Privacy Policy

1. Who We Are

Eluvera OÜ is a research-first leader and leadership development and organizational wellbeing company registered in Estonia (EU). This privacy policy explains how we collect, use, store, and protect your personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

Data Controller: Eluvera OÜ, Estonia
Contact: hello@eluvera.com

2. Data We Collect

We may collect the following categories of personal data:

• Contact information: name, email address, organization, role — provided when you contact us or submit a form.
• Usage data: pages visited, time on site, browser type, device information — collected via analytics cookies with your consent.
• Research data: if you participate in our research programs, we may collect assessment responses, behavioral data, and other information as described in specific research consent forms.

3. How We Use Your Data

We process personal data for the following purposes:

• To respond to your inquiries and provide our services
• To improve our website and user experience
• To conduct and support scientific research (with separate informed consent)
• To comply with legal obligations

4. Legal Basis for Processing

We process your data based on one or more of the following legal grounds under GDPR:

• Consent (Article 6(1)(a)) — for analytics cookies and marketing communications
• Contractual necessity (Article 6(1)(b)) — to provide services you have requested
• Legitimate interest (Article 6(1)(f)) — to improve our services and website functionality

5. Cookies

We use the following categories of cookies:

• Essential cookies: required for the site to function. These cannot be disabled.
• Analytics cookies: help us understand how visitors use our site. Only activated with your consent.
• Marketing cookies: used to deliver relevant content and measure campaign effectiveness. Only activated with your consent.

You can manage your cookie preferences at any time using the cookie banner or by contacting us.

6. Data Sharing

We do not sell your personal data. We may share data with trusted service providers (e.g., hosting, analytics) who process it on our behalf under strict data processing agreements. For research purposes, data is anonymized or pseudonymized before any sharing or publication.

7. Data Retention

We retain personal data only as long as necessary for the purposes outlined above. Contact form data is retained for up to 24 months. Research data retention is governed by specific research protocols and consent agreements. Cookie consent preferences are stored locally on your device.

8. Your Rights

Under GDPR, you have the right to:

• Access your personal data
• Rectify inaccurate data
• Request erasure of your data
• Restrict or object to processing
• Data portability
• Withdraw consent at any time
• Lodge a complaint with your local data protection authority

To exercise any of these rights, contact us at hello@eluvera.com.

9. International Transfers

As an EU-registered company, we process data within the European Economic Area (EEA) wherever possible. Where data is transferred outside the EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

10. Changes to This Policy

We may update this privacy policy from time to time. Changes will be posted on this page with an updated revision date. We encourage you to review this page periodically.

Contact

If you have questions about this policy or our data practices, contact us at:
hello@eluvera.com
Eluvera OÜ, Estonia