Privacy Policy for the Elvina website

This Privacy Policy explains how SmartExpert Inc. (d/b/a "ContentBuilder"; "SmartExpert," "we," "our") collects, uses, discloses and protects personal data when you use the website elvina.ai, the conversation with Elvina on it, its forms and the first paid step offered there (together, the "Site"). Our address is 690 Saratoga Ave, 1st floor, San Jose, CA 95129, United States, and our privacy contact is privacy@contentbuilder.ai. Elvina is a digital employee (AI), not a person, and the public name of our product; SmartExpert Inc. is the company responsible for your data.

Controller and processor. We act as a controller for the personal data we process for our own purposes on the Site: replying to you, running your conversation with Elvina, taking a payment, keeping the Site secure and learning which channels lead to useful conversations. When a business uses Elvina under a written customer agreement, we act as a processor for the data we process on its behalf, under the data-processing terms of that agreement.

If you do not agree with this Policy, please do not use the Site.

This Policy applies to personal data about visitors of the Site, including people who use it on behalf of a business. It does not apply to data we process as a processor under a customer agreement: please contact that customer about its privacy practices. It also does not cover the ContentBuilder platform at contentbuilder.ai, which has its own privacy policy, or other websites and services you reach from the Site, such as Calendly, Stripe, WhatsApp and Instagram, which follow their own policies.

Demo request. The demo request form sends the name, work email, company, role, goal and optional phone you enter, plus the page you submitted from, the time, and a short reference used to prevent duplicate submissions. The form also sends the first page you opened on this website and the site that linked you here, if any, plus the campaign tags of that link when it had them (source, medium, campaign, content); until you send the form they stay in your browser tab. With the demo request form we record your network (IP) address and the type of browser you use, to keep the form free of abuse.

Project form. The AI Brand Studio form on our project page asks what you want to grow, your main goal, your monthly budget for content and promotion, your Instagram or website if you choose to share it, your name and your email, and the ManyChat contact reference if you arrived from our Instagram direct messages. You choose between your personal brand and your company’s sales; reach, traffic, or leads and sales; and a budget range. The form reaches HubSpot as a contact with these answers and a note, without a sales deal. Then you pick a time in Calendly: the booking link passes Calendly the reference of your request, your two choices and the tag of the reel you came from, if any, not your name or email.

If you arrive from Instagram, the project page shows a short questionnaire instead. For a personal brand it asks who you are, what one client pays you for your main offer, your monthly budget for your brand and when you want to start; for sales and leads it asks about your company, your role, your monthly marketing budget and when you want to start; then your name, your email and, if you choose, your Instagram or company website. If you arrived from our Instagram direct messages, it also sends the ManyChat contact reference. From these answers our website places your request in a group, for example ready to start soon or not ready yet. The group decides whether we offer you a call in Calendly right away, and it reaches HubSpot with your answers. The booking link passes Calendly the reference of your request, whether you chose personal brand or sales and leads, and the tag of the reel you came from, if any, not your name or email.

Partners form. The collabs, podcasts and press form asks for your name, email, an optional organization or link, the kind of request and your message, and reaches HubSpot as a contact with a note. The project and partners forms also send the page you submitted from, the time, a short reference used to prevent duplicate submissions and the same visit details as the demo request, but they do not record your network address or browser.

Every request is written to a request log on our server and delivered to HubSpot, the customer-relationship system our team works in, and our team is alerted to it in Telegram; for a demo request that alert can include the details you entered, for the project and partners forms it only links to the contact. We use your details to reply, to prepare the demo or call you asked for and to follow up, and the visit details to learn which channels lead to useful conversations. We do not sell them, and we do not add you to a marketing list without a separate opt-in you choose yourself.

When you write to Elvina on this website, what you type, the files you attach and the page you started from go to our server, where Elvina answers with the help of our AI model providers. The conversation is kept on our server so that you can continue it, and this browser keeps a cookie for 30 days to reopen it. If you start a voice call, your microphone audio goes to OpenAI, which turns it into Elvina’s spoken replies and a text transcript. We keep the transcript in your conversation; we do not record or store the audio. OpenAI may keep API data for abuse monitoring, normally for up to 30 days, with the exceptions its data policies describe. A call lasts up to five minutes. To ask us to delete a conversation, see section 15. If you pay for the first step, Stripe processes your card; we receive the amount, your email and a reference to your conversation, not your card number.

If you start from our questionnaire page, it also sends the options you tap (your role, the size of your team, what is going on and when you need help), so Elvina can start the conversation from your answers and skip those questions. The questionnaire does not ask for your name. The conversation also receives the campaign tags of the link that brought you here (source, medium, campaign, content), the site that linked you and the first page you opened; this browser keeps them so that a visit within 30 days is credited to the same link, and a visit after 30 days, or from a link of a new campaign, replaces them. We use them to learn which channels lead to useful conversations. Along with them go the term tag of that link when it has one, the pages you opened in this browser tab (up to ten) and the label of the button that opened the conversation.

The conversation also learns your browser’s language and the hour of your local time. When you start a voice call, OpenAI also receives the recent messages in this chat (up to the last 16) and the page title and address, so that Elvina can continue the conversation by voice. If you give Elvina your email, for a sign-in code, so that a person on our team can send you a finished material, or with a request for a call, it is kept with your conversation; the code appears on screen, or arrives from our email delivery provider once email sending is switched on. To limit new conversations, messages and calls from one connection, our chat service receives the network address of your requests and stores it there only as a shortened hash; the website’s own server logs still record it, as section 07 describes.

If you give Elvina your email in a conversation on this website to have a finished material sent to you or to request a call with our team, we also add you as a contact to HubSpot, the customer-relationship system our team works in, or update your contact there. The contact holds your email, your first name if you told it to Elvina, your questionnaire answers if you started from our questionnaire page, the campaign tags and the term tag of the link that brought you here, the site that linked you, the first page you opened, the ManyChat contact reference if you arrived from our Instagram direct messages, whether you asked for a call or for a person, a short summary of your request written from what you told Elvina (such as your business, its locations, the role you hire or train for and your task), and a link to your conversation in our team dashboard, which only our team can open; it also notes that your email has not been confirmed. The text of your conversation stays on our chat server and is not copied to HubSpot, and neither are your last name, phone number, network address or the other pages you opened. If you told the questionnaire that you are looking for a job, nothing is sent to HubSpot, and neither is a conversation that Elvina has marked as a job search or as a request we do not handle. Our team gets a Telegram alert that links to the contact without repeating your details. We use this contact to send you the material or arrange the call and to follow up on your request; we do not add you to a marketing list without a separate opt-in you choose yourself.

When you ask for a call with our team, the Calendly booking window opens with what you have already told Elvina filled in, such as your name, email and a short summary of your task, and our team gets a Telegram alert with that summary and your contact; the WhatsApp option opens a message with the same summary for you to send. People on the Elvina team can read conversations in our team dashboard: they reply when you ask for a person, handle payments, deliver materials and review replies to improve Elvina.

A quiz from your procedure is made in the conversation with Elvina, so the procedure and everything else you send for it are handled as section 04 describes. The Site no longer has a separate quiz generator. Text pasted into the former generator was sent to our AI model provider, Anthropic, to write the quiz and was not stored on this website; details sent through its follow-up form were handled like a demo request (section 03).

If you write to our Instagram account in direct messages, they are answered with ManyChat, an Instagram messaging automation service. ManyChat processes that conversation for us: your Instagram handle, your answers to our questions there, the email you give and the tag of the reel you came from. We use them to reply and to arrange a call. A link from those messages can open our project page with your ManyChat contact reference and your two choices: it skips the form and goes straight to booking a call, and the booking link passes Calendly your ManyChat contact reference, your two choices and the tag of the reel you came from, if any, not your name or email. Instagram, a Meta service, processes the messages under its own terms and privacy policy.

Server and security logs. When your browser requests a page, our servers and their hosting providers record the request: your network (IP) address, the page address, the time, the referring page and the type of browser and device. We use these logs to run the Site, find errors and stop abuse. Website and security logs are kept for up to thirty days.

Visit measurement. Each page you open, and steps of the conversation such as opening the chat or sending a first message, send an event to our server with a random visitor ID that this browser keeps from visit to visit, the page path and the source tag of the link you came from. These events carry no name or email, and our server stores the visitor ID only in hashed form. We use them to count visits and to see where conversations start and stop.

Web analytics. When it is switched on, Cloudflare Web Analytics counts page views and loading speed. It sets no cookies and stores nothing in your browser; Cloudflare receives the page address, the referring page, your network address and technical details of your browser under its own privacy policy.

Session recordings. When it is switched on, Microsoft Clarity shows us how visitors use the Site: clicks, taps, scrolling, mouse movement and replays of visits, including the pages opened one after another. Before anything is sent to Clarity, the conversation with Elvina, anything you type into a form, the previews and confirmations that repeat what you entered, and email addresses and numbers shown on the page are masked. Clarity sets two cookies of this Site, _clck (kept for one year, it recognizes a returning browser) and _clsk (kept for one day, it links the pages of a visit), and keeps one marker for the open tab, _cltk, in session storage; Microsoft may also set cookies on its own domains, which it uses for advertising, site analytics and other purposes. Microsoft receives the page address, the page as displayed with those parts masked, the referring page, your network address and technical details of your browser and device, and processes this data as an independent controller under the Microsoft Privacy Statement (privacy.microsoft.com/privacystatement). Clarity generally keeps recordings for 30 days; labeled or favorited sessions and a random sample of recordings may be kept for up to 9 months, and heatmaps and click data for up to 9 months. In the European Economic Area, the United Kingdom and Switzerland, Clarity sets no cookies without consent, and this Site does not ask for it. Clarity does not load when your browser sends a Global Privacy Control signal, and you can turn it off in this browser as section 12 describes. We use it to see where pages confuse visitors and to fix those pages.

Some data reaches us from services you use on the way to us or through the Site:

• Calendly. If you schedule a call with our team, Calendly passes us the details you enter in its booking window, such as your name, email, the time you chose and your answers to its questions.
• Stripe. If you pay for the first step, Stripe tells us the payment status, the amount, a payment reference and the conversation it belongs to. Stripe keeps your card details; we never receive them.
• The link that brought you here. Its address can carry campaign tags, and your browser tells us which site linked you here, as described in sections 03 and 04.
• Instagram. ManyChat passes us what you share in Instagram messages, as described in section 06.

We use personal data for the purposes below. The legal basis for each, where the law asks for one, is shown in brackets.

• Reply to you, prepare the demo, call or material you asked for, and follow up on your request. (Steps you asked for before a contract / Legitimate interests)
• Run the conversation with Elvina, keep it so that you can continue it, prepare and deliver the materials you approve, and process the first paid step. (Contract)
• Learn which pages and channels lead to useful conversations. (Legitimate interests)
• Keep the Site secure: rate limits, abuse prevention, logs and incident response. (Legitimate interests / Legal obligation)
• Improve Elvina and the Site. Our team reviews conversations to improve Elvina’s replies and rules, and we may use de-identified or aggregated data to improve the Site and Elvina. You may opt out by writing to privacy@contentbuilder.ai. (Legitimate interests; opt-out)
• Marketing, only with a separate opt-in you choose yourself and with the ability to unsubscribe at any time. (Consent)
• Comply with law, enforce our Terms of Use and prevent harm. (Legal obligation / Legitimate interests)

We share personal data only as described below. Most of the providers named here process it on our behalf, under their terms and data-protection commitments; Microsoft receives Microsoft Clarity data as an independent controller under its own privacy terms. We may also share aggregated or de-identified statistics that do not identify you. We do not sell personal data for money. When Microsoft Clarity is switched on, Microsoft receives website usage data and may use its own cookies for advertising, as section 07 describes. These disclosures may constitute sale or sharing under California law; see the US state notices below. A Global Privacy Control signal or the switch in section 12 turns Clarity off. The Site uses no other advertising or cross-site tracking technology. A named list of subprocessors for a customer workspace is part of the customer agreement.

• Hosting. The providers that host our servers process requests, logs and stored data.
• AI model providers. Anthropic processes the text of your conversation to write replies; OpenAI processes the audio of a voice call, with the recent messages of the chat and the page title and address, to produce Elvina’s spoken replies and the transcript.
• Team and customer-relationship tools. HubSpot holds form requests and the contacts from conversations with Elvina described in section 04, Telegram carries alerts to our team, and ManyChat answers Instagram messages.
• Booking, payment and email. Calendly runs call bookings, Stripe processes payments, and our email delivery provider sends sign-in codes once email sending is switched on.
• Analytics. When they are switched on, Cloudflare Web Analytics counts page views without cookies, and Microsoft Clarity records how visitors use the Site, with the conversation and form fields masked, as section 07 describes. Microsoft processes Clarity data as an independent controller under its own privacy statement.
• At your direction. When you choose to write to us on WhatsApp or Instagram, Meta processes those messages under its own terms.
• Affiliates. Within our corporate group.
• Legal. To comply with law or court orders, or to protect rights and safety.
• Business transfers. As described in the next section.

If we undergo a merger, acquisition, asset sale or bankruptcy, personal data may be transferred to a successor subject to comparable protections. We will notify you where required by law.

This section is our cookie policy. Cookies are small text files a website places in your browser. Browser storage (local storage and session storage) works in a similar way; scripts running on this Site, including third-party scripts it loads, can read what it keeps there.

Strictly necessary cookie. The Site sets one cookie, elvina_ws, when you start a conversation with Elvina. It holds a reference to your conversation for 30 days so that the chat can reopen it, it is sent only to the Site’s chat service, and page scripts cannot read it. The chat needs it to work, so it does not require consent.

Third parties. The Calendly booking window loads only after you click to pick a time, and Calendly may then set its own cookies under its cookie policy. Stripe’s payment page opens on Stripe’s own site. Cloudflare Web Analytics sets no cookies. When Microsoft Clarity is switched on, it sets the _clck and _clsk cookies and Microsoft may set cookies on its own domains, as section 07 describes. Apart from Clarity, the Site uses no advertising, social-media or cross-site tracking cookies or pixels.

Your choices. You can block or delete cookies and clear site data in your browser settings at any time. Without the elvina_ws cookie the chat cannot reopen your conversation; the rest of the Site works without it. Visit measurement and campaign attribution do not use cookies; they use the browser storage listed below, which the Site does not offer a separate switch for today, so clearing site data is the way to remove it. A Global Privacy Control signal turns Microsoft Clarity off; it does not change anything else on the Site. When Clarity is switched on, you can also turn it off in this browser with the switch at the end of this section: it saves your preference in this browser and reloads the page to stop recording. Clearing site data removes this preference.

Browser storage. The Site keeps these items in your browser:

• elv-entry (local storage): the campaign tags, referring site and first page of your visit, sent when you start a conversation. It does not expire on its own; a visit after 30 days, or from a link of a new campaign, replaces it.
• elv-path and elv-entry-btn (session storage, this tab only): up to ten pages you opened and the button that opened the chat, sent when you start a conversation.
• elvina.campaign (session storage, this tab only): the visit details that the demo request form sends with your request.
• elvina.visitor (local storage): the random visitor ID used for visit measurement in section 07. It stays until you clear site data.
• elv-internal-session (session storage): marks a visit from one of our own test links so that it is left out of our counts.
• _cltk (session storage, this tab only): a marker Microsoft Clarity uses while it records the open page, when Clarity is switched on (section 07). Session storage normally ends when the tab is closed.
• elv-clarity-off (local storage): set when you turn Microsoft Clarity off in this browser, so that it does not load again. It stays until you turn Clarity back on or clear site data.
• A pending call booking (session storage), kept until our server records it.
• elvina-academy-v1 and elvina-pilot-brief-v1 (local storage): your Academy lesson progress and the pilot brief you prepare. They stay in this browser and are not sent to us.

We keep personal data for as long as we need it for the purposes in this Policy and for legitimate purposes such as security, accounting and tax, and resolving disputes. Most of the records below do not expire automatically. To ask us to delete them, email privacy@contentbuilder.ai: we verify requests and handle them as applicable law requires, subject to its exceptions (section 15).

• Conversations with Elvina, including voice transcripts, and the customer card our team keeps for them: kept so that you can continue the conversation and our team can follow up, while the conversation can lead to work with you. They are not deleted automatically. The cookie that reopens a conversation expires after 30 days.
• Form requests and contacts from conversations with Elvina, in our request log and in HubSpot: kept while we reply, prepare and follow up, and while you remain a contact or customer.
• Team alerts in Telegram and messages handled by ManyChat: kept while we arrange and follow up on the call; ManyChat and Meta also keep messages under their own terms.
• Visit events: kept while we use them to understand how visitors find us; they carry no name or email and are not deleted automatically.
• Website and security logs, which record your network address with each request: kept for up to thirty days.
• Microsoft Clarity data, when Clarity is switched on: recordings generally for 30 days; labeled or favorited sessions and a random sample of recordings for up to 9 months; heatmaps and click data for up to 9 months.
• Records our chat service keeps about conversations, such as tool use, usage and payments: kept with the conversation and not deleted automatically.
• Network addresses used for chat and voice-call limits are kept in hashed form in our chat service’s rate-limit records. Rate-limit entries older than one day are removed during later chat requests; records of closed voice calls are removed when the call registry is next saved, three or more days after the call was created, and a call still in progress may stay longer. The copy linked to your access to a conversation stays with that conversation.
• Browser storage: stays in your browser until it is replaced or you clear site data, as section 12 describes.
• Voice call audio: not recorded or stored by us. OpenAI may keep API data for abuse monitoring, normally for up to 30 days, with the exceptions its data policies describe.
• Payment records: kept for as long as accounting and tax law requires.

We maintain administrative, technical and physical safeguards, such as encryption in transit, access controls on our servers and a team login for our dashboard. No system is 100% secure: please do not send passwords or other secrets through the Site, and report suspicious activity to privacy@contentbuilder.ai. The security page of this website describes how data and approvals are handled in a pilot.

Depending on where you live, you may have the right to the following. To use any of them, email privacy@contentbuilder.ai. We may verify your identity, for example by email, and you may appoint an authorized agent where the law allows. We act on verified requests as applicable law requires, subject to its exceptions, and tell you what we must keep and why. We will not discriminate against you for using your rights. To appeal a decision on your request, reply to it or email privacy@contentbuilder.ai with the subject "Privacy appeal"; we review appeals within the period the law sets and, if we deny one, explain how to contact your regulator.

• Access and portability: receive a copy of your data.
• Rectification: correct inaccurate data.
• Deletion: ask us to delete your data, including a conversation with Elvina, the request log and CRM records about you and copies sent to our team tools.
• Restriction and objection, for example to marketing or to the use of your conversation to improve Elvina.
• Opt out of marketing: unsubscribe or write to us.
• Limit the use and disclosure of sensitive personal data, where applicable.
• Withdraw consent, where processing relies on consent.
• Not be subject to solely automated decisions with legal or similarly significant effects. Elvina does not make such decisions about you; hiring and other decisions about people are made by people.

The Site is intended for users 18 and older and is not directed to children under 13. We do not knowingly collect their data. If you are a parent or guardian and believe a child has given us personal data, contact privacy@contentbuilder.ai and we will delete it.

We are SmartExpert Inc., based in California, in the San Francisco Bay Area, United States. Your data is processed in the United States and in other countries where our service providers operate, which may have different data protection standards. Where the law requires a transfer mechanism, we rely on Standard Contractual Clauses or another lawful mechanism, with additional safeguards where needed.

For residents of California, Colorado, Connecticut, Virginia and other U.S. states with privacy laws, this section sets out our practices in the terms those laws use. The summary at the top of this page is our notice at collection; the points below give the detail.

• Categories collected (as defined by law): identifiers (name, email, phone, network address, the random visitor ID, Instagram handle, ManyChat contact reference); commercial information (the first step you bought and its payment status, and the budget and price answers you give on the project form); internet or other electronic network activity (pages opened, chat steps, campaign tags, logs); audio information (voice call audio, which we do not record or store; OpenAI processes it as section 13 describes); professional information (company and role); communications (your messages, files and form text); inferences (what your business needs, drawn from your answers, to tailor Elvina’s replies and to brief our team, and the group the project questionnaire places your request in).
• Sources: you, your browser, Calendly, Stripe and ManyChat.
• Purposes: replying to you, preparing demos, calls and materials, and following up on your request; running the conversation with Elvina and the first paid step; security and abuse prevention; learning which channels lead to useful conversations; improving Elvina and the Site; marketing only with your opt-in; legal compliance.
• Disclosed for business purposes to: hosting providers, AI model providers, our customer-relationship and team tools, booking, payment and email providers, analytics, and recipients you choose, as section 10 lists.
• Retention: identifiers, professional details, communications and inferences while we handle and follow up on your inquiry or customer relationship; commercial information: payment records as accounting and tax law requires, and the budget and price answers you give on the project form for as long as we keep that request; network activity: visit events while we use them, website and security logs for up to thirty days, and browser storage for the periods described in section 12; Clarity retention periods are described in section 13; call audio is not stored by us. Section 13 gives the detail for each record.
• Sensitive personal information. We do not ask for it and do not use it to infer characteristics about you. Please do not send it.
• Sale and sharing. We do not sell personal data for money. When Microsoft Clarity is switched on, disclosures of website usage data to Microsoft through Clarity may constitute "sale" for other valuable consideration or "sharing" for cross-context behavioral advertising under California law. You can opt out of these Clarity disclosures with a Global Privacy Control signal, which we honor, or with the switch in section 12. We do not knowingly sell or share the data of consumers under 16.
• Rights. Know and access, delete, correct and portability; opt out of targeted advertising or certain profiling; limit the use and disclosure of sensitive data; non-discrimination.
• How to make a request. Email privacy@contentbuilder.ai. We verify requests and honor authorized agents as the law provides; appeals work as section 15 describes.

Before a voice call starts, the chat tells you that you are talking to Elvina, a digital employee (AI), not a person, and that OpenAI processes your audio and the recent messages in this chat to generate her replies; the call starts only after you confirm. We do not record or store the audio, and we do not use your voice or your image to identify you or to build a voiceprint.

Do not enter passwords, keys, health or payment data, or confidential source material into any form or conversation on this website. For a real pilot, data categories, retention, deletion, hosting and subprocessors are agreed in writing first.

We may update this Policy from time to time. We will update the effective date and, where required, notify you, for example by email or in the chat. Continued use of the Site after changes take effect constitutes acceptance.

Questions or concerns? Contact privacy@contentbuilder.ai and we will try to resolve them. You may also lodge a complaint with your data protection authority (EU, UK or Switzerland).

Email: privacy@contentbuilder.ai. Mail: SmartExpert Inc. (d/b/a "ContentBuilder"), Attn: Privacy, 690 Saratoga Ave, 1st floor, San Jose, CA 95129, United States.

Where the law requires it, we may appoint representatives in the EU or the UK and will publish their contact details in this Policy. Residents of Brazil (LGPD) or Canada (PIPEDA) can use the rights in section 15 through the same contact.