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ELVOAQ AI Transparency & Data Processing Policy

Effective Date: July 1, 2026

Version: 1.0

Last Updated: July 1, 2026

Operator: Lukas Rajnic, sole trader, trading as ELVOAQ

Jurisdiction: Slovak Republic

1. Introduction

This AI Transparency & Data Processing Policy explains how Lukas Rajnic, a sole trader established in the Slovak Republic, trading as ELVOAQ (“ELVOAQ”, “we”, “our”, or “us”), provides, operates, protects, and governs artificial intelligence features within the ELVOAQ platform.

ELVOAQ is built for individuals, companies, organizations, advisors, collectors, asset owners, and professional users who require a secure digital environment for valuable assets, sensitive records, proof documents, structured asset information, and controlled workflows.

Artificial intelligence is integrated into ELVOAQ as a supporting intelligence layer. It is not designed to replace the user’s ownership, judgment, control, or responsibility. ELVOAQ AI is designed to help users organize information, analyze uploaded materials, extract useful details, classify documents, summarize records, support workflows, and interact with their digital vault in a more efficient way.

This Policy describes:

What ELVOAQ AI is;

Which AI provider ELVOAQ uses;

How Grok models may be used within the platform;

What types of data may be processed;

How uploaded photos, documents, prompts, and AI conversations are handled;

How ELVOAQ protects AI-related data;

How users can delete AI chats;

How ELVOAQ approaches privacy, confidentiality, encryption, and secure AI processing;

What limitations apply to AI-generated results;

How this Policy relates to xAI’s official terms and legal documents.

This Policy forms part of ELVOAQ’s broader legal, privacy, and security framework and should be read together with the ELVOAQ Terms of Use, Privacy Policy, Cookie Policy, Refund Policy, and any applicable customer agreement, enterprise agreement, data processing agreement, or written contract entered into with ELVOAQ.

2. Position of ELVOAQ AI

ELVOAQ AI is the name of the artificial intelligence functionality integrated into the ELVOAQ platform.

ELVOAQ AI may assist users with:

Document review;

Photo analysis;

Asset identification support;

Metadata extraction;

File classification;

Record organization;

Search assistance;

Summarization;

Proof document interpretation;

Warranty and receipt extraction;

Asset description generation;

Workflow suggestions;

Duplicate detection support;

Contextual assistance inside the user’s vault;

Business and organizational productivity tasks;

Controlled sharing preparation;

Information structuring for individuals and companies.

ELVOAQ AI is not a separate consumer chatbot product. It is a platform feature designed to support the secure management of user-controlled information inside ELVOAQ.

ELVOAQ AI does not independently own user data, does not replace the user, and does not make final decisions on behalf of the user unless the user specifically configures automated workflows where available.

Users remain responsible for reviewing all AI-generated outputs before relying on them.

3. AI Provider Disclosure

ELVOAQ uses Grok models provided through xAI Enterprise API and xAI API services for certain AI-powered functionality inside the platform.

xAI is an independent third-party artificial intelligence provider. ELVOAQ is not owned by xAI, does not represent xAI, and is not an official xAI legal representative.

Where ELVOAQ uses Grok models, user requests may be processed through xAI’s AI infrastructure for the purpose of generating a response, performing analysis, interpreting uploaded content, or supporting other AI functionality requested by the user.

ELVOAQ may use Grok models for tasks such as:

Text understanding;

Image understanding;

Reasoning;

Classification;

Summarization;

Extraction;

Search assistance;

Document interpretation;

User support automation;

Workflow assistance;

Multimodal analysis involving text and images.

ELVOAQ may update, replace, add, or remove AI models and providers over time where necessary for security, reliability, performance, compliance, availability, cost control, or product improvement.

At the time this Policy is written, ELVOAQ’s AI functionality may reference or rely on:

xAI Enterprise Terms of Service;

xAI Data Processing Addendum;

xAI Privacy Policy;

xAI Acceptable Use Policy;

xAI API documentation;

Other xAI legal or technical documentation applicable to enterprise and API usage.

Users and business customers should understand that xAI’s official legal documents may change over time. ELVOAQ may update this Policy where required to reflect material changes in provider terms, architecture, data processing arrangements, or regulatory obligations.

4. ELVOAQ’s Role

Depending on the specific use case, account type, jurisdiction, and customer relationship, ELVOAQ may act as a controller, processor, service provider, operator, or equivalent role under applicable privacy and data protection laws.

For individual users, ELVOAQ generally determines the purposes and means of processing user account information and platform data required to deliver the ELVOAQ service.

For business and enterprise customers, ELVOAQ may process certain customer-controlled information on behalf of the customer according to the applicable service agreement, data processing agreement, enterprise agreement, or written contractual terms.

When AI functionality is used, ELVOAQ remains the primary customer-facing platform operator. Users interact with ELVOAQ AI inside the ELVOAQ environment. Where Grok models are used, xAI acts as an AI infrastructure and model provider according to the applicable xAI enterprise, API, privacy, and data processing terms.

ELVOAQ does not transfer its direct user relationship to xAI merely because Grok models are used to power certain AI features.

5. Privacy-First AI Design

ELVOAQ AI is designed around a privacy-first architecture. The purpose of ELVOAQ AI is to help users work with their own information, not to monetize, sell, expose, or exploit that information.

ELVOAQ’s AI design principles include:

5.1 Data Minimization

ELVOAQ aims to process only the data reasonably necessary to provide the AI functionality requested by the user.

Where possible, ELVOAQ seeks to avoid unnecessary transmission of unrelated account data, unrelated vault data, unrelated files, unrelated assets, or unrelated personal information.

5.2 Purpose Limitation

AI-related data is processed for platform purposes, including:

Responding to user requests;

Analyzing uploaded content;

Generating requested outputs;

Maintaining AI conversation history for the user;

Supporting account security;

Maintaining platform reliability;

Improving safety and system performance;

Complying with legal obligations.

ELVOAQ does not process AI prompts, uploaded photos, documents, or conversations for unrelated advertising purposes.

5.3 User Control

Users can decide whether to use AI functionality. Users can submit prompts, upload photos, ask questions, request analysis, or delete AI chats where deletion functionality is provided.

5.4 Confidentiality

ELVOAQ treats AI prompts, uploaded files, generated responses, and related interaction history as confidential user information.

5.5 Security by Design

AI functionality is designed to operate within ELVOAQ’s broader security architecture, including encryption, access controls, monitoring, auditability, and controlled infrastructure practices.

5.6 No Data Sale

ELVOAQ does not sell user prompts, AI conversations, uploaded documents, uploaded photos, asset information, vault content, or generated AI responses.

5.7 No Advertising Monetization

ELVOAQ AI is not an advertising system. ELVOAQ does not use user AI conversations to build advertising profiles or sell targeting segments.

5.8 Controlled AI Processing

ELVOAQ designs AI processing to occur within controlled technical environments and contractual frameworks. Where third-party AI infrastructure is used, ELVOAQ seeks to apply contractual, technical, and organizational measures appropriate for enterprise-grade processing.

6. Confidential AI Processing Architecture

ELVOAQ has designed its AI processing architecture to follow modern confidential AI processing principles. The objective is to allow users to benefit from advanced AI capabilities while reducing unnecessary exposure of user content.

ELVOAQ’s confidential AI processing approach is designed around the following objectives:

User data should remain protected during transmission;

AI requests should be processed only for the requested platform function;

Routine internal access to user prompts and uploaded materials should be restricted;

AI infrastructure providers should receive only the information required to process the specific request;

Human access to readable user content should be limited and controlled;

Access should be logged, monitored, and restricted according to role and necessity;

Sensitive information should be encrypted where technically appropriate;

User-controlled deletion should be supported where available;

AI-generated outputs should remain part of the user’s ELVOAQ account unless deleted, exported, or otherwise managed by the user.

ELVOAQ’s AI architecture is intended to provide a high standard of privacy, confidentiality, and controlled processing comparable in design philosophy to modern private cloud AI processing systems. ELVOAQ is not affiliated with Apple and does not use Apple Private Cloud Compute. Any reference to private cloud AI processing principles in ELVOAQ materials is intended to describe a privacy-oriented design approach, not a claim of affiliation with Apple or use of Apple infrastructure.

Where technically implemented, ELVOAQ may use confidential processing mechanisms, secure request routing, encryption, access isolation, limited retention logic, service boundary controls, or other safeguards intended to reduce the ability of unauthorized parties to view readable user content.

However, users should understand that any AI system involving third-party model infrastructure may require the technical processing of submitted prompts, images, documents, or related data to produce the requested output. ELVOAQ’s commitment is to minimize, secure, restrict, and govern such processing rather than expose or monetize it.

7. AI Provider Access and Confidentiality

ELVOAQ’s AI provider architecture is designed so that user prompts, photos, documents, and other AI inputs are processed only for the requested AI functionality.

ELVOAQ aims to ensure that AI infrastructure providers do not use ELVOAQ customer content for unrelated purposes, advertising, or unauthorized commercial exploitation.

Where supported by contract, technical architecture, or provider terms, ELVOAQ seeks to restrict provider access to customer content, limit retention, and prevent use of customer content for model training unless expressly permitted by the customer or legally required.

ELVOAQ designs its platform so that, during normal AI processing:

Customer data is transmitted securely;

Only necessary data is sent for inference;

AI requests are processed for the user-requested task;

Provider-side use is limited by applicable enterprise/API terms;

Readable human access is restricted according to contractual and operational safeguards;

ELVOAQ does not sell or transfer customer content for advertising or unrelated profiling.

Where ELVOAQ states that AI provider personnel cannot read user messages, this refers to ELVOAQ’s intended confidential processing design, access restriction model, and normal operational controls. It does not mean that no technical system, legal obligation, security investigation, abuse review, or exceptional operational process could ever involve access under any circumstances.

ELVOAQ will not intentionally design AI workflows for provider-side human review of user content unless required for security, abuse prevention, compliance, legal process, troubleshooting, or another legitimate and controlled purpose.

8. Types of Data Processed by ELVOAQ AI

ELVOAQ AI may process different categories of user data depending on how the platform is used.

8.1 Prompts and Instructions

This includes text submitted by users into ELVOAQ AI, such as questions, commands, instructions, descriptions, search requests, analysis requests, and follow-up messages.

Examples may include:

“Analyze this receipt.”

“Summarize this certificate.”

“Identify the asset in this photo.”

“Help me organize these documents.”

“Create a description for this asset.”

“Find missing proof records.”

8.2 Uploaded Photos

Users may upload photos to ELVOAQ AI. Uploaded photos may include images of physical assets, documents, certificates, receipts, warranties, objects, serial numbers, packaging, collections, vehicles, watches, art, jewelry, equipment, or other items.

ELVOAQ AI may analyze uploaded photos to assist with:

Visual identification;

Description generation;

Condition notes;

Category suggestions;

Object recognition support;

Document interpretation;

Text extraction;

Proof matching;

Asset comparison;

Organization inside the user’s vault.

8.3 Uploaded Documents

Users may upload documents such as:

Receipts;

Invoices;

Certificates;

Warranty documents;

Insurance documents;

Appraisals;

Provenance records;

Contracts;

Ownership records;

Maintenance records;

Photos of paper documents;

PDFs;

Other supporting materials.

ELVOAQ AI may process these documents to extract, classify, summarize, or connect them to relevant asset records.

8.4 Asset Data

ELVOAQ AI may process structured asset information stored in the user’s account, such as:

Asset name;

Category;

Estimated value;

Purchase date;

Location;

Condition;

Ownership history;

Notes;

Attachments;

Serial numbers;

Certificates;

Proof documents;

Maintenance history;

Warranty information.

8.5 Conversation History

ELVOAQ may store AI conversations inside the user’s ELVOAQ account so the user can view, continue, retrieve, manage, or delete previous AI interactions.

8.6 Technical and Operational Data

ELVOAQ may process technical data needed to operate AI functionality, including:

Request timestamps;

Model routing metadata;

Error logs;

Security logs;

Performance metrics;

Abuse-prevention signals;

Account identifiers;

Request status;

System diagnostics;

API usage metadata;

Infrastructure monitoring data.

Such data is used for security, reliability, debugging, compliance, billing, abuse prevention, and service operation.

9. Storage of Prompts and AI Conversations

ELVOAQ stores user prompts and AI conversations inside the ELVOAQ platform for the benefit of the user.

This storage allows users to:

Continue previous AI conversations;

Review previous AI outputs;

Maintain records of AI-assisted analysis;

Connect AI outputs to asset records;

Use AI history as part of their organized vault;

Keep continuity across sessions;

Delete chats when no longer needed.

AI conversation history is part of the user’s ELVOAQ account experience. It is not stored for resale, advertising, or external data monetization.

ELVOAQ may store:

User prompts;

Uploaded files connected to AI requests;

Generated AI responses;

Conversation timestamps;

Linked asset records;

Conversation metadata;

Deletion status;

Security logs connected to AI usage.

Users may delete AI chats where the feature is available. Deleted chats may no longer be visible in the active user interface after deletion.

However, deletion may be subject to:

Backup retention periods;

Legal retention obligations;

Security investigation requirements;

Fraud prevention requirements;

Enterprise audit obligations;

Technical deletion cycles;

Disaster recovery systems;

System integrity requirements.

ELVOAQ will not retain deleted AI conversations longer than reasonably necessary for legitimate business, legal, security, or operational purposes.

10. Uploaded Photos and Images

ELVOAQ allows users to upload photos for AI-supported analysis.

Photos may contain sensitive information. For example, a photo may reveal:

A valuable object;

A serial number;

A location;

A receipt;

A person’s name;

A certificate number;

A private room;

A business asset;

A vehicle plate;

A document;

Ownership evidence;

Financial information.

Users should only upload photos they are authorized to process and store inside ELVOAQ.

ELVOAQ AI may use Grok models to analyze uploaded photos where image understanding is required. This processing may involve transmitting the photo or a derived representation of the photo through secure AI processing channels for the purpose of generating the requested output.

ELVOAQ does not sell uploaded photos. ELVOAQ does not use uploaded photos for advertising. ELVOAQ does not intentionally expose uploaded photos to other users unless the account owner shares them through platform functionality.

Where technically possible and commercially reasonable, ELVOAQ may reduce, transform, extract, compress, redact, or limit image data before AI processing where full image transmission is not necessary.

Users are responsible for ensuring that uploaded photos do not violate the rights of third parties, confidentiality obligations, intellectual property rights, privacy rights, or applicable laws.

11. Use of Grok Models

ELVOAQ uses Grok models through xAI Enterprise API and xAI API services to provide certain AI functionality.

Grok models may be used to process:

Text prompts;

Uploaded images;

User instructions;

Document excerpts;

Asset metadata;

Generated context;

Structured platform data required for the request.

ELVOAQ may use Grok models for:

Natural language understanding;

Multimodal analysis;

Reasoning;

Text generation;

Classification;

Extraction;

Summarization;

Document assistance;

Visual assistance;

Workflow support;

Contextual user assistance.

The use of Grok models is governed by applicable xAI terms, which may include xAI Enterprise Terms of Service, xAI Data Processing Addendum, xAI Privacy Policy, xAI Acceptable Use Policy, API documentation, and any written agreement between ELVOAQ and xAI.

ELVOAQ does not guarantee that Grok outputs will always be correct, complete, up to date, legally sufficient, financially accurate, or suitable for every use case.

Users must verify important outputs before relying on them.

12. No Sale of Customer Data

ELVOAQ does not sell:

User prompts;

AI conversations;

Uploaded photos;

Uploaded documents;

Asset records;

Certificates;

Receipts;

Ownership information;

Vault content;

Generated AI outputs;

Business customer data;

Individual customer data.

ELVOAQ does not operate ELVOAQ AI as a data brokerage system.

ELVOAQ does not provide user vault content to advertisers.

ELVOAQ does not create advertising profiles from AI conversations.

ELVOAQ does not sell AI interaction history to third parties.

Where third-party providers are used, they are used to provide technical infrastructure, AI processing, platform functionality, security, storage, hosting, analytics, monitoring, compliance, or other legitimate operational services.

13. No Advertising Use of AI Data

ELVOAQ AI data is not used for advertising targeting.

This means ELVOAQ does not use AI conversations, prompts, uploaded files, or generated outputs to:

Sell targeted advertising;

Build advertising audiences;

Sell behavioral profiles;

Share user interests with advertisers;

Monetize private documents through advertising systems;

Create third-party marketing segments;

Display ads based on vault content.

ELVOAQ’s business model is based on providing a secure platform, not exploiting user data for advertising.

14. AI Training and Model Improvement

ELVOAQ does not use private customer vault content, uploaded files, prompts, AI conversations, or asset information to train public AI models without appropriate legal basis, customer permission, contractual authorization, or anonymization where applicable.

Where ELVOAQ uses third-party AI providers such as xAI, the handling of data for model improvement, retention, abuse monitoring, and training is subject to applicable enterprise/API terms, data processing agreements, and provider documentation.

For enterprise API usage, ELVOAQ seeks to apply contractual protections that restrict unauthorized use of customer content for provider-side model training, advertising, or unrelated commercial purposes.

ELVOAQ may use aggregated, de-identified, or statistical information to improve platform reliability, security, usability, performance, or product design, provided that such information does not reasonably identify a user or expose private vault content.

ELVOAQ may also use test data, synthetic data, anonymized examples, internal development data, or customer-approved data to improve AI features.

15. Encryption and Security Safeguards

ELVOAQ applies technical and organizational safeguards designed to protect AI-related data.

These safeguards may include:

Encryption in transit;

Encryption at rest;

Secure API communication;

Access control;

Role-based permissions;

Authentication controls;

Account-level authorization;

Logging and monitoring;

Infrastructure hardening;

Secure development procedures;

Secrets management;

Vulnerability management;

Data minimization;

Segregation of environments;

Security incident response;

Backup and recovery controls;

Internal access restrictions;

Administrative access monitoring.

AI requests involving third-party model providers are transmitted using secure channels where supported.

ELVOAQ aims to ensure that user data is not exposed in readable form to unauthorized parties during normal platform operation.

No digital system can be guaranteed to be completely secure. ELVOAQ cannot promise that unauthorized access, cyberattacks, system failures, provider failures, software vulnerabilities, legal demands, or operational incidents will never occur.

ELVOAQ’s commitment is to design, maintain, and improve safeguards appropriate for the sensitivity of the platform and the nature of the data processed.

16. Confidentiality and Human Access

ELVOAQ restricts internal human access to user AI data.

Routine access to prompts, uploaded files, photos, documents, AI conversations, and generated outputs is not permitted except where necessary for legitimate purposes.

Legitimate purposes may include:

User support requested by the user;

Debugging;

Security monitoring;

Abuse investigation;

Legal compliance;

Fraud prevention;

System reliability;

Enterprise audit obligations;

Incident response;

Billing dispute investigation;

Compliance with law;

Enforcement of ELVOAQ’s Terms of Use.

Where access is required, ELVOAQ seeks to apply need-to-know access principles, role-based controls, logging, confidentiality obligations, and internal restrictions.

ELVOAQ’s objective is that neither routine ELVOAQ personnel nor routine AI provider personnel should access readable user content during normal AI processing.

This objective is subject to technical, contractual, legal, and operational limitations.

17. User Deletion Rights for AI Chats

Users may delete AI chats where deletion functionality is available in the ELVOAQ platform.

When a user deletes an AI chat, ELVOAQ will remove it from the active user-facing interface according to the platform’s deletion process.

Deletion may include:

Removing the visible conversation;

Removing linked conversation history;

Removing user-facing AI responses;

Removing associated chat metadata where applicable;

Updating the account state to reflect deletion.

However, deleted AI data may remain for a limited period in:

Backups;

Security logs;

Audit logs;

Disaster recovery systems;

Temporary processing caches;

Legal hold records;

Compliance systems;

Enterprise audit records;

Abuse-prevention systems.

ELVOAQ will not use deleted AI chats for active user-facing functionality after deletion, except where restoration, investigation, legal compliance, or system integrity requires it.

Business and enterprise accounts may have additional administrative retention controls depending on their contract, workspace settings, audit requirements, or compliance obligations.

18. Business and Enterprise Users

ELVOAQ AI is available for both individuals and businesses.

Business and enterprise users may use ELVOAQ AI for:

Asset administration;

Document management;

Internal record workflows;

Insurance preparation;

Ownership documentation;

Audit support;

Compliance organization;

Team productivity;

Controlled information sharing;

Internal knowledge assistance.

Where a business customer uploads information relating to employees, clients, contractors, assets, vendors, partners, or third parties, that customer is responsible for ensuring that it has the right to process such information through ELVOAQ.

Business customers are responsible for:

Obtaining required permissions;

Providing required notices;

Complying with employment, privacy, confidentiality, and data protection laws;

Managing internal user access;

Configuring workspace permissions;

Reviewing AI-generated outputs;

Ensuring lawful use of AI functionality;

Preventing unauthorized upload of restricted information.

Enterprise customers may enter into separate agreements with ELVOAQ that override or supplement this Policy.

19. Individual Users

Individual users may use ELVOAQ AI to manage private assets, personal documents, proof records, collections, receipts, warranties, ownership documentation, and related information.

Individual users should avoid uploading information they are not authorized to process.

Users should take care when uploading:

Government IDs;

Bank documents;

Health records;

Legal documents;

Highly confidential contracts;

Third-party personal data;

Children’s data;

Passwords;

Secret keys;

Private access credentials;

Sensitive personal information.

ELVOAQ AI may help organize sensitive information, but users remain responsible for deciding what they upload.

20. Sensitive Information

ELVOAQ is designed for privacy-conscious users and may be used to store sensitive records. However, AI functionality should be used carefully with highly sensitive information.

Sensitive information may include:

Financial documents;

Insurance records;

Legal records;

Health information;

Government identification;

Biometric data;

Children’s data;

Trade secrets;

Confidential business documents;

Security credentials;

Ownership evidence;

High-value asset details;

Personal addresses;

Private location data.

Users should not submit sensitive information to ELVOAQ AI unless they understand the processing involved and have the right to do so.

ELVOAQ may implement warnings, restrictions, redaction tools, access controls, or configuration options for sensitive information where appropriate.

21. Automated Decision-Making

ELVOAQ AI is primarily designed to assist users, not to make legally binding decisions about them.

ELVOAQ AI may generate suggestions, classifications, summaries, estimates, descriptions, or recommendations. Such outputs are informational and supportive.

ELVOAQ AI should not be treated as the sole basis for decisions involving:

Legal rights;

Financial obligations;

Insurance claims;

Employment decisions;

Credit decisions;

Medical decisions;

Tax decisions;

Investment decisions;

Regulatory compliance;

Criminal or legal liability;

Ownership disputes;

High-value transactions.

Users and business customers remain responsible for human review and final decision-making.

22. AI Output Accuracy

AI-generated outputs may be inaccurate, incomplete, outdated, misleading, biased, or unsuitable for a specific context.

ELVOAQ does not guarantee that AI outputs will be:

Correct;

Complete;

Legally valid;

Financially accurate;

Tax compliant;

Technically precise;

Suitable for insurance submission;

Suitable for court or dispute purposes;

Free from hallucinations;

Free from omissions;

Free from bias;

Accepted by third parties.

Users must independently verify important outputs.

Where AI is used to analyze receipts, certificates, ownership records, warranties, or asset evidence, users should compare the AI result against the original document.

ELVOAQ AI is a support tool, not an authority.

23. Prohibited Uses

Users must not use ELVOAQ AI for unlawful, harmful, abusive, deceptive, or unauthorized purposes.

Prohibited uses include, but are not limited to:

Uploading data the user has no right to process;

Violating third-party privacy rights;

Generating fraudulent ownership documents;

Creating forged proof records;

Misrepresenting asset value or ownership;

Circumventing security controls;

Extracting secrets from the system;

Attempting to reverse engineer ELVOAQ AI;

Using ELVOAQ AI for harassment, abuse, or illegal activity;

Uploading illegal content;

Using AI outputs to deceive insurers, buyers, courts, regulators, or counterparties;

Violating xAI usage policies;

Violating ELVOAQ’s Terms of Use.

ELVOAQ may suspend, restrict, or terminate access to AI functionality where misuse is suspected.

24. Provider Terms and xAI References

ELVOAQ’s use of Grok models is subject to applicable xAI documentation and contractual terms.

Relevant xAI materials may include:

xAI Enterprise Terms of Service;

xAI Consumer Terms of Service, where applicable;

xAI Data Processing Addendum;

xAI Privacy Policy;

xAI Acceptable Use Policy;

xAI API documentation;

Other xAI legal, technical, or policy materials published or provided by xAI.

These documents are maintained by xAI and may be updated by xAI from time to time.

ELVOAQ may update its AI provider disclosures if xAI changes its terms, API behavior, data processing practices, enterprise commitments, service features, or legal requirements.

Nothing in this Policy modifies xAI’s own legal terms. This Policy explains ELVOAQ’s own user-facing approach to AI transparency and data processing inside the ELVOAQ platform.

25. International Data Transfers

ELVOAQ is operated from the Slovak Republic and may use infrastructure, providers, subprocessors, cloud services, AI providers, security vendors, and operational systems located in the European Economic Area, the United States, or other jurisdictions.

Where personal data is transferred internationally, ELVOAQ seeks to apply appropriate safeguards as required by applicable law.

Such safeguards may include:

Data processing agreements;

Standard contractual clauses;

European Union data protection safeguards;

Technical and organizational measures;

Encryption;

Access restrictions;

Transfer impact assessments where required;

Provider due diligence;

Contractual confidentiality obligations.

Users acknowledge that AI processing involving third-party providers may involve international data flows depending on infrastructure, provider configuration, account settings, and contractual arrangements.

26. Retention of AI Data

ELVOAQ retains AI-related data only for as long as reasonably necessary for the purposes described in this Policy, unless a longer retention period is required or permitted by law, contract, security requirements, enterprise configuration, or legitimate operational need.

Retention periods may depend on:

Account type;

User deletion actions;

Enterprise settings;

Legal requirements;

Security requirements;

Backup cycles;

Audit obligations;

Billing requirements;

Dispute resolution;

Abuse prevention;

Customer support requirements;

Platform integrity.

AI conversations may remain stored in the user’s account until the user deletes them or until retention rules apply.

Uploaded files connected to AI requests may remain stored in the user’s vault unless deleted by the user or removed according to applicable retention settings.

Technical logs may be retained separately for security, reliability, and compliance purposes.

27. Backups and Disaster Recovery

ELVOAQ may maintain backups and disaster recovery systems to protect platform integrity and service continuity.

AI-related data may remain in backups for a limited period after deletion from the active system.

Backup copies are not intended for active use and are retained for resilience, disaster recovery, security, and business continuity.

ELVOAQ will not intentionally restore deleted AI conversations into active user-facing systems except where necessary for disaster recovery, legal compliance, security investigation, or user-requested restoration where available.

28. Security Incidents

If ELVOAQ becomes aware of a security incident affecting AI-related data, ELVOAQ will assess the incident and take appropriate action.

Such action may include:

Investigation;

Containment;

Mitigation;

Remediation;

Provider coordination;

User notification where legally required;

Authority notification where legally required;

Security improvements;

Audit review;

Account protection measures.

ELVOAQ does not guarantee that every security event will result in user notification. Notification depends on legal requirements, severity, risk, affected data, contractual obligations, and applicable law.

29. User Responsibilities

Users are responsible for using ELVOAQ AI safely, lawfully, and responsibly.

Users must:

Review AI outputs before relying on them;

Avoid uploading information they are not authorized to process;

Avoid using AI outputs for fraud or misrepresentation;

Protect account credentials;

Manage workspace permissions;

Delete chats or data they no longer wish to retain;

Comply with applicable laws;

Comply with ELVOAQ’s Terms of Use;

Comply with applicable xAI usage restrictions where relevant;

Exercise judgment when submitting sensitive information.

Business users must also ensure that their organization has proper policies, notices, permissions, and legal bases for using AI with employee, customer, supplier, asset, or third-party information.

30. Children and Age Restrictions

ELVOAQ is intended for users who meet the age requirements described in the ELVOAQ Terms of Use.

ELVOAQ AI should not be used by children unless permitted by applicable law and authorized by a parent, guardian, school, organization, or enterprise customer with appropriate legal authority.

Users must not intentionally upload children’s personal data to ELVOAQ AI unless they have a lawful basis and appropriate authorization.

31. Intellectual Property

Users retain ownership of their uploaded content, prompts, documents, photos, asset information, and other customer materials, subject to the ELVOAQ Terms of Use and applicable law.

AI-generated outputs may be used by the user according to the ELVOAQ Terms of Use, applicable law, and any third-party restrictions that may apply.

ELVOAQ does not claim ownership of user vault content merely because it is processed by ELVOAQ AI.

Users are responsible for ensuring that their use of AI-generated outputs does not infringe third-party rights.

32. Confidential Business Information

Business and enterprise users may upload confidential business information into ELVOAQ.

ELVOAQ treats such information as confidential according to applicable agreements, privacy obligations, and platform security practices.

However, users should carefully configure access controls, workspace permissions, sharing settings, and AI usage policies before uploading highly confidential information.

Enterprise customers may request additional contractual terms, security documentation, or data processing arrangements where available.

33. Controlled Sharing and AI Outputs

ELVOAQ may allow users to create controlled views, exports, summaries, or shared records using AI assistance.

Users are responsible for checking shared AI outputs before sending them to:

Family members;

Advisors;

Buyers;

Sellers;

Insurers;

Lawyers;

Accountants;

Auditors;

Employees;

Team members;

Business partners;

External organizations.

AI-generated summaries may omit important details or include incorrect assumptions. Users should review all shared materials manually.

34. Data Portability and Export

Where available, ELVOAQ may allow users to export certain records, documents, asset data, or AI-related information.

Export functionality may depend on:

Account type;

Subscription plan;

Technical limitations;

Enterprise settings;

Legal restrictions;

Security requirements;

File type;

Data format;

Admin permissions.

ELVOAQ does not guarantee that all AI conversation history, generated outputs, metadata, or system logs will be exportable in every format.

35. Changes to AI Providers

ELVOAQ may change AI providers, models, routing systems, infrastructure, or processing architecture over time.

Reasons may include:

Better privacy controls;

Better security;

Improved model quality;

Reduced latency;

Better cost structure;

Better enterprise terms;

Regulatory changes;

Provider availability;

Product development;

Reliability concerns;

Compliance requirements.

Where a material change affects how user data is processed, ELVOAQ may update this Policy or provide additional notice where required by law.

ELVOAQ is not required to maintain any specific AI provider permanently.

36. Changes to AI Functionality

ELVOAQ may add, modify, suspend, restrict, or remove AI features at any time.

AI functionality may change due to:

Model updates;

Safety improvements;

Regulatory obligations;

Provider limitations;

Technical issues;

Product strategy;

Abuse prevention;

Security concerns;

User feedback;

Enterprise requirements.

ELVOAQ does not guarantee that a specific AI feature, model, output style, performance level, or workflow will remain available indefinitely.

37. Compliance Framework

ELVOAQ seeks to operate AI functionality in accordance with applicable legal, privacy, security, and consumer protection obligations.

Depending on user location, account type, and data processed, relevant frameworks may include:

Act No. 18/2018 Coll. on Personal Data Protection (Slovak Republic);

EU General Data Protection Regulation, where applicable;

UK GDPR, where applicable;

Contractual data protection obligations;

Consumer protection laws;

E-commerce laws;

Cybersecurity obligations;

Enterprise customer requirements;

AI-related regulatory developments.

ELVOAQ monitors regulatory developments and may update AI governance practices accordingly.

38. Responsible AI Governance

ELVOAQ is committed to responsible AI governance.

Responsible AI governance includes:

Clear user-facing disclosures;

Human review expectations;

Security controls;

Privacy review;

Provider due diligence;

Abuse prevention;

Internal accountability;

Policy updates;

Monitoring of AI performance;

Review of high-risk use cases;

User control over chats and data;

Restriction of harmful or illegal usage.

ELVOAQ does not claim that AI systems are perfect, neutral, or error-free.

ELVOAQ’s position is that AI should assist human judgment, not secretly replace it.

39. Disclaimers

ELVOAQ AI is provided on an “as is” and “as available” basis, subject to the ELVOAQ Terms of Use and applicable law.

ELVOAQ does not guarantee that AI outputs will be:

Accurate;

Complete;

Reliable;

Legally valid;

Financially correct;

Suitable for insurance claims;

Suitable for legal disputes;

Suitable for tax filing;

Suitable for investment decisions;

Accepted by third parties;

Free from errors;

Free from hallucinations;

Free from omissions;

Free from bias.

Users use ELVOAQ AI at their own risk and remain responsible for verifying important information.

Nothing generated by ELVOAQ AI constitutes legal, financial, tax, insurance, investment, medical, technical, or professional advice unless expressly stated in a separate written agreement.

40. Limitation of Liability

To the maximum extent permitted by applicable law, ELVOAQ shall not be liable for losses arising from:

User reliance on AI-generated outputs;

Incorrect AI analysis;

Incomplete summaries;

Misclassified documents;

Incorrect asset descriptions;

Incorrect image interpretation;

User failure to verify AI outputs;

Unauthorized user uploads;

Third-party provider errors;

AI provider downtime;

Model hallucinations;

Output bias;

Data submitted by the user;

Misuse of AI features;

Violation of third-party rights;

Business decisions based on AI output;

Insurance, legal, financial, tax, or investment decisions based on AI output.

This limitation applies subject to mandatory law and any separate written agreement between ELVOAQ and the customer.

41. Relationship with Other ELVOAQ Policies

This Policy supplements other ELVOAQ legal documents.

If there is a conflict between this Policy and a signed enterprise agreement, the signed enterprise agreement may control to the extent stated in that agreement.

If there is a conflict between this Policy and mandatory law, mandatory law controls.

If there is a conflict between this Policy and the ELVOAQ Privacy Policy concerning personal data processing, the documents should be interpreted together in a way that gives effect to both. Where required, the Privacy Policy or applicable data processing agreement may prevail for formal data protection matters.

42. Updates to This Policy

ELVOAQ may update this AI Transparency & Data Processing Policy from time to time.

Updates may reflect:

Changes in AI providers;

Changes in Grok model usage;

Changes in xAI terms;

Changes in platform functionality;

Changes in data processing practices;

Changes in security architecture;

Changes in applicable law;

Changes in enterprise requirements;

Changes in user controls;

Changes in retention practices.

The updated version will be posted on the ELVOAQ website or made available inside the platform.

The “Last Updated” date indicates when this Policy was last revised.

Continued use of ELVOAQ AI after an update may constitute acceptance of the updated Policy where permitted by law.

43. Contact

Questions about this AI Transparency & Data Processing Policy may be directed to ELVOAQ through the contact details provided in the ELVOAQ Privacy Policy, Terms of Use, website, or platform account area.

Users may contact ELVOAQ regarding:

AI data processing;

AI conversation deletion;

Privacy questions;

Security questions;

Business or enterprise processing;

Provider disclosures;

Data protection rights;

AI transparency;

Account-specific concerns.

44. Short Public Summary

ELVOAQ AI is a privacy-first intelligence layer built into the ELVOAQ platform. ELVOAQ uses Grok models through xAI Enterprise API and xAI API services to support selected AI features such as document analysis, image understanding, summarization, classification, and workflow assistance.

ELVOAQ does not sell user prompts, uploaded photos, documents, vault content, asset information, or AI conversations. ELVOAQ AI is not used to create advertising profiles. User prompts and chats may be stored inside ELVOAQ for the user’s own history and continuity, and users may delete AI chats where deletion functionality is available.

ELVOAQ’s AI architecture is designed around confidential processing, encryption, restricted access, data minimization, and user control. ELVOAQ aims to provide powerful AI functionality without turning private customer information into an advertising or data monetization product.

45. Premium Website Statement

ELVOAQ AI is designed for private intelligence, not public exposure.

Your prompts, uploaded photos, documents, asset records, and AI conversations are treated as confidential platform data. ELVOAQ does not sell your AI interactions, does not use them for advertising profiles, and does not monetize your vault content through third-party advertising systems.

ELVOAQ AI uses Grok models through xAI Enterprise API and xAI API services for selected AI capabilities. AI processing is designed around encryption, controlled access, confidential processing principles, and strict data minimization.

Privacy before personalization.

Security before convenience.

Control before compromise.

46. Final Statement

ELVOAQ believes that artificial intelligence should enhance user control, not weaken it.

The purpose of ELVOAQ AI is to help users understand, organize, protect, and manage important information with greater precision. AI should support the user’s vault, not exploit it.

ELVOAQ’s approach is simple:

We do not sell your AI data.

We do not build advertising profiles from your vault.

We do not treat your private records as a product.

We use selected AI providers, including Grok models through xAI Enterprise API and xAI API services, to provide requested platform functionality.

We design AI processing around encryption, confidentiality, data minimization, and user control.

We allow users to delete AI chats where deletion functionality is available.

We expect users to verify important AI outputs before relying on them.

ELVOAQ AI exists to make private asset intelligence more useful, more structured, and more controlled.

It is not built to expose your information.

It is built to help you command it.