Privacy Policy
Last updated: 1 November 2026.
This policy explains how ELEVATE2AI, LDA handles the personal data of people who visit elevate2ai.com, contact us or chat with PocketSphere, the website's AI assistant.
Who is the controller
The controller for the website's data is ELEVATE2AI, LDA, tax number (NIF) 519240308, with its registered office at Avenida dos Moinhos do Arneiro, 18B, 2705-434 São João das Lampas (Sintra), Portugal.
For any question about your data, write to info@elevate2ai.com or call +351 915 950 259.
We have not appointed a data protection officer. Privacy questions go to the same contacts.
What this policy covers
This policy covers the website and the contacts you make with us from it, by email, phone or WhatsApp.
When we build or maintain systems for other companies, we process the data in those systems on their behalf and on their instructions. In those cases, the client company is the controller. If your data is held in one of those systems, please make your request to that company.
When you visit the website
To show you the pages, the server receives the technical data your browser sends on any visit, such as your IP address, browser type and the page requested. The website hosting and delivery provider uses this data to serve the website and protect it from abuse. That provider states that it keeps operational and security logs for as long as needed to run and secure the service, and longer if it is investigating an incident.
Visit statistics: if you accept them in the cookie notice, the website's usage analytics service, run by our usage and error analytics provider, counts visits in aggregate. It records, for example, the pages viewed, how long the visit lasted, the website or campaign you came from, your country and your device type. To do this, once you accept, it sets an analytics cookie in your browser with a random session identifier, which lasts 30 minutes and is renewed on each page viewed. If you decline, these statistics are not collected and the cookie is not set. According to the provider, this data is stored in the European Union, and we only see aggregate figures for the last 90 days. The provider may use this data, once de-identified, to improve its services.
Performance and errors: if you accept the statistics, the same provider also receives, on each visit, the pages viewed, the time spent on each page, loading performance measurements and, if a technical error occurs, the page and the technical details of the error, so that we can fix it. Each visit gets a random identifier, which is not stored in your browser. We apply the same retention approach to this data as to the technical logs. If you decline, statistics are switched off and we also do not receive error reports from your visit.
Legal basis: for the technical data from visits, our legitimate interest in keeping the website running and secure (Article 6(1)(f) GDPR). For visit statistics and performance and error data, your consent (Article 6(1)(a) GDPR). You can withdraw your consent at any time, as easily as you gave it, under ‘Cookie preferences’ in the footer of any page. When you withdraw it, the page reloads so that your new choice applies straight away. Withdrawing it does not affect processing carried out before.
Apart from these statistics and the performance and error data, we do not use any other analytics tools, or any advertising or social media tools. The website's code does not set cookies. It uses your browser's session storage, for technical purposes that are strictly necessary for browsing: remembering where you were on a page and trying again to load a page that failed. It does not store personal data and it is deleted when you close the tab. It also uses your browser's local storage to keep your choice in the cookie notice, the date you made it and the version of the policy in force at that date. Because they are strictly necessary, these two uses do not require your consent. The website's cookies come from the services we use: the website hosting and delivery provider sets two technical cookies, which are strictly necessary for the website to work and stay secure, and the website's usage analytics service sets an analytics cookie, only if you accept it. The details are in our Cookie Policy.
When you contact us
The contact form does not send any data to the website. When you press Send request, your email app opens with the message already filled in. The message only goes when you send it, from your own email account, and it arrives in our info@elevate2ai.com inbox. The website does not store anything you type.
The message contains what you fill in: name, company, email, phone if you give it, sector, number of clients, students or members, what you would like to solve, the software you use and how you heard about us. It also contains the page language, your confirmation that you have read this policy, with its version, and your choice about news.
We handle in the same way the data you give us if you write to our email directly, call us or send us a WhatsApp message. If you use WhatsApp, the message also goes through that service, which handles it under its own terms and privacy policy.
Purpose: to reply to your request, arrange the call and, if you ask us to, prepare a proposal.
Legal basis: steps taken at your request before entering into a contract (Article 6(1)(b) GDPR). If your contact is not about a proposal or a contract, for example a general question or a complaint, the legal basis is our legitimate interest in replying to you (Article 6(1)(f) GDPR).
Retention: we keep the data while your request is open. If it does not lead to a contract, we delete it within 12 months of our last contact. If it leads to a contract, we keep it for the period required by law, for example for tax and accounting obligations.
Please do not include health data or other people's data in your message.
News by email
The form has a separate, optional box, unticked by default, for receiving news and content from Elevate2AI by email.
If you tick it, we use your email to send you that news. We send it from the company's own email, with no other mailing tool. Legal basis: your consent (Article 6(1)(a) GDPR).
You can withdraw your consent at any time, using the unsubscribe option included in every message, by writing to info@elevate2ai.com or by replying to one of the messages. Withdrawing it does not affect messages sent before.
Retention: we keep your email for this purpose until you withdraw your consent.
PocketSphere, the AI assistant
PocketSphere is the website's AI assistant. It answers questions about Elevate2AI and its products. Using it is optional.
What is sent: the text of the messages you write and of the replies. With each question, the website sends the last 6 messages of the conversation, so that the reply has context. The website does not add your name, email or IP address to the conversation.
Where it goes: the text goes through the website's server to our AI model provider, which generates the reply on servers in the United States. This transfer is made under the standard contractual clauses approved by the European Commission (Commission Implementing Decision (EU) 2021/914).
Retention: Elevate2AI does not keep the conversations. The website does not log the content of the messages or the replies. The conversation stays only in the memory of the page open in your browser and disappears when you close the tab or reload the page. Retention of the messages by the AI model provider is governed by the agreements with the hosting provider.
Elevate2AI does not use your data to train models. The hosting provider does not use visitors' data to train models, and the agreements with the AI model provider limit how that data is used.
Question limit: to prevent abuse, the server works out a code from the date and your IP address (a SHA-256 hash). This code is used only to count questions, stays in the server's memory, is not sent to the AI providers and changes every day, so the previous day's code stops having any effect.
Legal basis: our legitimate interest in answering the questions you ask us through the website and in preventing abuse (Article 6(1)(f) GDPR).
The replies are generated by AI and may contain errors. PocketSphere does not make decisions about you. Do not share personal or confidential data in the chat, such as health data, financial data or your company's internal information. To talk to us about a specific case, use the contact form or write to info@elevate2ai.com.
Who receives the data
We do not sell personal data or share it for advertising. We only disclose it to other parties when the law requires it, for example to public authorities.
For the website and for email, we use providers in these categories, which process the data on our behalf (processors):
- website hosting and delivery provider: hosts the website and the server that connects PocketSphere to the AI models, and delivers the pages over a global network. It processes technical data from visits, such as the IP address;
- AI model provider, in the USA: generates PocketSphere's replies and receives the text of the conversations;
- email provider, with data hosted in the European Union (Ireland): company email, including the info@elevate2ai.com inbox, where contact requests arrive, and sending our news;
- usage and error analytics provider: aggregate visit statistics, page performance data and technical error reports, only with your consent.
You can ask for the list of processors at info@elevate2ai.com.
Transfers outside the European Economic Area
Some providers process data outside the European Economic Area. The AI model provider processes the text of PocketSphere conversations in the United States. The hosting provider's delivery network is global and may process technical data from visits, such as the IP address, outside the European Economic Area. Technical error reports may also be processed in the United States.
These transfers are made under the standard contractual clauses approved by the European Commission (Commission Implementing Decision (EU) 2021/914). You can ask for a copy of these clauses at info@elevate2ai.com.
What data you have to give us
You are not required by law to give us any data. To send your request through this form, you need to fill in the fields marked as required. If you prefer not to, you can write to us directly at info@elevate2ai.com. The other fields are optional.
Automated decisions
We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you. We do not profile visitors.
Your data protection rights
Under the GDPR, you can:
- ask for access to your data;
- ask for inaccurate or incomplete data to be rectified;
- ask for your data to be erased;
- ask for processing to be restricted;
- ask for portability of the data you gave us, where the processing is based on your consent or on your contact request;
- withdraw your consent at any time, without affecting processing carried out before.
Right to object: you can object at any time, on grounds relating to your particular situation, to processing based on our legitimate interest: technical data from visits, PocketSphere and contacts that are not about a proposal or a contract. This right does not apply to the data in a contact request made to prepare a proposal or a contract.
To exercise these rights, write to info@elevate2ai.com. We reply within one month.
You can also lodge a complaint with the Portuguese data protection authority, the Comissão Nacional de Proteção de Dados (CNPD), at www.cnpd.pt (opens in a new tab).
Data security
The website uses encrypted connections (HTTPS). We limit access to the data to the people who need it to reply to requests.
Changes to this policy
We may update this policy, for example if we change suppliers or start handling data in a different way. The version in force is the one published on this page, with the date of the last update.