Skip to content

Legal

Privacy Policy

Last Updated: April 2026

Data Controller: Vetoropiparo Unipessoal LDA (Lisbon, Portugal)

1. Strategic Intent

Lvlup operates on the principle of Information Parity. We collect and process data to arm the User with the intelligence required to command the market. We do not sell User personal data to third-party advertisers.

2. Data Collection: The Strategic Input

We process the following categories of data:

Identity Data:
Name, email, and authentication credentials.
Professional Intelligence (CV Content):
Work history, education, and skills. By uploading a CV, the User explicitly consents to the processing of any "Special Category Data" (Art. 9 GDPR) contained therein.
Usage Intelligence:
User interactions with "The Board," tracked through Google Tag Manager (Google Analytics 4) and HubSpot. These technologies are loaded only with your consent in the EU/UK and may be opted out of elsewhere — see Cookie Policy.

3. Proprietary Intelligence & AI Processing

External Analysis:
We utilize third-party APIs (OpenAI and Google Gemini). We rely on their contractual commitments that data sent via API is not utilized to train their foundational models.
Internal Evolution (Lvlup Model):
We use anonymized and de-identified data derived from User interactions and CV analyses to train and refine our proprietary career intelligence models. This processing is based on our Legitimate Interest in improving the platform intelligence, subject to User opt-out rights.

4. Cookies & Tracking Technologies

Lvlup uses two categories of cookies and comparable technologies: strictly-necessary (authentication, security, the consent mechanism itself) and optional (analytics + marketing). We do not load analytics or marketing scripts until you give consent.

EU / UK / EEA / Switzerland:
You see an opt-in banner on your first visit. Optional cookies are loaded only after you click "Accept all" or enable them in "Manage cookies". Withdrawal is as easy as giving consent.
United States & rest of world:
You see a notice on your first visit. You can opt out at any time via "Manage cookies" in the footer or our dedicated Do Not Sell or Share page. We honor the Global Privacy Control (GPC) signal as a clear opt-out.
Vendors and retention:
The full list of cookies, vendors, and retention periods is documented in our Cookie Policy.

5. Data Sovereignty & International Transfers

Primary Storage:
User data is currently stored on secure, encrypted servers within the European Union.
Global Scaling:
We reserve the right to move or replicate data to US-based servers to improve latency, provided such transfers comply with Standard Contractual Clauses (SCCs).

6. User Rights (GDPR)

Users retain full sovereignty over their professional data. You may exercise the following rights via privacy@lvlup.cv:

The "Kill Switch":
Deleting an account triggers a permanent deletion of original CV files within 30 days.
Opt-Out of Training:
Users may request that their data be excluded from our proprietary model training.

7. AI Transparency (EU AI Act Compliance)

Lvlup is an AI-augmented platform. We disclose that:

  • Our "Alignment Scores" are generated through algorithmic analysis.
  • We maintain internal logs of AI decision-making patterns to ensure fairness and mitigate bias for all Users.

8. Commercial Customization & Affiliates

We may use your CV analysis and usage data to suggest professional development tools and certifications. These recommendations are part of our "Symmetry Initiative" to help you bridge market gaps. We may receive commissions from third parties for these referrals. We do not share your raw personal identity data with these third-party affiliates; we only provide you with the link to their services.