Privacy Policy

Who Is Responsible

Aivelli is a sole proprietorship (eenmanszaak) owned and run by Lela Gagua, established in Eindhoven, the Netherlands, KVK 98190431. Aivelli is the controller for the processing described in this policy, except where section 6 says that Aivelli processes data on behalf of a client. Aivelli has no data protection officer; the law does not require one for a business of this size.

Aivelli follows the General Data Protection Regulation (GDPR), the Dutch GDPR Implementation Act (UAVG) and the Dutch Telecommunications Act (Telecommunicatiewet) for everyone whose data it processes, wherever they are.

Whose Data, Which Data

2.1 Website visitors

• Technical data: IP address, browser and device type, pages visited, referring page and time of visit. Collected by the hosting server logs and the security plugin so the site works and stays secure.
• Analytics and marketing data: see section 4 and the Cookie Policy. Set only after your consent.
• Spam protection: when you submit a form, the form data and your IP address are checked for spam by CleanTalk.

2.2 Newsletter subscribers and guide requests

• Your email address, the date and source of your signup (for example the Copilot guide page, the homepage form or an event signup page), your confirmation of the signup and whether you open or click emails.
• Country derived from your IP address at signup or open, used to send emails at a sensible time and in the right language.

2.3 People who contact Aivelli

• Name, email address and the content of your message, through the contact form or by email.

2.4 People who book an intro call

• Name, email address, company, role and your answers to the booking questions, through Calendly.
• Meeting data from Microsoft Teams or Zoom: name, email address and time of participation.

2.5 Instagram followers who interact with Aivelli posts

• When you comment a keyword on an Aivelli Instagram post, ManyChat reads the comment, stores your Instagram user ID, display name and the messages exchanged and sends you an automated direct message with the link to the free guide. If you tap a button in that message, that choice is stored too.

2.6 Clients and participants

See section 6.

2.7 Past buyers of digital playbooks (sold until 4 November 2026)

• Email address, purchase reference, product and date. Accounts and logins no longer exist; buyers reach their content through a direct link. Payment details were handled by Stripe and are not stored by Aivelli.

2.8 Business contacts

• Name, role, employer, business email and phone number and notes about the conversation, for people who contact Aivelli, are introduced by a partner or have a business relationship with Aivelli.

Why and on Which Legal Basis

Cookies, Analytics & Advertising Tools

The website uses cookies and similar tools. Strictly necessary cookies (consent storage, security) are set without consent. Analytics (Google Analytics 4 through Google Site Kit and Google Tag Manager) and marketing tools (Meta pixel, LinkedIn Insight Tag) load only after you accept them in the cookie banner (CookieYes).

• Strictly necessary: consent storage and security. Set without consent.
• Analytics: Google Analytics 4. Google Analytics 4 does not store your full IP address, but Google processes the data in the United States. Set only after you consent.
• Marketing: Meta pixel and LinkedIn Insight Tag. Meta and LinkedIn may link your visit to your account on their platform if you are logged in there. Set only after you consent.

You can change your choice at any time via “Cookie Settings” in the footer. The Cookie Policy lists every cookie, its provider, purpose, duration and category.

Newsletter & Guides

Aivelli sends its emails with the Newsletter plugin on its own WordPress website, hosted at Strato in Germany, through Strato’s mail servers.

• When you sign up for a guide or the newsletter you receive a confirmation email first (double opt-in).
• Every email has an unsubscribe link. Unsubscribing stops all marketing email; a transactional email about a request you made may still follow.
• Aivelli records opens and clicks to see which content is useful and to remove inactive addresses.
• Signups from a live event page (for example a QR code at an event) work the same way: the page says what you sign up for and you confirm by email.

Clients & Participants

When Aivelli delivers a program for a client, it handles:

• names and work email addresses of participants, to run the sessions, send the participant guide and the follow-up invitation and write the learning record;
• a 1-page learning record per participant, delivered to the client for its own training records; Aivelli keeps a copy;
• in the AI Adoption Month, notes from interviews with leaders and team leads, used only to write the use-case map and the adoption plan;
• examples of recurring work that the client shares for the sessions.

Roles

For participant contact data and its own records (session administration, the learning record copy, invoicing), Aivelli is an independent controller. For interview notes, work examples and any other material the client provides for the work, Aivelli acts on the client’s instructions as a processor under the data protection terms in section 14 of Aivelli’s Terms and Conditions. The client informs its staff about the program and about Aivelli’s role.

Retention

• Participant names, email addresses and learning record copies: 2 years after the end of the engagement, then deleted.
• Interview notes and work examples: returned or deleted within 30 days after the engagement ends, as the client chooses.
• Invoices and contracts: 7 years.

Instagram Automation (ManyChat)

Aivelli uses ManyChat (Manychat, Inc., USA) to reply automatically when you comment a keyword on an Aivelli Instagram post. ManyChat stores your Instagram user ID, your name, the comment, the messages exchanged and the buttons you tap, so the guide can be sent to you and so you do not receive the same message twice.

ManyChat processes this on Aivelli’s behalf under a data processing agreement and is certified under the EU-US Data Privacy Framework. Instagram itself (Meta Platforms Ireland) processes your data under its own privacy policy.

AI Tools Aivelli Uses to Prepare Its Work

Aivelli uses AI tools (Claude by Anthropic, ChatGPT by OpenAI and Microsoft 365 Copilot) to draft its own materials.

• Client personal data or client confidential material is entered only into a tool on a business plan whose contract excludes training on inputs and is covered by a data processing agreement and only where this is needed for the work.
• Interview notes are anonymized before any AI tool processes them.
• Website visitor, subscriber and contact data are not entered into AI tools.

Who Receives Data

Aivelli uses the following service providers. Each processes data on Aivelli’s behalf under a data processing agreement, unless marked as an independent controller.

Aivelli also shares data when the law requires it, for example with the tax authority, or to establish or defend a legal claim.

Transfers Outside the EEA

Where a provider processes data in the United States, Aivelli relies on:

• EU-US Data Privacy Framework: the European Commission adequacy decision of 10 July 2023, upheld by the EU General Court on 3 September 2025 in case T-553/23 (an appeal is pending), where the provider is certified;
• Standard contractual clauses: the European Commission’s clauses with a transfer assessment, for providers that are not certified.

You can ask for a copy of the safeguards at le***@*****li.com. Data of Georgian clients and contacts is processed in the EU in the same way as everyone else’s.

How Long Aivelli Keeps Data

Security

Aivelli takes technical and organizational measures under GDPR article 32, including:

• TLS encryption on the website and in email
• A web application firewall and malware scanning
• 2-factor authentication on Aivelli’s accounts
• EU hosting, daily backups and regular software updates
• Client files kept in Aivelli’s Microsoft 365 environment, not on personal devices without encryption

If a data breach is likely to put your rights at risk, Aivelli reports it to the Autoriteit Persoonsgegevens within 72 hours and informs you without undue delay (GDPR articles 33 and 34).

Your Rights

You can ask Aivelli to:

• Access: tell you what data it holds about you and give you a copy
• Rectification: correct data that is wrong
• Erasure: delete your data, except where Aivelli must keep it by law
• Restriction: limit how it is used while a question is resolved
• Portability: hand over the data you provided in a machine-readable format
• Objection: stop processing based on legitimate interest, including any direct marketing
• Withdraw consent: for example for the newsletter or cookies, without affecting what happened before

Send your request to le***@*****li.com. Aivelli replies within 1 month; for complex requests this can be extended by 2 months and you will be told if so. There is no fee for a reasonable request. Aivelli may ask you to confirm your identity.

Changes to This Policy

Aivelli updates this policy when its practices, tools or the law change and shows the new date at the top. For changes that matter to subscribers or clients, Aivelli sends an email or shows a notice on the website.

Contact

For questions about this policy, to exercise your rights or to report a concern, email Aivelli. Formal requests are answered within 1 month.