Data Protection
emeryAI

As of: April 2026

We are pleased about your interest in our website. The protection of your personal data is of great importance to us.

This privacy policy informs you about what personal data we process on this website, in the emeryAI Dashboard, and in the emeryAI Interface, and for what purposes.

1. Supervisor

Controller within the meaning of the General Data Protection Regulation (GDPR) is:

Elevate GmbH
Infanteriestraße 11a / Building B2
80797 Munich
Germany

Represented by the Managing Directors: Patrick Wachner, Karolina Orawski

Tel: +49 (0)89 – 991 226 58
Email: [email protected]
Registration number: HRB 226101 Munich District Court

2. Scope

This privacy policy applies to the website www.emeryai.com, the embedded emeryAI conversational interface on the website, as well as the emeryAI Dashboard (customer administration interface). The website is a standalone web presence for the emeryAI brand, operated by Elevate GmbH.

3. Collection and processing of personal data

You can generally visit our website without providing any personal information. Personal data is only collected if you voluntarily provide it to us as part of an inquiry, registration, or use of our services. This may include, in particular, your name, email address, phone number (optional), and the content of your inquiry.

4. Purposes of Processing

We process personal data to provide the website, process inquiries, communicate with users, and improve our services.

5. Legal Basis for Processing

Processing is carried out on the basis of Art. 6(1)(a) GDPR (consent), Art. 6(1)(b) GDPR (contract or pre-contractual measures), and Art. 6(1)(f) GDPR (legitimate interest). Our legitimate interest lies in particular in the secure and efficient provision of our website and services.

6. Hosting and Server Log Files

This website is hosted by Raidboxes GmbH (Münster, Germany). When you access the website, information is automatically collected that your browser transmits. This includes in particular your IP address, date and time of the request, browser type and version, operating system, referrer URL, the page accessed, and the amount of data transferred and the HTTP status code. This data is technically necessary to display the website correctly and to ensure stability and security. The server log files are automatically deleted after 30 days. The legal basis is Article 6(1)(f) of the GDPR (legitimate interest in the secure and efficient provision of the website).

7. Contact

When you contact us (e.g., by email or form), your information will be stored for the purpose of processing your request and for any follow-up questions. The legal basis is Art. 6 para. 1 lit. b GDPR (pre-contractual measures) or Art. 6 para. 1 lit. f GDPR (legitimate interest in processing your request).

8. Cookies

Our website uses cookies. These are small text files that are stored on your device. Cookies are used to make our website more user-friendly, effective, and secure. Where necessary, we obtain your consent via a cookie banner. You can find more information about the cookies used in the following sections on the respective services.

9. Google Tag Manager

We use Google Tag Manager, a service of Google LLC. Google Tag Manager is used to manage website tags through an interface. The tool itself does not process personal data, but it triggers other tags, which in turn may collect data. This is done on the basis of our legitimate interest in efficient website management and optimization in accordance with Art. 6(1)(f) of the GDPR. The company is certified under the „EU-US Data Privacy Framework“ (DPF). Further information: https://www.dataprivacyframework.gov/list.

10. Google Analytics

This website uses Google Analytics, a web analytics service provided by Google LLC. Google Analytics uses cookies, which enable an analysis of your use of the website. The information generated by cookies about your use of this website is usually transmitted to a Google server and stored there. We use Google Analytics exclusively with IP anonymization enabled. This means that your IP address will be shortened beforehand within the European Union or in other contracting states of the European Economic Area. The use of Google Analytics is based on your consent according to Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time via the cookie banner. Further information can be found in Google's privacy policy: https://policies.google.com/privacy.

11. Mailchimp (Newsletter)

We use Mailchimp, a service from Intuit Inc., to send out our newsletter. If you sign up for our newsletter, the data you enter (e.g., email address) will be transferred to Mailchimp and stored there. Mailchimp may use this data to analyze user behavior (e.g., open rates, click behavior) in order to optimize the newsletter. The processing is carried out based on your consent in accordance with Art. 6 (1) lit. a GDPR. You can unsubscribe from the newsletter at any time via the unsubscribe link in the newsletter or by notifying us. You can find more information in Mailchimp's privacy policy: https://mailchimp.com/legal/privacy/.

12. Content Delivery Network (Cloudflare)

We use the Content Delivery Network (CDN) of Cloudflare Inc, 101 Townsend St, San Francisco, CA 94107, USA. Cloudflare acts as an intermediary between your browser and our web server. All requests to our website are routed via Cloudflare servers. Cloudflare can process technical data, in particular your IP address, the content accessed, browser type and version as well as the date and time of access. This serves to speed up the delivery of our website content and to protect against attacks (e.g. DDoS protection). Cloudflare stores temporary log files on the server side, which are usually deleted within 24 hours. The use is based on our legitimate interest in the secure and high-performance provision of our website in accordance with Art. 6 para. 1 lit. f GDPR. Cloudflare is certified in accordance with the EU-US Data Privacy Framework (DPF). Further information can be found in Cloudflare's privacy policy: https://www.cloudflare.com/privacypolicy/.

13. Bunny Stream

We use the streaming service Bunny Stream to embed videos on our website. The provider is BunnyWay d.o.o., Dunajska cesta 165, 1000 Ljubljana, Slovenia (hereinafter „Bunny Stream").

When a page with an embedded video is accessed, a connection is established with Bunny Stream's servers. Technical connection data such as the IP address, browser and device information, and playback and quality data (e.g., buffering and error statistics) are processed to ensure the smooth delivery of videos. According to the provider, personal data is not stored permanently.

The use of Bunny Stream is based on our legitimate interest in fast, stable, and secure delivery of our video content (Art. 6(1)(f) GDPR).

You can find more information about data protection at Bunny Stream here: https://bunny.net/privacy/.

Cookie Consent Tool

Our website uses a cookie consent tool to obtain your consent to the storage of certain cookies on your end device and to document this in compliance with data protection regulations. When you access our website, a banner is displayed that allows you to give or refuse your consent to various categories of cookies. Your consent decision, date and time of consent, browser information and your IP address (anonymized if necessary) are processed. This data is stored to fulfill legal obligations in accordance with Art. 6 para. 1 lit. c GDPR and on the basis of our legitimate interest in a legally compliant design of our website in accordance with Art. 6 para. 1 lit. f GDPR. You can change or revoke your consent at any time via the cookie banner settings.

15. emeryAI Interface (Conversational Interface)

This website uses emeryAI, an AI-powered conversational interface. The provider is Elevate GmbH, Infanteriestraße 11a / Haus B2, 80797 Munich, Germany.

emeryAI allows you to interact via text or voice input with an AI assistant that provides information about our company. In accordance with Art. 50 of Regulation (EU) 2024/1689 (EU AI Act), we would like to point out that you are interacting with an AI system. The responses generated are based on language models and may be incorrect, incomplete or out of date despite careful configuration. They do not constitute legally binding information or medical, legal or financial advice. When you use the interface, technical data is automatically collected, in particular your IP address (which is anonymized before being saved), browser type, device type, screen resolution, language setting, time zone and the referrer URL. In addition, your text entries and the AI-generated answers are processed. If you voluntarily provide personal data (e.g. name, e-mail address via a contact form), this will also be stored. Summarized conversation histories (e.g. requested topics and expressed interests) can be made available to us as the operator of this website to improve our offer.

emeryAI uses a cookie for recognition (emery_visitor_token, runtime up to 90 days) as well as local storage entries for session and settings data. The cookie is only set with your explicit consent via the interface's consent banner. Without consent, your data will only be processed for the duration of the browser session, and no recognition will take place.

Your inputs for generating AI responses are transferred to language model providers in the USA (OpenAI and/or Anthropic). Your inputs will not be used to train the language models. Data is stored on servers in the EU (Supabase, Frankfurt region). Application hosting is provided by Vercel Inc. (USA). If you use the optional voice function, audio data will be transferred to ElevenLabs Inc. (USA) for conversion into text; this will only happen after your explicit consent.

The use of emeryAI is based on Art. 6 para. 1 lit. f GDPR (legitimate interest in providing an interactive conversation interface). If cookies are set or audio data is processed, this is done on the basis of Art. 6 para. 1 lit. a GDPR (consent). Consent can be revoked at any time.

Conversation content is deleted after a maximum of 7 days of inactivity (LLM context) or after an additional 90 days (conversation display). All other data will be deleted after 14 months at the latest.

The named US providers are certified under the „EU-US Data Privacy Framework“ (DPF). Further information on this can be found at: https://www.dataprivacyframework.gov/list. Additionally, EU Standard Contractual Clauses (SCCs) are incorporated into the agreements with providers.

More information on data processing by emeryAI can be found in the Privacy Policy of the emeryAI Interface.

16. emeryAI Demo Interface 

This website features an interactive product demonstration of emeryAI. The provider is Elevate GmbH, Infanteriestraße 11a / Haus B2, 80797 Munich, Germany.

The demo shows pre-built conversation flows for demonstration purposes. There is no AI-powered processing of your input, no conversation content is stored, and no cookies are set.

When you access the demo, technical data will be automatically collected by the hosting provider Vercel Inc. (USA), specifically your IP address, browser type, and time of access. This is technically necessary for the delivery of the website. Processing is carried out on the basis of Art. 6 para. 1 lit. f GDPR (legitimate interest in providing the website). Vercel is certified under the EU-US Data Privacy Framework (DPF). More information: https://www.dataprivacyframework.gov/list.

For more information, please see our privacy policy: https://emeryai.com/privacy.

17. emeryAI Dashboard (Administration Interface)

The emeryAI Dashboard is the management interface for registered customers and their employees. 

When using the dashboard, account data is collected, specifically your email address (for login via Magic Link), and possibly your name and role. In addition, customer company data (company name, address, website URL), usage data (access times, actions performed), and technical data (IP address, browser type, device type) are processed.

The dashboard uses cookies and local storage entries for session management after login, as well as for your preferences (e.g., language, workspace selection).

Access to the dashboard is protected by login via Magic Link, optional two-factor authentication, and further technical and organizational security measures.

The provision and operation of the dashboard, as well as authentication and access control, are based on Art. 6(1)(b) GDPR (performance of a contract). IT security measures are based on Art. 6(1)(f) GDPR (legitimate interest).

Account and company data are stored for the duration of the contractual relationship and deleted after termination according to legal retention periods (typically 6-10 years for tax and commercial records). Dashboard usage data will be deleted after 14 months.

18. Order Processor

For the provision of our services, we use the following service providers as contract processors:

Supabase Inc. (USA, Data Processing in EU Frankfurt) for databases, authentication, and edge functions. OpenAI, L.L.C. (USA) and Anthropic PBC (USA) for AI language models in the interface. ElevenLabs Inc. (USA) for speech recognition and speech output in the interface. Vercel Inc. (USA, Edge Network incl. EU) for Application Hosting. Raidboxes GmbH (Germany) for website hosting. n8n GmbH (Germany) for workflow automation.

Your inputs in the interface will not be used for training the deployed AI language models.

Contracts have been concluded with all named order processors in accordance with Art. 28 GDPR, which ensure data is processed in compliance with data protection regulations.

19. Transfer to Third Countries

As part of the services mentioned in Section 16, personal data will be transferred to the USA. This transfer is secured by the EU-US Data Privacy Framework (adequacy decision of the European Commission of July 10, 2023) and/or by EU Standard Contractual Clauses in accordance with Implementing Decision (EU) 2021/914. The certification of the respective providers can be found at https://www.dataprivacyframework.gov/list To see/inspect/consult.

20. Your Rights

You have the following rights under the GDPR: the right to access your personal data (Art. 15 GDPR), the right to rectification of inaccurate data (Art. 16 GDPR), the right to erasure of your data (Art. 17 GDPR), provided there are no legal retention obligations to the contrary, the right to restrict processing (Art. 18 GDPR), the right to data portability (Art. 20 GDPR), and the right to object to processing based on legitimate interests (Art. 21 GDPR).

To exercise your rights, please contact: [email protected]

Note on using the interface without cookie consent: If you used the interface without consenting to cookies, we and third parties will not be able to associate the data collected with your person after your browser session ends (Art. 11 GDPR). In this case, we can only identify your data if you can provide us with your session ID.

21. Withdrawal of your consent

You can revoke your consent at any time with effect for the future (Art. 7 para. 3 GDPR). You can withdraw cookie consent for the emeryAI interface directly through the settings in the interface. You can withdraw consent for website cookies via the cookie banner.

22. Right to complain

You have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). The competent supervisory authority for us is the Bavarian State Office for Data Protection Supervision (BayLDA), Promenade 18, 91522 Ansbach (www.lda.bayern.de).

23. Data Security

We implement technical and organizational security measures to protect your data from loss, manipulation, or unauthorized access.

24. Dispute Resolution

The European Commission provides an online dispute resolution (ODR) platform: https://ec.europa.eu/consumers/odr/. We are neither willing nor obligated to participate in an alternative dispute resolution settlement procedure before a consumer arbitration board (§ 36 VSBG).

25. Changes to this Privacy Policy

We reserve the right to adapt this privacy policy to always comply with current legal requirements or changes in our services. You will always find the current version on this page.