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logo elephan ai - elephan.ai
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logo elephan ai - elephan.ai
logo elephan ai - elephan.ai

Elephan Privacy Notice

Elephan Privacy Notice

Elephan Privacy Notice

Elephan Privacy Notice

Introduction

We, at Elephan Soluções em Tecnologia Ltda, a private legal entity, enrolled with the CNPJ do MF under No. 55.386.224/0001-75, with headquarters at Rua Harmonia, No. 445, apartment No. 102, Sumarezinho district, CEP 05.435-000, in the city of São Paulo, State of São Paulo (“Elephan”), take your privacy and the protection of your data seriously, which is why this Privacy Notice (“Notice”) publicly explains how we process your Personal Data, what your rights are, and how you can exercise them.

This Notice is part of our Compliance Program with the Lei Geral de Proteção de Dados Pessoais and other sector-specific laws on the matter and, therefore, must be read and interpreted together with the current data protection laws.

From the content presented, you will be able to understand by which means personal data are collected and/or processed, how such collection or processing and use occur, among other processing activities that are carried out. After all, Elephan is the Data Operator (Operadora de Dados), and is responsible within the limits of its respective obligations.

1. Basic Concepts: What do you need to know to understand this Notice?

For the sole purpose of facilitating the reading of this Privacy Notice, Elephan presents below some useful definitions for its interpretation and full understanding:

Term

Term

Explanation

Explanation

Personal Data

Personal Data

It is information related to a natural person that is capable of identifying the person or making it possible to identify them. Examples of personal data that may allow your identification include: name, CPF, phone number, e-mail, name of the legal representative(s), etc.

It is information related to a natural person that is capable of identifying the person or making it possible to identify them. Examples of personal data that may allow your identification include: name, CPF, phone number, e-mail, name of the legal representative(s), etc.

Sensitive Personal Data

Sensitive Personal Data

Sensitive personal data include data on racial or ethnic origin, religious belief, political opinion, membership in a trade union or an organization of a religious, philosophical, or political nature, data concerning health or sex life, genetic or biometric data, when linked to a natural person.

Sensitive personal data include data on racial or ethnic origin, religious belief, political opinion, membership in a trade union or an organization of a religious, philosophical, or political nature, data concerning health or sex life, genetic or biometric data, when linked to a natural person.

Processing

Processing

It is any form of use that Elephan may make of your Personal Data, including, but not limited to, the following activities: collection, processing, storage, consultation, use, sharing, transmission, classification, reproduction, deletion, and assessment.

It is any form of use that Elephan may make of your Personal Data, including, but not limited to, the following activities: collection, processing, storage, consultation, use, sharing, transmission, classification, reproduction, deletion, and assessment.

Data Subject

Data Subject

It is you, the natural person to whom the Personal Data relate.

It is you, the natural person to whom the Personal Data relate.

Elephan

Elephan

Elephan is a company that offers a commercial intelligence solution focused on recording, transcribing, and analyzing meetings, facilitating customer service, negotiations, and the management of strategic business data.

Elephan is a company that offers a commercial intelligence solution focused on recording, transcribing, and analyzing meetings, facilitating customer service, negotiations, and the management of strategic business data.

Controller

Controller

Processing agent responsible for making the essential decisions regarding the Processing of personal data, such as defining the purpose of the Processing activities, including those Processing activities to be carried out by Operators on its behalf.

Processing agent responsible for making the essential decisions regarding the Processing of personal data, such as defining the purpose of the Processing activities, including those Processing activities to be carried out by Operators on its behalf.

Operator

Operator

Processing agent that must act in the Processing of personal data, when delegated by the Controller, within the limits and scope of the agreed instructions, and may not carry out Processing in a manner different from the instructions given.

Processing agent that must act in the Processing of personal data, when delegated by the Controller, within the limits and scope of the agreed instructions, and may not carry out Processing in a manner different from the instructions given.

Person in Charge

Person in Charge

This is our Data Protection Officer (Data Protection Officer - DPO), who acts as a communication channel between Elephan, Data Subjects, and the Autoridade Nacional de Proteção de Dados regarding the protection of your personal data.

This is our Data Protection Officer (Data Protection Officer - DPO), who acts as a communication channel between Elephan, Data Subjects, and the Autoridade Nacional de Proteção de Dados regarding the protection of your personal data.

Legal bases

Legal bases

These are the legal grounds that authorize us to process personal data: consent, legal and/or regulatory obligation, for example.

These are the legal grounds that authorize us to process personal data: consent, legal and/or regulatory obligation, for example.

2. How and which personal data are collected and/or received?

The types of Personal Data and the way in which Elephan collects or processes them depend on how you, as a data subject, relate to the company’s activities and why. In other words, the Personal Data collected and/or processed will differ depending on whether you are a candidate for a job opening or a customer who has contracted or intends to contract the services provided by Elephan.

Processing Purposes

Processing Purposes

Types of personal data

Types of personal data

Legal basis

Legal basis

Record of your access to the website

Record of your access to the website

Data collected through cookies, including IP address, date and time of access, geographic location

Data collected through cookies, including IP address, date and time of access, geographic location

Compliance with a Legal or Regulatory Obligation (Marco Civil da Internet)

Compliance with a Legal or Regulatory Obligation (Marco Civil da Internet)

Forwarding your expression of interest to the person in charge (Free trial)

Forwarding your expression of interest to the person in charge (Free trial)

Full name, phone or mobile, e-mail, CPF, full address.

Full name, phone or mobile, e-mail, CPF, full address.

Contract performance or preliminary steps

Contract performance or preliminary steps

Management of services provided to clients

Management of services provided to clients

Name and e-mail

Name and e-mail

Contract performance

Contract performance

Video and/or audio recording of the meeting for the provision of services to clients

Video and/or audio recording of the meeting for the provision of services to clients

Name, e-mail, image and voice data

Name, e-mail, image and voice data

Contract performance

Contract performance

Sending an e-mail with meeting summaries

Sending an e-mail with meeting summaries

Name and e-mail

Name and e-mail

Contract performance

Contract performance

Logging messages via WhatsApp

Logging messages via WhatsApp

Nome e telefone

Nome e telefone

Contract performance

Contract performance

Sending marketing e-mail

Sending marketing e-mail

Name and e-mail

Name and e-mail

Consent

Consent

Customer Support (SAC)

Customer Support (SAC)

Name and e-mail

Name and e-mail

Compliance with a legal obligation

Compliance with a legal obligation

If you have any questions about this item, please contact us; we will be happy to assist you through our contact channels made available at the end of this Notice.

3. With whom does Elephan share your data?

In certain situations, we need to share your Personal Data with third parties that provide services on our behalf. Below, you will identify the situations in which we may share your Personal Data.

Public Authorities

Public Authorities

If a judge or an authority with legal competence requires Elephan to share certain personal data for, for example, an investigation, we will share them. We oppose any abuse of authority and, if Elephan understands that a given order is abusive, we will always defend data subjects’ privacy.

If a judge or an authority with legal competence requires Elephan to share certain personal data for, for example, an investigation, we will share them. We oppose any abuse of authority and, if Elephan understands that a given order is abusive, we will always defend data subjects’ privacy.

Third Parties

Third Parties

With partner companies and suppliers, in the development and provision of services made available to you, especially cloud storage companies.

With partner companies and suppliers, in the development and provision of services made available to you, especially cloud storage companies.

Companies involved in changes to the corporate structure (due to merger, acquisition, spin-off, etc.)

Companies involved in changes to the corporate structure (due to merger, acquisition, spin-off, etc.)

As our operations develop, we may buy or sell other companies and services. In such cases, user information is usually one of the transferred assets, remaining, however, subject to the conditions defined in existing Privacy Notices (unless you consent to other forms of use). In addition, in the unlikely event that Elephan or substantially all of its assets are acquired by third parties, user information will be one of the transferred assets.

As our operations develop, we may buy or sell other companies and services. In such cases, user information is usually one of the transferred assets, remaining, however, subject to the conditions defined in existing Privacy Notices (unless you consent to other forms of use). In addition, in the unlikely event that Elephan or substantially all of its assets are acquired by third parties, user information will be one of the transferred assets.

Protection of Elephan and third parties

Protection of Elephan and third parties

We provide accounts and other personal information when we believe such disclosure is appropriate to comply with the law or our regulatory obligations; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of Elephan, our users, or third parties. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

We provide accounts and other personal information when we believe such disclosure is appropriate to comply with the law or our regulatory obligations; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of Elephan, our users, or third parties. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

Elephan further declares that it does not share data with third parties for the purpose of training public artificial intelligence models, nor for commercial analysis, marketing, or any purposes not related to the performance of its services.

4. How long are your personal data stored?

Following the guidelines of the Lei Geral de Proteção de Dados, Elephan stores your Personal Data only for as long as necessary to fulfill the purposes for which they were collected, unless there is any other reason for their retention, such as compliance with legal or contractual obligations, among others permitted by law, as per the illustrative table below:

Type of Data

Type of Data

Retention Period

Retention Period

Legal basis

Legal basis

Budget registration data

Budget registration data

Budget registration data: 5 (five) years from the first record.

Budget registration data: 5 (five) years from the first record.

Articles 12 and 34 of the Código de Defesa do Consumidor.

Articles 12 and 34 of the Código de Defesa do Consumidor.

Browsing data

Browsing data

6 (six) months

6 (six) months

Article 15 of the Marco Civil da Internet.

Article 15 of the Marco Civil da Internet.

Other Data

Other Data

For as long as the relationship lasts and there is no request for deletion or withdrawal of consent.

For as long as the relationship lasts and there is no request for deletion or withdrawal of consent.

Article 9, item II, of the Lei Geral de Proteção de Dados Pessoais.

Article 9, item II, of the Lei Geral de Proteção de Dados Pessoais.

5. What are the rights of Data Subjects?

Your Personal Data belong to you, and Brazilian law guarantees you a series of rights related to them. We are committed to complying with these rights and, in this section, we will explain what these rights are and how you can exercise them.

Your Rights

Your Rights

Explanation

Explanation

Confirmation and Access

Confirmation and Access

You may request from Elephan confirmation as to whether your Personal Data are being processed so that, if so, you may access them, including by requesting copies of the records we have about you.

You may request from Elephan confirmation as to whether your Personal Data are being processed so that, if so, you may access them, including by requesting copies of the records we have about you.

Correction

Correction

You may request the correction of your Personal Data if they are incomplete, inaccurate, or outdated.

You may request the correction of your Personal Data if they are incomplete, inaccurate, or outdated.

Anonymization, blocking, or deletion

Anonymization, blocking, or deletion

You may request (a) the anonymization of your Personal Data, so that they can no longer be related to you and, therefore, cease to be Personal Data; (b) the blocking of your Personal Data, temporarily suspending our ability to process them for certain purposes; and (c) the deletion of your Personal Data, in which case we must erase all your Personal Data with no possibility of reversal.

You may request (a) the anonymization of your Personal Data, so that they can no longer be related to you and, therefore, cease to be Personal Data; (b) the blocking of your Personal Data, temporarily suspending our ability to process them for certain purposes; and (c) the deletion of your Personal Data, in which case we must erase all your Personal Data with no possibility of reversal.

Portability

Portability

You may request that Elephan provide your Personal Data in a structured and interoperable format for transfer to a third party, provided that such transfer does not violate Elephan’s intellectual property or trade secrets.

You may request that Elephan provide your Personal Data in a structured and interoperable format for transfer to a third party, provided that such transfer does not violate Elephan’s intellectual property or trade secrets.

Information about the possibility of not consenting

Information about the possibility of not consenting

You have the right to receive clear and complete information about the possibility and consequences of not providing consent. Your consent, when required, must be free and informed. Therefore, whenever we request your consent, you will be free to deny it - in such cases, it may not be possible to provide the services.

You have the right to receive clear and complete information about the possibility and consequences of not providing consent. Your consent, when required, must be free and informed. Therefore, whenever we request your consent, you will be free to deny it - in such cases, it may not be possible to provide the services.

Withdrawal of consent

Withdrawal of consent

If you have consented to any purpose for processing your Personal Data, you may always choose to withdraw your consent. However, this will not affect the lawfulness of any Processing carried out prior to the withdrawal. If you withdraw your consent, we may be unable to provide services to you, but we will notify you when that occurs.

If you have consented to any purpose for processing your Personal Data, you may always choose to withdraw your consent. However, this will not affect the lawfulness of any Processing carried out prior to the withdrawal. If you withdraw your consent, we may be unable to provide services to you, but we will notify you when that occurs.

Opposition

Opposition

The law authorizes the processing of Personal Data even without your consent or a contract with us. In such situations, we will only process your Personal Data if we have legitimate grounds to do so. If you do not agree with any purpose for processing your Personal Data, you may object and request its interruption.

The law authorizes the processing of Personal Data even without your consent or a contract with us. In such situations, we will only process your Personal Data if we have legitimate grounds to do so. If you do not agree with any purpose for processing your Personal Data, you may object and request its interruption.

On this subject, it is emphasized that you are not required to provide the Personal Data we request; however, if you choose not to provide them, we may not be able to assist you with our services or answer your questions. For your security, whenever you submit a request to exercise your rights, Elephan may request additional information and/or documents in order to prevent fraud.


In some cases, Elephan may have legitimate reasons not to comply with a request to exercise rights. Such situations may occur where the disclosure of specific information could violate Elephan’s or third parties’ intellectual property rights or trade secrets.


When requests are eligible to be met, they may not be answered immediately. However, Elephan undertakes to respond to all requests within a reasonable time and always in accordance with applicable law.


If you wish to submit a request, contact Elephan’s Data Protection Officer (DPO) via e-mail at henrique@elephan.ai.

6. How does Elephan protect your Data?

Our responsibility is to take care of your Personal Data and use them only for the purposes described in this Notice. To ensure your privacy and the protection of your Personal Data, we adopt advanced technological resources to ensure the security of all data processed by Elephan.


Among the security measures implemented are network and systems access controls, antivirus and firewall adoption, as well as the promotion of national and international best practices in Information Security.


Despite all the attention devoted to the privacy of your data, we cannot guarantee total security. Unauthorized access and use by third parties of your information, hardware or software failures beyond Elephan’s control, and other external factors may compromise the security of your Personal Data.


Your role is essential to maintaining a safe environment for everyone. Therefore, if you identify or become aware of any factor that compromises the security of your data in your relationship with Elephan, please contact us.

  1. Data Incidents and Notifications

The Lei Geral de Proteção de Dados defines a “personal data breach” as a security breach that leads to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored, or otherwise processed.


In the event of an information security incident involving destruction, loss, alteration, unauthorized access, or an incident involving Personal Data that causes relevant harm to the Data Subject (after assessment), we will communicate the incident to the Data Subject and/or the ANPD, at minimum using the requirements and information set out by the Autoridade Nacional de Proteção de Dados.

8. Questions? Talk to our officer in charge

If you believe that your Personal Data have been processed in a manner incompatible with this Notice or with your choices as the Data Subject of your Personal Data, if you have learned of any incident involving Personal Data processed by Elephan, or if you have questions, comments, or suggestions related to this Notice and how we process your Personal Data, please contact us. We have a Data Protection Officer available at the following contact address:


Data Protection Officer (DPO): Henrique Machado.


Contact e-mail:
henrique@elephan.ai

Mailing address:

Rua Harmonia, No. 445, Sumarezinho district, in the city of São Paulo/SP, CEP: 05.435-000

9. Changes to the Privacy Notice

As we are always seeking to improve our services and the way we operate, this Notice may be updated to reflect improvements made. Therefore, Elephan recommends visiting this page periodically so that you are aware of any changes implemented!


Last updated date: September 8, 2025