority and, where required, you, in accordance with applicable law.

12. Your Privacy Rights

12.1 Rights available to all users.

• Access: request a copy of the personal information we hold about you.
• Correction: request that we correct inaccurate information.
• Deletion: request that we delete your information.
• Portability: request a copy in a portable, machine-readable format.
• Withdraw consent: withdraw consent to processing that is based on consent, including our processing of your consumer health data.
• Object or restrict: object to or request restriction of certain processing.
• Opt out of marketing: unsubscribe at any time.
• Non-discrimination: we will not deny you service, charge you a different price, or provide a different quality of service because you exercised a privacy right.

To exercise any right, contact us at the privacy contact address in Section 2. We will verify your identity, usually by confirming control of the email address associated with your account, and we will respond within the period required by applicable law. You may use an authorized agent where the law permits.

12.2 United States state privacy rights.

If you are a resident of California, Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, or another state with a comprehensive privacy law, you have the rights listed above, together with the right to appeal a refusal and the right to lodge a complaint with your state Attorney General.

Under the California Consumer Privacy Act, as amended, we disclose that: the categories of personal information we collect are identifiers, commercial information (subscription status), internet or network activity, approximate geolocation, and sensitive personal information (health-related content); we collect it for the business purposes described in Section 7; we obtain it from you and from your use of the Service; we disclose it only to the service providers described in Section 8.2; and we do not sell it or share it for cross-context behavioral advertising.

We use and disclose sensitive personal information only for the purposes permitted under applicable law, that is, to provide the Service you requested, and not for inferring characteristics about you.

12.3 Rights under the GDPR.

Because we are established in Estonia, the EU General Data Protection Regulation may apply to our processing. Where it does, you have the rights described in Section 12.1, and you have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or with your local supervisory authority.

13. International Transfers

We are established in Estonia, and our service providers may be located in the United States and elsewhere. This means your information may be transferred to, stored in, and processed in countries other than the one in which you live, including countries whose data protection laws may differ from those of your jurisdiction.

Where such transfers are subject to the GDPR, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses, or on an applicable adequacy decision.

Where personal information is transferred outside your country, we rely on appropriate safeguards for that transfer, including the European Commission's Standard Contractual Clauses and equivalent data-protection terms in our agreements with our service providers.

14. Cookies and Similar Technologies

We use only the storage and cookies necessary to operate the Service, such as keeping you signed in and remembering your settings. We do not use advertising cookies or third-party advertising trackers.

[UPDATE if you add analytics, attribution, or advertising SDKs. If you do, you will need a cookie or tracking consent mechanism, and you will need to update Sections 4, 7, 8, and 12.]

15. Children

EELO is strictly for adults aged 18 and over. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected information from someone under 18, we will delete it promptly. If you believe a minor has provided us with personal information, contact us immediately.

16. HIPAA Does Not Apply

We are not a healthcare provider, health plan, or healthcare clearinghouse, and we are not a business associate of any such entity. The Health Insurance Portability and Accountability Act (HIPAA) does not apply to EELO, and the information you enter is not protected health information under HIPAA. This does not reduce our commitment to protecting your information as described in this Policy, and it does not affect your rights under the state consumer health data laws described in Section 6.

17. Third-Party Resources and Links

EELO may link to third-party crisis lines, directories, or websites. Those third parties have their own privacy policies, and we are not responsible for their practices. If you contact a third-party resource, any information you give them is governed by their policy, not by ours.

18. Changes to This Policy

We may update this Privacy Policy from time to time. If we make a material change, we will provide notice, for example by in-app notice or by email, before it takes effect. Where a change requires your consent under applicable law, we will obtain that consent. The "Last Updated" date at the top shows when this Policy was last revised.

19. Contact and Complaints

To exercise a right, ask a question, or make a complaint, contact us at:

ClientValley OÜ

Tallinn, Estonia

eeloocd@gmail.com

If you are not satisfied with our response, you may lodge a complaint with the Estonian Data Protection Inspectorate, or with your state Attorney General if you are a United States resident.

Terms of Service

Operated by ClientValley OÜ (Estonia)

Last Updated: 15 July 2026 · Effective Date: 15 July 2026

1. Agreement to These Terms

These Terms of Service (the "Terms") form a legally binding agreement between you ("you," "your," or "User") and ClientValley OÜ, a private limited company (osaühing) registered in the Republic of Estonia, which operates the EELO mobile and web application and all related content, features, and services (together, "EELO" or the "Service"). References to "we," "us," or "our" mean ClientValley OÜ.

By creating an account, starting a free trial, purchasing a subscription, downloading, accessing, or otherwise using EELO in any way, you acknowledge that you have read, understood, and agree to be bound by these Terms and by our Privacy Policy, which is incorporated into these Terms by reference. If you do not agree to these Terms, you must not access or use the Service.

If you are entering into these Terms on behalf of a company or other legal entity, you represent that you have the authority to bind that entity to these Terms.

2. Who We Are

The Service is provided by:

• Legal entity: ClientValley OÜ
• Trading name / product: EELO

14802223

Tallinn, Estonia

eeloocd@gmail.com

eeloocd@gmail.com

3. Eligibility

You may use EELO only if all of the following are true. By using EELO, you represent and warrant that:

• You are at least eighteen (18) years of age. EELO is strictly an adult service. We do not knowingly permit anyone under 18 to create an account or use the Service.
• You are a resident of, and physically located in, the United States. EELO is currently offered only in the United States. We make no representation that the Service is appropriate, lawful, or available for use in any other jurisdiction. If you access EELO from outside the United States, you do so on your own initiative and at your own risk, and you are solely responsible for compliance with local law.
• You have the legal capacity to enter into a binding contract.
• You have not previously been suspended or removed from the Service.
• You are not barred from using the Service under any applicable law.

We reserve the right, but assume no obligation, to verify eligibility and to suspend or terminate any account we reasonably believe belongs to a person under 18, to a person outside the United States, or to a person who has misrepresented their eligibility.

4. Health and Safety Disclaimers

4.1 EELO is a self-help wellness tool, not healthcare.

EELO provides self-guided educational content and structured self-help exercises inspired by principles commonly described in the self-help literature, including gradual, self-directed practice of facing avoided situations and choosing not to act on urges. EELO is intended solely for general wellness, self-reflection, and personal development purposes. It is not medical care, mental health care, psychotherapy, counseling, psychiatric care, crisis intervention, or treatment of any kind.

4.2 EELO does not diagnose, treat, cure, prevent, or manage any condition.

Nothing in EELO diagnoses, treats, cures, mitigates, prevents, or manages obsessive compulsive disorder, anxiety, depression, or any other disease, disorder, illness, or medical or mental health condition. Any educational content that describes such conditions is provided for general informational purposes only. It is not a diagnosis, a clinical assessment, or a treatment plan, and it must not be relied upon as any of those things.

4.3 EELO is not a medical device.

EELO is intended as a general wellness product. It is not intended to be, and must not be used as, a medical device or as a substitute for a medical device, and it has not been evaluated, cleared, or approved by the United States Food and Drug Administration or by any other regulatory authority.

4.4 EELO was not created by healthcare professionals.

EELO WAS NOT DESIGNED, WRITTEN, REVIEWED, VALIDATED, TESTED, OR APPROVED BY PHYSICIANS, PSYCHIATRISTS, PSYCHOLOGISTS, THERAPISTS, COUNSELORS, OR ANY OTHER LICENSED HEALTHCARE OR MENTAL HEALTH PROFESSIONALS. NO LICENSED CLINICIAN HAS REVIEWED ITS CONTENT, ITS EXERCISES, ITS METHODS, OR THEIR SUITABILITY FOR YOU OR FOR ANYONE ELSE.

EELO has not been subjected to any clinical trial, clinical validation, peer review, or regulatory review of any kind. You must not assume that anything in EELO reflects clinical best practice, professional consensus, or a standard of care.

4.5 EELO was built with the assistance of artificial intelligence, and it may contain errors or misinformation.

PORTIONS OF EELO, INCLUDING ITS SOFTWARE, ITS TEXT, ITS EXERCISES, AND ITS EDUCATIONAL CONTENT, WERE CREATED WITH THE ASSISTANCE OF ARTIFICIAL INTELLIGENCE TOOLS. CONTENT PRODUCED WITH THE HELP OF ARTIFICIAL INTELLIGENCE CAN BE INACCURATE, INCOMPLETE, OUTDATED, MISLEADING, OR SIMPLY WRONG, AND IT CAN STATE INCORRECT INFORMATION CONFIDENTLY.

EELO MAY THEREFORE CONTAIN FACTUAL ERRORS AND MISINFORMATION, INCLUDING IN ITS EDUCATIONAL MATERIAL AND IN ANY DESCRIPTION OF PSYCHOLOGICAL CONCEPTS, MENTAL HEALTH CONDITIONS, OR SELF-HELP TECHNIQUES. DO NOT TREAT ANY STATEMENT IN EELO AS ACCURATE, AUTHORITATIVE, CURRENT, OR APPLICABLE TO YOU. VERIFY ANYTHING THAT MATTERS WITH A QUALIFIED PROFESSIONAL BEFORE ACTING ON IT. WE DISCLAIM ALL LIABILITY FOR ANY INACCURACY, ERROR, OMISSION, OR MISINFORMATION IN THE SERVICE, AND FOR ANY RELIANCE YOU PLACE ON IT.

4.6 EELO does not replace therapy or professional help.

EELO IS NOT A SUBSTITUTE FOR THERAPY, COUNSELING, PSYCHOTHERAPY, PSYCHIATRIC CARE, MEDICATION, OR ANY OTHER FORM OF PROFESSIONAL HELP, AND IT MUST NEVER BE USED AS ONE. IT IS NOT AN ALTERNATIVE TO SEEING A THERAPIST, PSYCHOLOGIST, PSYCHIATRIST, OR PHYSICIAN.

IF YOU NEED HELP, SEEK A QUALIFIED PROFESSIONAL. DO NOT USE EELO INSTEAD OF SEEKING PROFESSIONAL HELP, AND DO NOT DELAY, REDUCE, INTERRUPT, OR STOP PROFESSIONAL CARE BECAUSE YOU ARE USING EELO.

4.7 Self-directed facing-fear exercises are not a substitute for professionally guided care.

The structured practice EELO supports is loosely inspired by the general, widely described principle of gradually approaching what you avoid while choosing not to act on the urge to escape or neutralize. When work of this kind is delivered as part of professional care, it is normally assessed, planned, paced, supervised, and adjusted by a trained clinician who knows your history and responds to how you react.

EELO PROVIDES NO ASSESSMENT, NO SUPERVISION, NO CLINICAL PACING, AND NO CLINICAL JUDGMENT OF ANY KIND. SELF-DIRECTED PRACTICE THROUGH AN APP IS NOT EQUIVALENT TO PROFESSIONALLY GUIDED CARE, DOES NOT REPLACE IT, AND MAY BE LESS EFFECTIVE, LESS SAFE, OR MORE DISTRESSING THAN IT. IF YOU WISH TO UNDERTAKE THIS KIND OF WORK, YOU SHOULD DO SO WITH A QUALIFIED THERAPIST OR PSYCHOLOGIST.

4.8 No professional relationship is created.

Your use of EELO does not create a doctor-patient, therapist-client, counselor-client, or any other professional or fiduciary relationship between you and ClientValley OÜ, or between you and any of our officers, employees, contractors, advisors, or content contributors. No individual involved in creating EELO is acting as your clinician.

4.9 EELO is not an emergency service.

EELO IS NOT MONITORED IN REAL TIME. WE DO NOT REVIEW USER ENTRIES, AND WE HAVE NO ABILITY TO DETECT, RESPOND TO, INTERVENE IN, OR ESCALATE ANY CRISIS, EMERGENCY, OR RISK OF HARM. DO NOT USE EELO TO COMMUNICATE ANY EMERGENCY. IF YOU ARE EXPERIENCING A MEDICAL OR MENTAL HEALTH EMERGENCY, ARE THINKING ABOUT SUICIDE OR SELF-HARM, OR BELIEVE YOU MAY HARM ANOTHER PERSON, IMMEDIATELY CALL 988, CALL 911, OR GO TO THE NEAREST EMERGENCY ROOM.

4.10 Consult a qualified professional.

You should consult a licensed physician, psychiatrist, psychologist, therapist, or other qualified healthcare professional before beginning EELO, before making any decision about your health or care, and before starting, stopping, or changing any treatment, medication, or therapy. Never disregard professional medical advice, or delay seeking it, because of anything you have read, seen, or done in EELO.

4.11 Assumption of risk: distress is a foreseeable part of this kind of practice.

You understand and expressly acknowledge that self-directed practice of the kind EELO supports intentionally involves approaching situations, thoughts, images, sensations, or feelings that you find uncomfortable or distressing, and intentionally not performing the behaviors you would normally use to relieve that discomfort.

You understand that this can, and often does, temporarily increase anxiety, fear, distress, discomfort, intrusive thoughts, urges, physical symptoms, emotional upset, or a sense of things getting worse before they get better. You further understand that outcomes vary from person to person, that symptoms may not improve, that symptoms may worsen, and that worsening may be prolonged or severe. You accept all of these risks knowingly and voluntarily.

You are solely responsible for deciding whether, when, how far, and how fast to practice, for the specific content of any challenge you create, and for stopping at any time. EELO does not and cannot assess whether any challenge you write is safe, suitable, or appropriate for you.

4.12 Do not use EELO in these circumstances.

You must not use EELO, and you should seek professional help instead, if any of the following applies to you:

• You are experiencing a mental health crisis, or you are thinking about suicide, self-harm, or harming another person.
• You are experiencing psychosis, hallucinations, delusions, mania, or a loss of contact with reality.
• You are experiencing severe depression, severe anxiety, or severe distress that impairs your ability to function or to make safe decisions.
• You are experiencing symptoms related to trauma, or your urges relate to real danger to yourself or to anyone else.
• You have a substance use disorder or an eating disorder, or your urges relate to restricting food, purging, self-injury, or substance use.
• You are under the care of a healthcare professional who has advised against this kind of self-directed practice, or you have not consulted your professional about using EELO alongside your care.
• You are unable to give informed, voluntary consent to your own participation.

If any of the above becomes true while you are using EELO, you must stop using the Service and seek professional support.

4.13 Third-party crisis and support resources.

EELO may display or link to third-party crisis lines, helplines, directories, organizations, websites, or other support resources. These are provided for convenience and general information only.

WE DO NOT OPERATE, CONTROL, ENDORSE, VET, SUPERVISE, OR GUARANTEE ANY THIRD-PARTY RESOURCE. WE DO NOT GUARANTEE THAT ANY SUCH RESOURCE WILL BE AVAILABLE, WILL RESPOND, WILL RESPOND IN TIME, WILL BE ACCURATE, WILL BE COMPETENT, WILL BE APPROPRIATE FOR YOU, OR WILL PROVIDE ANY HELP, BENEFIT, OR OUTCOME OF ANY KIND. WE ARE NOT RESPONSIBLE OR LIABLE FOR ANY ACT, OMISSION, DELAY, FAILURE, ADVICE, CONDUCT, OR OUTCOME OF ANY THIRD-PARTY RESOURCE, OR FOR ANY CONSEQUENCE OF YOUR CONTACTING OR FAILING TO CONTACT ONE. YOUR USE OF ANY THIRD-PARTY RESOURCE IS ENTIRELY AT YOUR OWN RISK AND IS A MATTER SOLELY BETWEEN YOU AND THAT THIRD PARTY.

4.14 Progress, scores, and tracking have no meaning outside the app.

EELO may display progress indicators, completion counts, streaks, steps climbed, distress or intensity ratings, charts, summaries, and similar features. These are generated solely from what you yourself type or tap inside the app.

THESE FIGURES ARE SELF-REPORTED, SUBJECTIVE, AND UNVALIDATED. THEY ARE NOT A CLINICAL MEASURE, NOT A DIAGNOSTIC TOOL, NOT A PSYCHOMETRIC INSTRUMENT, AND NOT AN ASSESSMENT OF ANY KIND. THEY MEASURE ONLY YOUR ACTIVITY AND YOUR OWN RATINGS WITHIN THIS APP.

PROGRESS SHOWN IN EELO DOES NOT MEAN, INDICATE, DEMONSTRATE, OR PREDICT ANY ACTUAL IMPROVEMENT, RECOVERY, OR CHANGE IN YOUR CONDITION, SYMPTOMS, WELLBEING, OR FUNCTIONING IN REAL LIFE OUTSIDE OF THE APP. A HIGH SCORE, A COMPLETED LADDER, OR A FALLING DISTRESS RATING PROVES NOTHING ABOUT YOUR HEALTH. EQUALLY, A LOW SCORE OR A LACK OF PROGRESS IN THE APP MEANS NOTHING ABOUT YOU. YOU MUST NOT USE ANY IN-APP FIGURE TO ASSESS YOUR OWN CONDITION, TO EVALUATE YOUR PROGRESS, OR TO MAKE ANY DECISION ABOUT YOUR HEALTH OR YOUR CARE.

Do not present any in-app figure to a clinician as if it were a clinical measurement, and do not rely on it in place of a proper professional assessment.

4.15 No guarantee of results.

We make no promise, representation, warranty, or guarantee of any kind that EELO will produce any particular result, improvement, reduction in symptoms, benefit, or outcome, or that it will work for you at all. Any testimonial, example, story, statistic, or illustration is not a guarantee and is not typical of results any individual should expect.

4.16 You are responsible for your own choices.

YOU ALONE ARE RESPONSIBLE FOR YOUR DECISIONS, YOUR ACTIONS, YOUR INACTIONS, YOUR BEHAVIOR, AND THEIR CONSEQUENCES, INCLUDING ANY DECISION TO ATTEMPT, CONTINUE, OR STOP ANY CHALLENGE OR EXERCISE, ANY DECISION TO SEEK OR NOT TO SEEK PROFESSIONAL HELP, AND ANY DECISION TO START, STOP, OR CHANGE ANY TREATMENT, MEDICATION, OR THERAPY. WE ACCEPT NO RESPONSIBILITY AND NO ACCOUNTABILITY FOR YOUR CHOICES OR FOR ANY OUTCOME ARISING FROM THEM.

5. The Service

EELO provides self-guided tools that may include, without limitation, structured step-by-step self-help exercises, in-the-moment coping exercises such as breathing and grounding, self-tracking and reflection features, and educational content.

EELO is under active development. We may add, change, suspend, limit, or remove any feature, content, or functionality at any time, with or without notice. We do not warrant that any particular feature or piece of content will remain available.

6. Your Account

• You must provide accurate and complete information and keep it up to date.
• You are solely responsible for maintaining the confidentiality of your login credentials, recovery code, passphrase, and device security.
• You are solely responsible for all activity that occurs under your account.
• You must notify us immediately of any unauthorized access to or use of your account.
• You may not share your account, sell it, transfer it, or allow anyone else to use it.

We are not liable for any loss or damage arising from your failure to safeguard your account, credentials, recovery code, or device.

7. Subscriptions, Free Trials, Billing, and Cancellation

7.1 Plans and pricing.

EELO offers paid subscription plans. Current plans, prices, billing periods, and trial terms are disclosed to you at the point of purchase and are incorporated into these Terms. Prices are stated in United States dollars and exclude any applicable taxes unless stated otherwise.

Current plans and prices (United States). As of the Effective Date, EELO offers the following auto-renewing subscription plans. Prices are in United States dollars and exclude any applicable taxes. The price, billing period, and trial terms applicable to you are also shown at the point of purchase before you buy, and those point-of-purchase terms control if they ever differ from the list below:

• Annual plan: $44.99 per year, following a 3-day free trial for new subscribers.

• Monthly plan: $15.99 per month, following a 3-day free trial for new subscribers.

• Weekly plan: $7.99 per week. The weekly plan does not include a free trial.

The 3-day free trial is available only on the Annual and Monthly plans, is limited to one per person and per Apple ID, and is not available on the Weekly plan. If you begin a free trial and do not cancel at least 24 hours before it ends, it will automatically convert to a paid subscription at the price above.

7.2 Free trial.

We may offer a free trial. Unless you cancel before the end of the free trial period, your subscription will automatically convert to a paid subscription and you will be charged the applicable price. Free trials may be limited to one per person or per device, and we may modify or withdraw a free trial offer at any time.

7.3 Automatic renewal.

SUBSCRIPTIONS RENEW AUTOMATICALLY. YOUR SUBSCRIPTION WILL AUTOMATICALLY RENEW AT THE END OF EACH BILLING PERIOD AND YOUR PAYMENT METHOD WILL BE CHARGED THE THEN-CURRENT PRICE, UNLESS YOU CANCEL AT LEAST 24 HOURS BEFORE THE END OF THE CURRENT PERIOD.

7.4 Purchases made through an app store.

If you purchase a subscription through the Apple App Store, Google Play, or another third-party platform, that purchase is processed by, and your billing relationship for that purchase is with, that platform. Cancellation, refunds, and billing disputes for those purchases are governed by that platform's terms and policies, and must generally be managed through your platform account settings. We do not control and cannot process refunds on behalf of those platforms.

7.5 Cancellation.

You may cancel at any time. Cancellation takes effect at the end of the current billing period. You will retain access until then. Cancelling does not automatically delete your account or your data. To delete your data, use the in-app deletion feature or contact us.

7.6 Refunds.

Except where a refund is required by applicable law or by the policy of the app store through which you purchased, all fees are non-refundable, and we do not provide refunds or credits for partial billing periods, unused time, or periods during which you did not use the Service.

7.7 Price changes.

We may change our prices. We will give you reasonable advance notice of any price increase that would apply to your renewal. If you do not accept the new price, you may cancel before it takes effect.

7.8 Failed payments.

If a payment fails, we may suspend or terminate your access to paid features.

7.9 Your automatic-renewal rights under state law.

Several U.S. states, including California, Virginia, Illinois, New York, and others, have automatic-renewal laws that give consumers specific protections. Where those laws apply to you, the following applies and, to the extent of any conflict, prevails over the rest of this Section 7:

• Clear disclosure and consent: before you are charged, we (and, for App Store purchases, Apple) present the recurring nature of the subscription, the recurring charge, the billing frequency, and the price, and you must affirmatively agree to those terms.

• Easy cancellation: you may cancel at any time. Subscriptions purchased through the Apple App Store are managed and cancelled in your device settings under your Apple ID subscriptions, and Apple provides the cancellation mechanism for those purchases. You do not have to contact us to cancel an App Store subscription, and we provide an in-app link to your subscription-management settings.

• Renewal and price-change notice: where required by law, you will receive advance notice before a renewal or before any price increase takes effect, with instructions on how to cancel.

• Free-trial and introductory-offer terms: where a plan includes a free trial or introductory price, the length of that trial or offer, and the price and billing frequency that apply once it ends, are disclosed to you before purchase.

IF YOU PURCHASED THROUGH THE APPLE APP STORE, APPLE IS THE MERCHANT OF RECORD, APPLE PROCESSES YOUR PAYMENT AND RENEWALS, AND CANCELLATIONS AND REFUNDS ARE HANDLED THROUGH YOUR APPLE ID SUBSCRIPTION SETTINGS UNDER APPLE'S TERMS.

8. Your Content

"Your Content" means anything you enter into EELO, including the fears, triggers, habits, challenges, notes, ratings, reflections, and other information you record.

You retain ownership of Your Content. You grant us a limited, worldwide, non-exclusive, royalty-free license to host, store, process, transmit, back up, and display Your Content solely to the extent necessary to operate and provide the Service to you, and to the extent technically possible given any encryption applied to that content. This license ends when Your Content is deleted, except for copies retained in routine backups for a limited period and for any copies we are required by law to retain.

You are solely responsible for Your Content. You represent that you have the right to submit it and that it does not violate these Terms or any law or any third-party right. We do not routinely monitor or review Your Content, and we have no obligation to do so.

You should not enter information that you would not want stored, and you should not rely on EELO as a system of record.

9. Intellectual Property

All rights, title, and interest in and to EELO, including the software, source code, design, interface, structure, graphics, text, audio, educational content, exercises, methods, names, logos, and trademarks, are and remain the exclusive property of ClientValley OÜ and its licensors, and are protected by copyright, trademark, and other laws.

Subject to your compliance with these Terms, we grant you a limited, personal, revocable, non-exclusive, non-transferable, non-sublicensable license to access and use EELO for your own personal, non-commercial self-help purposes. No other rights are granted. All rights not expressly granted are reserved.

10. Acceptable Use

You must not, and must not attempt to, and must not permit anyone else to:

• Use EELO for any unlawful, harmful, fraudulent, or abusive purpose.
• Use EELO to plan, encourage, promote, or carry out self-harm, suicide, violence, or harm to any person.
• Copy, reproduce, distribute, republish, sell, license, sublicense, rent, lease, or otherwise commercially exploit any part of EELO.
• Reverse engineer, decompile, disassemble, or attempt to derive the source code of EELO, except to the extent this restriction is prohibited by applicable law.
• Circumvent, disable, or interfere with any security, authentication, encryption, access control, rate limiting, or payment feature.
• Access EELO by automated means, including scraping, crawling, or bots, or use EELO to build a competing or derivative product or dataset.
• Introduce any virus, malware, or other harmful code, or otherwise interfere with or disrupt the integrity, security, or performance of EELO or its infrastructure.
• Impersonate any person or misrepresent your affiliation, age, location, or identity.
• Use EELO to provide services to, or on behalf of, any third party, including any patient, client, or person in your care.
• Use EELO or any of its content as a clinical tool, or represent to anyone that EELO constitutes care, treatment, or professional advice.

11. End-to-End Encryption, Your Recovery Code, and Irreversible Data Loss

11.1 Your entries are end-to-end encrypted.

The content you enter into EELO, including your fears, triggers, habits, challenges, notes, reflections, and ratings, is end-to-end encrypted. It is encrypted on your own device, using a key derived from your credentials, before it is transmitted to or stored on our systems.

THIS MEANS WE CANNOT SEE YOUR ANSWERS. WE CANNOT READ, DECRYPT, ACCESS, REVIEW, MONITOR, RESTORE, OR RECOVER THE CONTENT YOU ENTER. NO EMPLOYEE, CONTRACTOR, OR ADMINISTRATOR OF CLIENTVALLEY OÜ CAN READ IT. WE COULD NOT PRODUCE IT IN READABLE FORM EVEN IF WE WERE ASKED OR LEGALLY COMPELLED TO DO SO.

A direct consequence of this design is that we have no ability to see what you write, and therefore no ability to detect distress, risk, crisis, or harm in your entries, and no ability to intervene. This reinforces Section 4.9: EELO is not monitored and is not an emergency service.

11.2 Your recovery code.

Because your data is encrypted with a key only you control, EELO issues you a recovery code. The recovery code is the only way to regain access to your encrypted content if you lose or forget your password or passphrase, or if you lose access to your device. It is shown to you once, at setup. It is your responsibility to write it down and store it somewhere safe, offline, and private.

WE DO NOT HOLD, STORE, OR HAVE ANY COPY OF YOUR RECOVERY CODE OR YOUR ENCRYPTION KEY. WE CANNOT RETRIEVE, RESET, REISSUE, OR REGENERATE IT FOR YOU, AND WE CANNOT UNLOCK YOUR DATA WITHOUT IT.

IF YOU LOSE OR FORGET BOTH YOUR PASSWORD AND YOUR RECOVERY CODE, YOUR ENCRYPTED CONTENT IS PERMANENTLY AND IRREVERSIBLY LOST. IT CANNOT BE RECOVERED BY US, BY YOU, OR BY ANYONE ELSE, BY ANY MEANS. THIS IS NOT A DEFECT. IT IS THE INTENDED CONSEQUENCE OF ENCRYPTION THAT PROTECTS YOUR PRIVACY.

YOU ACCEPT SOLE RESPONSIBILITY FOR SAFEGUARDING YOUR PASSWORD AND YOUR RECOVERY CODE. TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE ACCEPT NO LIABILITY WHATSOEVER FOR ANY LOSS OF, OR INABILITY TO ACCESS, ANY CONTENT ARISING FROM YOUR LOSS, DISCLOSURE, OR MISHANDLING OF YOUR CREDENTIALS OR RECOVERY CODE.

11.3 No backup guarantee.

We do not guarantee that any data will be retained, backed up, or recoverable. You are responsible for keeping your own separate copies of anything you consider important. If you share your recovery code with another person, that person may be able to read all of your content, and you are responsible for that disclosure.

12. Third-Party Services, Content, and Links

EELO relies on third-party providers, including hosting, database, authentication, payment, app store, and email providers, and it may contain links to third-party websites, content, or resources. A current list of the providers that process personal information on our behalf is set out in our Privacy Policy. We do not control third parties, we do not endorse them, and we are not responsible or liable for their content, products, services, policies, availability, acts, or omissions. Your dealings with any third party are solely between you and that third party.

13. Availability, Changes, and Discontinuation

We do not guarantee that EELO will be available, uninterrupted, timely, secure, or error-free. The Service may be unavailable due to maintenance, updates, technical failures, third-party outages, or causes beyond our control. We may modify, suspend, limit, or discontinue EELO or any part of it, permanently or temporarily, at any time and without liability to you. If we permanently discontinue the Service, we will make reasonable efforts to give notice and, where required, to provide a pro-rata refund of any prepaid, unused subscription fees.

14. Suspension and Termination

You may stop using EELO and delete your account at any time.

We may suspend or terminate your access, in whole or in part, immediately and without notice or liability, if we reasonably believe that you have breached these Terms, that you are ineligible, that your use poses a risk to you, to others, or to the Service, or that suspension or termination is required by law or advisable to protect our legitimate interests.

On termination, your license to use EELO ends immediately. Sections that by their nature should survive termination will survive, including Sections 4, 8, 9, 11, 12, and 16 through 23.

15. Feedback

If you send us ideas, suggestions, or feedback, you grant us a perpetual, irrevocable, worldwide, royalty-free, fully sublicensable license to use, modify, and exploit them for any purpose without any obligation, compensation, or attribution to you.

16. Disclaimer of Warranties

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, EELO AND ALL CONTENT, EXERCISES, TOOLS, EDUCATIONAL MATERIALS, AND RESOURCES ARE PROVIDED "AS IS" AND "AS AVAILABLE," WITH ALL FAULTS AND WITHOUT WARRANTY OF ANY KIND.

WE EXPRESSLY DISCLAIM ALL WARRANTIES, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE, INCLUDING ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, QUIET ENJOYMENT, ACCURACY, AND NON-INFRINGEMENT, AND ANY WARRANTIES ARISING OUT OF ANY COURSE OF DEALING OR USAGE OF TRADE.

WITHOUT LIMITING THE FOREGOING, WE MAKE NO WARRANTY OR REPRESENTATION THAT: (A) EELO WILL MEET YOUR REQUIREMENTS OR ACHIEVE ANY INTENDED RESULT; (B) EELO WILL IMPROVE, REDUCE, RELIEVE, OR HAVE ANY EFFECT ON ANY SYMPTOM, CONDITION, THOUGHT, FEELING, URGE, OR BEHAVIOR; (C) YOUR CONDITION WILL NOT WORSEN; (D) EELO WILL BE UNINTERRUPTED, TIMELY, SECURE, ACCURATE, COMPLETE, CURRENT, OR ERROR-FREE; (E) ANY CONTENT OR EDUCATIONAL MATERIAL IS ACCURATE, COMPLETE, CURRENT, OR SUITABLE FOR YOU; (F) DATA WILL NOT BE LOST, CORRUPTED, OR UNRECOVERABLE; OR (G) ANY THIRD-PARTY RESOURCE WILL RESPOND, HELP, OR BE AVAILABLE.

NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED FROM US OR THROUGH EELO, CREATES ANY WARRANTY NOT EXPRESSLY STATED IN THESE TERMS.

Some jurisdictions do not allow the exclusion of certain warranties, so some of the above exclusions may not apply to you. In that case, such warranties are limited to the minimum extent permitted by law.

17. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT WILL CLIENTVALLEY OÜ, OR ITS OFFICERS, DIRECTORS, SHAREHOLDERS, EMPLOYEES, CONTRACTORS, AGENTS, ADVISORS, SUPPLIERS, OR LICENSORS (TOGETHER, THE "EELO PARTIES"), BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR ANY LOSS OF PROFITS, REVENUE, DATA, GOODWILL, OR OTHER INTANGIBLE LOSSES, ARISING OUT OF OR RELATING TO EELO OR THESE TERMS, WHETHER BASED ON WARRANTY, CONTRACT, TORT (INCLUDING NEGLIGENCE), STATUTE, OR ANY OTHER LEGAL THEORY, AND WHETHER OR NOT WE HAVE BEEN INFORMED OF THE POSSIBILITY OF SUCH DAMAGE.

WITHOUT LIMITING THE FOREGOING, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE EELO PARTIES WILL HAVE NO LIABILITY WHATSOEVER FOR: (A) ANY EMOTIONAL DISTRESS, MENTAL ANGUISH, PSYCHOLOGICAL INJURY, ANXIETY, PANIC, WORSENING OF SYMPTOMS, RELAPSE, OR DETERIORATION OF ANY CONDITION; (B) ANY PERSONAL INJURY, BODILY INJURY, SELF-HARM, OR DEATH; (C) ANY HARM CAUSED BY YOU TO ANY OTHER PERSON; (D) ANY DECISION, ACTION, OR INACTION BY YOU, INCLUDING ANY DECISION TO SEEK OR NOT TO SEEK PROFESSIONAL CARE, OR TO START, STOP, OR CHANGE ANY TREATMENT OR MEDICATION; (E) ANY ACT, OMISSION, DELAY, FAILURE, OR UNAVAILABILITY OF ANY THIRD-PARTY CRISIS LINE, HELPLINE, PROVIDER, OR RESOURCE; (F) ANY LOSS OF OR INABILITY TO RECOVER ENCRYPTED CONTENT, INCLUDING WHERE YOU HAVE LOST YOUR PASSWORD OR RECOVERY CODE; (G) ANY ERROR, INACCURACY, OMISSION, OR MISINFORMATION IN THE SERVICE OR IN ANY OF ITS CONTENT, INCLUDING CONTENT PRODUCED WITH THE ASSISTANCE OF ARTIFICIAL INTELLIGENCE, OR ANY RELIANCE YOU PLACE ON IT; (H) ANY RELIANCE ON ANY IN-APP PROGRESS INDICATOR, SCORE, RATING, CHART, OR SUMMARY, OR ANY CONCLUSION YOU DRAW FROM ONE; OR (I) OUR INABILITY TO DETECT, MONITOR, OR RESPOND TO ANY RISK, CRISIS, OR HARM DISCLOSED IN YOUR ENTRIES, WHICH WE CANNOT READ.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE TOTAL AGGREGATE LIABILITY OF THE EELO PARTIES FOR ALL CLAIMS ARISING OUT OF OR RELATING TO EELO OR THESE TERMS WILL NOT EXCEED THE GREATER OF (I) THE TOTAL AMOUNT YOU ACTUALLY PAID US FOR THE SERVICE IN THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (II) ONE HUNDRED UNITED STATES DOLLARS (USD 100).

These limitations apply even if any limited remedy fails of its essential purpose. Some jurisdictions do not allow the exclusion or limitation of certain damages, so some of the above may not apply to you. Nothing in these Terms excludes or limits liability that cannot lawfully be excluded or limited, including liability for fraud, fraudulent misrepresentation, or gross negligence or willful misconduct where such exclusion is prohibited.

18. Indemnification

You agree to defend, indemnify, and hold harmless the EELO Parties from and against any and all claims, demands, actions, proceedings, liabilities, damages, losses, judgments, fines, penalties, costs, and expenses (including reasonable legal fees) arising out of or relating to: (a) your use or misuse of EELO; (b) Your Content; (c) your breach of these Terms or of any law or third-party right; (d) any decision, action, or inaction you take in connection with EELO; or (e) any harm you cause to yourself or to any other person.

19. Assumption of Risk, Waiver, and Release

You knowingly, voluntarily, and expressly assume all risks associated with using EELO, including all risks described in Section 4.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, YOU HEREBY RELEASE, WAIVE, DISCHARGE, AND COVENANT NOT TO SUE THE EELO PARTIES FROM AND AGAINST ANY AND ALL CLAIMS, LIABILITIES, DEMANDS, DAMAGES, LOSSES, COSTS, AND CAUSES OF ACTION OF EVERY KIND, WHETHER KNOWN OR UNKNOWN, FORESEEN OR UNFORESEEN, ARISING OUT OF OR RELATING TO YOUR USE OF EELO, INCLUDING ANY EMOTIONAL, PSYCHOLOGICAL, OR PHYSICAL HARM, DISTRESS, OR WORSENING OF ANY CONDITION.

IF YOU ARE A CALIFORNIA RESIDENT, YOU EXPRESSLY WAIVE CALIFORNIA CIVIL CODE SECTION 1542, WHICH STATES: "A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS THAT THE CREDITOR OR RELEASING PARTY DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE AND THAT, IF KNOWN BY HIM OR HER, WOULD HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR OR RELEASED PARTY." YOU WAIVE ANY SIMILAR PROVISION OF ANY OTHER JURISDICTION.

20. Binding Arbitration and Class Action Waiver

PLEASE READ THIS SECTION CAREFULLY. IT AFFECTS YOUR LEGAL RIGHTS, INCLUDING YOUR RIGHT TO FILE A LAWSUIT IN COURT AND TO HAVE A JURY TRIAL.

20.1 Informal resolution first.

Before starting any arbitration, you agree to first contact us in writing and to attempt in good faith to resolve the dispute informally for at least sixty (60) days from the date we receive your notice. Your notice must describe the dispute and the relief you seek.

20.2 Agreement to arbitrate.

If the dispute is not resolved informally, you and ClientValley OÜ agree that any dispute, claim, or controversy arising out of or relating to EELO or these Terms, including their formation, interpretation, breach, or termination, will be resolved exclusively by final and binding individual arbitration, and not in court, except as stated in Section 20.5.

Any arbitration will be administered by the American Arbitration Association (AAA) under its Consumer Arbitration Rules, as modified by this Section 20. The arbitration will be conducted by a single arbitrator. The seat of the arbitration is Delaware, United States, and the arbitration may be conducted remotely or in the county of your residence where the rules so provide. The allocation of arbitration fees is governed by the AAA Consumer Arbitration Rules, under which we pay the fees they require us to pay for consumer disputes. Either party may bring an individual claim in small-claims court instead of arbitration if it qualifies.

20.3 Class action and jury trial waiver.

YOU AND WE AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN AN INDIVIDUAL CAPACITY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, COLLECTIVE, CONSOLIDATED, OR REPRESENTATIVE PROCEEDING. THE ARBITRATOR MAY NOT CONSOLIDATE MORE THAN ONE PERSON'S CLAIMS AND MAY NOT PRESIDE OVER ANY CLASS OR REPRESENTATIVE PROCEEDING. YOU AND WE WAIVE ANY RIGHT TO A JURY TRIAL.

20.4 Your right to opt out.

You may opt out of this arbitration agreement by sending written notice to our legal contact address within thirty (30) days of first accepting these Terms. Your notice must include your name, the email address associated with your account, and a clear statement that you wish to opt out of arbitration. Opting out will not affect any other part of these Terms.

20.5 Exceptions.

Either party may bring an individual claim in small claims court, and either party may seek injunctive or equitable relief in a court of competent jurisdiction to protect its intellectual property or to prevent unauthorized access to the Service.

20.6 Time limit.

To the maximum extent permitted by law, any claim arising out of or relating to EELO or these Terms must be brought within one (1) year after the claim arose, or it is permanently barred.

21. Governing Law

21.1 Governing law and forum for U.S. users. These Terms, and any dispute arising out of or relating to them or to the Service, are governed by the laws of the State of Delaware, United States, without regard to its conflict-of-law rules, except that the Federal Arbitration Act governs the interpretation and enforcement of the arbitration provision in Section 20. This choice of Delaware law applies to the maximum extent permitted; nothing in it deprives you of the protection of the mandatory consumer-protection laws of the U.S. state in which you reside, which continue to apply to you. Subject to the arbitration provision in Section 20, you and we agree that any dispute not subject to arbitration will be resolved exclusively in the state or federal courts located in Delaware, and you and we consent to personal jurisdiction there, except where the law of your state of residence gives you the right to bring a claim in your local courts, which right is preserved.

21.2 The company. EELO is operated by ClientValley OÜ, a company registered in Estonia. For any matter outside the scope of Section 21.1 (for example, corporate or tax matters concerning the company itself), Estonian law applies. This does not change the law that governs your use of the Service as a U.S. consumer, which is set out in Section 21.1.

These Terms and any dispute arising out of them will be governed by the law specified above, without regard to its conflict-of-law rules. The United Nations Convention on Contracts for the International Sale of Goods does not apply. Nothing in these Terms deprives you of the protection of any mandatory consumer protection law of the jurisdiction in which you reside.

22. Apple App Store Additional Terms

If you download EELO from the Apple App Store, the following applies and prevails over any conflicting provision in these Terms in respect of that download:

• These Terms are between you and ClientValley OÜ only, and not with Apple Inc. ("Apple").
• Apple has no obligation to furnish any maintenance or support services for EELO.
• If EELO fails to conform to any applicable warranty, you may notify Apple, and Apple may refund the purchase price. To the maximum extent permitted by law, Apple has no other warranty obligation whatsoever with respect to EELO.
• Apple is not responsible for addressing any claim by you or any third party relating to EELO, including product liability claims, any claim that EELO fails to conform to any legal or regulatory requirement, and claims arising under consumer protection or similar legislation.
• Apple is not responsible for the investigation, defense, settlement, or discharge of any third-party claim that EELO infringes intellectual property rights.
• You represent that you are not located in a country subject to a United States Government embargo or designated as a "terrorist supporting" country, and that you are not listed on any United States Government list of prohibited or restricted parties.
• Apple and its subsidiaries are third-party beneficiaries of these Terms and, upon your acceptance, will have the right to enforce these Terms against you as a third-party beneficiary.

23. General Provisions

23.1 Entire agreement.

These Terms, together with the Privacy Policy and any terms presented at the point of purchase, constitute the entire agreement between you and us regarding EELO and supersede all prior agreements and understandings.

23.2 Severability.

If any provision is held invalid or unenforceable, it will be modified to the minimum extent necessary to make it enforceable, or if it cannot be modified, it will be severed, and the remaining provisions will remain in full force and effect.

23.3 No waiver.

Our failure to enforce any provision is not a waiver of our right to enforce it later.

23.4 Assignment.

You may not assign or transfer these Terms or any rights under them. We may assign or transfer these Terms, in whole or in part, without restriction, including in connection with a merger, acquisition, reorganization, or sale of assets.

23.5 Force majeure.

We are not liable for any failure or delay caused by events beyond our reasonable control, including acts of God, natural disaster, war, terrorism, civil unrest, epidemic, government action, labor dispute, internet or telecommunications failure, power failure, or failure of any third-party provider.

23.6 Notices and electronic communications.

You consent to receive communications from us electronically, including by email and in-app notice, and you agree that all agreements, notices, disclosures, and other communications provided electronically satisfy any legal requirement that they be in writing. We may send notices to the email address associated with your account. You may send notices to us at our legal contact address.

23.7 Relationship.

Nothing in these Terms creates any partnership, joint venture, agency, employment, or fiduciary relationship between you and us.

23.8 Headings.

Headings are for convenience only and do not affect interpretation.

23.9 Language.

These Terms are drafted in English. Any translation is provided for convenience only, and the English version prevails.

24. Changes to These Terms

We may update these Terms from time to time. If we make a material change, we will provide reasonable notice, for example by in-app notice or by email, before the change takes effect. Your continued use of EELO after the change takes effect constitutes your acceptance of the revised Terms. If you do not agree, you must stop using EELO and may cancel your subscription.

25. Contact

Questions about these Terms may be sent to:

ClientValley OÜ

Tallinn, Estonia

eeloocd@gmail.com