Privacy notice
What personal data Eleva uses, why, who we share it with, and the rights you have over it.
Last updated 10 November 2026
1. Who the controller is
The controller of the platform's data is BÚZIOS E TARTARUGAS - LDA ("Eleva"), NIPC 515001708, Rua Gil Vicente 2, 2775-198 Parede, Portugal.
- Data protection contact: privacy@eleva.care. Our privacy team reads every message sent to this address and answers privacy questions and requests.
- Data protection officer (DPO): we are appointing an external DPO. We will publish their contact details here and notify them to the Comissão Nacional de Proteção de Dados (CNPD) as soon as they start. privacy@eleva.care will always reach them.
2. Our role
- Eleva is an intermediary: it does not provide healthcare. The experts you choose are independent professionals.
- Eleva is the controller of account, booking, payment, communications and support data.
- The expert is the controller of the clinical content of your relationship with them (intake forms, notes, transcripts and reports). Eleva stores that content as a processor, on the expert's instructions. See the Health data notice and the Data processing agreement.
- For a booking with a clinic on Eleva, the clinic is the controller of the clinical content and issues your invoice; Eleva is its processor.
3. Data we process
- Account: name, email, phone number (if you give it, for example for SMS reminders), language and preferences.
- Bookings: expert, service, date, mode, cancellation policy applied, cancellations and refunds, and your confirmation that you are 18 or older and booking the session for yourself.
- Payments: amount, payment and refund status, promo code used and NIF, if you give it. Card details are handled by Stripe; Eleva does not store them.
- Online sessions: live audio and video, processed by Daily only to run the call, and video call join and leave logs. Session recording is turned off.
- Session records (health data): what you share before the session, the expert's notes, the report and, only if you turn it on, the live transcript. The text is encrypted at the application layer, with keys kept apart from the data, so Eleva staff cannot open it in normal operation. Files uploaded for a session are encrypted at rest by our storage provider, and access is limited.
- Communications: booking and reminder emails and SMS, and support requests.
- Technical data: IP address, browser and device of each sign-in session, security logs and errors, and the technical signals of the automated bot check that runs when you reserve, confirm or pay for a booking.
- Experts: identity, professional licence number (cédula profissional) and professional body (Ordem), ERS registration, verification and payment data collected by Stripe, and the tax data required by DAC7.
- Consents and confirmations: what you accepted or confirmed, when, and which version of the document.
If you book without an account. After your booking is confirmed, we create a member account in your name, linked to the email you used, with a personal Space where the booking lives. We do this so your booking has a home: you can see it, reschedule or cancel it under its policy, and find your session records later. We do not send you a separate sign-in email for this account, and you do not need it to join your session: the link in your confirmation email is enough. To use the account, sign in with the same email (by email link or with Google). If you do not want it, write to privacy@eleva.care and we delete it. See section 7 for how long we keep an account you never use.
What you must give us. To book, we need your name and email, the payment for a paid session, and your confirmation that you are 18 or older and booking for yourself. For a phone session we also need your phone number. Your NIF, a promo code and anything you share with the expert before the session are optional. Without the required details we cannot make the booking.
4. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Creating and managing your account, booking sessions, sending confirmations and reminders, giving access to the video call | Performance of the contract (GDPR, art. 6(1)(b)); for health data, see "Health data in your booking" below |
| Creating a member account and personal Space after a booking made without an account | Performance of the contract (art. 6(1)(b)) |
| Confirming that bookings are made by adults, for themselves | Performance of the contract (art. 6(1)(b)); legitimate interest in protecting minors (art. 6(1)(f)) |
| Collecting, refunding and transferring payments; sending your NIF to the expert for the invoice | Performance of the contract; legal obligation (art. 6(1)(c)) |
| Keeping accounting and tax records | Legal obligation |
| Storing session records on the expert's instructions | The expert's basis: provision of healthcare (art. 9(2)(h), and Law 58/2019, art. 29) |
| Live session transcription | Your explicit consent (art. 9(2)(a)), which you can withdraw at any time |
| AI draft of the session report from the expert's notes and the text you typed when booking | Your explicit consent to AI processing (art. 9(2)(a)), which you can withdraw at any time |
| Proving attendance at a session and responding to payment disputes | Legitimate interest (art. 6(1)(f)); establishment, exercise or defence of legal claims |
| Security, fraud and abuse prevention, including the automated bot check at booking and payment | Legitimate interest |
| Verifying experts and reporting their income to the AT (DAC7) | Legal obligation |
| Newsletter and marketing communications | Consent, which you can withdraw at any time |
Health data in your booking. A booking with a health professional, and anything you write for the expert before the session, can reveal information about your health. Eleva processes this information on two conditions of art. 9(2) GDPR:
- Health care (art. 9(2)(h) and 9(3)). It is needed to arrange and deliver the care you ask for from a health professional bound by professional secrecy. Everyone at Eleva who handles it is bound by the same duty of secrecy (Law 58/2019, art. 29).
- Your explicit consent (art. 9(2)(a)). When you book, you give your explicit consent for Eleva, as the intermediary, to process the health information in your booking and to pass what you write before the session to your expert. You can withdraw it in your privacy settings or by writing to privacy@eleva.care. While you have an upcoming confirmed booking, cancel it first under its policy; we keep the booking information we need for care already arranged and for our legal duties.
We do not use health data for advertising.
5. Recipients
- The expert you book receives the data needed for the session: your name, contact details, booking details, what you share before the session and your NIF, if you give it.
- Processors that help us operate the platform (hosting, database, email, SMS, video, payments and error monitoring), under a contract in line with art. 28 GDPR. The current list is in Sub-processors.
- Beehiiv provides the Femme Focus newsletter sign-up form. It loads only if you allow marketing in Cookie settings, and then receives what you enter to subscribe.
- Stripe also acts as an independent controller for its own legal obligations, for example identity verification and fraud prevention.
- Google or Microsoft, if you choose to sign in with those accounts, act as independent controllers.
- The Autoridade Tributária e Aduaneira, for the experts' tax data required by DAC7.
- Authorities and courts, when the law requires it.
6. International transfers
Our data is hosted in the European Union (Frankfurt), unless the sub-processor list states otherwise. Some providers, or their support teams, access data from the United States. In those cases, the transfer is based on the EU-US Data Privacy Framework and the European Commission's standard contractual clauses. See the details in Sub-processors.
7. Retention
| Data | Period |
|---|---|
| Account data | While the account exists; after a deletion request, deleted or anonymised, except what the law requires us to keep |
| Account created after a booking without an account, never used | Deleted 12 months after your last booking ends, unless you start using it |
| Bookings, attendance and your 18+ confirmation | 10 years, because they support payment and tax records |
| Session records (intake, notes, transcript, report) | 7 years after the last session |
| Files uploaded for a session | 7 years after the last session |
| Invoices, receipts and payment records | 10 years |
| AI drafts not accepted by the expert | 90 days |
| Notification delivery logs | 365 days |
| Support messages and complaints | 3 years after the matter is closed, longer while a dispute is open |
| Privacy requests | The record of the request: 3 years after it is closed. Your data export file: deleted when its download link expires, 24 hours after it is ready |
| Newsletter and marketing | Until you unsubscribe; then we keep only your address on a suppression list, so we do not write to you again |
| Consent records | While the consent is relied on and for the limitation period |
| Security logs | Up to 1 year |
When an account you never used is deleted, the booking and payment records stay for their own period, without a login attached.
8. Your rights
You have the right of access, rectification, erasure, restriction, portability and objection, and you can withdraw your consent at any time, without affecting processing already carried out.
- Write to privacy@eleva.care. We reply within one month, which can be extended by two further months for complex requests, in which case we tell you. This works whether or not you have an account. To protect you, we confirm the request through the email address linked to your booking or account.
- For clinical content, for which the expert is the controller, we may forward your request to the expert and help them respond.
- You can complain to the CNPD, Av. D. Carlos I, 134, 1.º, 1200-651 Lisbon, www.cnpd.pt.
9. Security
Session records are encrypted at the application layer, health files are kept in private storage, access is limited to the roles that need it and video recording is turned off. See the Security page.
10. Artificial intelligence and cookies
- Eleva's AI tools help experts write and translate the public text of their profile and services; those requests do not include member data or health data.
- An AI draft of a session report, built from the expert's notes and the text you typed when booking, only works with your specific consent to AI processing and with a model that has zero data retention. The expert reviews the draft; if they do not accept it, it is deleted after 90 days. See the AI processing notice.
- We do not use analytics or advertising cookies. Each cookie we use is listed by name in the Cookie policy.
11. Minors
Eleva is for adults. To create an account or book a session, you must be 18 or older, and you book sessions for yourself. When you book, you confirm this with a checkbox, and we keep that confirmation with the booking.
To arrange care for someone under 18, contact the expert directly. If we learn that a booking was made for someone under 18, we cancel it, refund what was paid and delete the data we are not required to keep.
12. Changes
If we change this notice in a material way, we tell you before the change takes effect. The date of the last update is at the top of the page.
If the language versions differ, the Portuguese version prevails.