Privacy Policy

1. Who we are

Elev.H is a leadership development platform operated by Elev.H Tecnologia Ltda., headquartered in Brazil. Our product helps leaders record observations about their team members, structure feedback, and track team development over time.

Contact: [email protected]

2. Data we collect

3. How we use your data

• Provide and improve the Elev.H platform
• Process payments and manage subscriptions
• Send product-related notifications (reminders, confirmations)
• Marketing communications (only with your consent)
• Comply with legal obligations
• Prevent fraud and ensure platform security

4. Legal basis for processing

We process your data based on the following legal bases under LGPD (Brazilian Law No. 13,709/2018) and GDPR (EU Regulation 2016/679):

• Contract performance: to provide the contracted services
• Consent: for marketing communications and non-essential cookies
• Legitimate interest: for security, fraud prevention, and product improvement
• Legal obligation: when required by law

5. Data sharing

We do not sell your data. We share only with vendors that help us operate the platform:

• Stripe — payment processing
• Resend — transactional email delivery
• Telegram — bot notifications (only if you connect)
• Google Analytics / Meta Pixel — usage analytics (with your consent)
• AWS / Cloudfront — hosting and file storage

All vendors are subject to data processing agreements compatible with LGPD and GDPR.

6. International transfers

Your data may be transferred to and processed on servers located in the United States and the European Union. We ensure these transfers occur with appropriate safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission.

7. Data retention

We retain your data for as long as your account is active. After account closure, we delete or anonymize your data within 90 days, unless a legal obligation requires longer retention.

8. Your rights

Depending on where you are located, you may have the following rights:

• Access: request a copy of your personal data
• Correction: request correction of inaccurate data
• Deletion: request deletion of your data
• Portability: receive your data in a structured format
• Objection: object to processing based on legitimate interest
• Consent withdrawal: at any time, for consent-based processing

California residents (CCPA): you have the right to know what data we collect, request its deletion, and opt out of the sale of personal information (which we do not conduct). To exercise these rights, contact [email protected].

To exercise any of these rights, email [email protected]. We will respond within 15 business days.

9. Cookies

We currently use only essential cookies necessary for platform operation (authentication and session management). We reserve the right to use analytics and marketing cookies in the future — if and when we do, this policy will be updated and, where required by law, your consent will be requested.

10. Security

We implement technical and organizational measures to protect your data, including encryption in transit (HTTPS/TLS), secure authentication with JWT in HttpOnly cookies, and role-based access controls. No system is 100% secure; in the event of a breach, we will notify affected users as required by LGPD and GDPR.

11. Children

Elev.H is not intended for users under 18 years of age. We do not knowingly collect data from minors. If we become aware that we have collected data from a minor, we will delete that information immediately.

12. Changes to this policy

We may update this policy periodically. We will notify you by email or in-platform notice for material changes. Continued use of the platform after notification constitutes acceptance of the updated policy.

13. Contact and Data Protection Officer

For questions about this policy or to exercise your rights, contact our Data Protection Officer:

[email protected]

EU residents may also lodge a complaint with their local data protection authority. US (California) residents may contact the California Privacy Protection Agency.