Privacy image piggybank surrounded by coloured keys

PRIVACY POLICY Last updated 10 March 2021

INTRODUCTION

Evolve Technologies Limited (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”). Please read this privacy policy carefully.  If you do not agree with the terms of this privacy policy, please do not access the site.

We reserve the right to make changes to this Privacy Policy at any time and for any reason.  We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy.  Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.

This privacy policy was created using Termly.

COLLECTION OF YOUR INFORMATION

We may collect information about you in a variety of ways. The information we may collect on the Site includes:

Derivative Data

Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site.

Mobile Device Data

Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.

USE OF YOUR INFORMATION

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience.  Specifically, we may use information collected about you via the Site to:

  • Compile anonymous statistical data and analysis for use internally or with third parties.
  • Generate a personal profile about you to make future visits to the Site more personalized.
  • Increase the efficiency and operation of the Site.
  • Monitor and analyze usage and trends to improve your experience with the Site
  • Perform other business activities as needed.
  • Resolve disputes and troubleshoot problems.
  • Respond to product and customer service requests.
  • Solicit support for the Site.

What legal basis do we have for using your information?

The legal basis for us using your information is:

By using the website and seeking information from it you consent to us doing so and we have a legitimate interest because the data will help us improve the experience for yourself and other users. It will also help us provide a better experience and offer it to more users in the future.

DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.

Third-Party Service Providers

We may share your information with third parties that perform services for us or on our behalf, including, data analysis, hosting services, customer service, and marketing assistance. We will not sell or rent your information to third parties

Third-Party Advertisers

We may use third-party advertising companies to serve ads when you visit the Site. These companies may use information about your visits to the Site and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.

Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Business Partners

We may share your information with our business partners to offer you certain products, services or promotions.

Other Third Parties

We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.

Sale or Bankruptcy

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity.  If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party.  You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations.  If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

TRACKING TECHNOLOGIES

Cookies and Web Beacons

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customize the Site and improve your experience. When you access the Site your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Site. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

Website Analytics

We may also partner with selected third-party vendors, such as Google Analytics, and others, to allow tracking technologies and remarketing services on the Site through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor.

More details of how Google and Google analytics uses data from our site can be found at:   www.google.com/policies/privacy/partners/

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

THIRD-PARTY WEBSITES

The Site may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site.

SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information.  While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.  Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

How long do we keep your information for?

We shall keep your information for as long as necessary to perform the purposes set out in this policy. After that we shall remove it permanently from our servers

POLICY FOR CHILDREN

We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.  If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy

What are your rights?

Under GDPR, you are entitled to access your personal information (otherwise known as a 'right to access'). If you wish to make a request, please do so in writing addressed to our Data Protection Officer Garth Vladislavich

A request for access to your personal information means you are entitled to a copy of the data we hold on you but it does not mean you are entitled to the documents or storage systems that contain this information

Under certain circumstances, in addition to the entitlement to ‘access your information’, you have the following rights:

The right to be informed: which is fulfilled by way of this privacy notice and our transparent explanation as to how we use your information

The right to rectification: you are entitled to have personal information rectified if it is inaccurate or incomplete

The right to erasure / ‘right to be forgotten’: you have the right to request the deletion or removal of your personal information where there is no compelling reason for its continued processing. This right only applies in the following specific circumstances:

  • Where the personal information is no longer necessary in regards to the purpose for which it was originally collected
  • Where consent is relied upon as the lawful basis for holding your information and you withdraw your consent
  • Where you object to the processing and there is no overriding legitimate interest for continuing the processing
  • The personal information was unlawfully processed
  • Where you object to the processing for direct marketing purposes

The right to object: you have the right to object to processing based on legitimate interests; and direct marketing. This right only applies in the following circumstances:

  • An objection to stop processing personal information for direct marketing purposes is absolute – there are no exemptions or grounds to refuse – we must stop processing in this context
  • You must have an objection on grounds relating to your particular situation
  • We must stop processing your personal information unless:
  • We can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms; or
  • The processing is for the establishment, exercise or defence of legal claims.

The right to restrict processing: you have the right to request the restriction or suppression of your information. When processing is restricted, we can store the data but not use it. This right only applies in the following circumstances:

  • Where you contest the accuracy of the personal information– we should restrict the processing until we have verified the accuracy of that data
  • Where you object to the processing (where it was necessary for the performance of a public interest or purpose of legitimate interests), and we are considering whether our organisation’s legitimate grounds override your right
  • Where processing is unlawful and you request restriction
  • If we no longer need the personal information but you require the information to establish, exercise or defend a legal claim

Complaints about the use of personal information

If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate further. Our Data Protection Officer is Insert name and e mail address

If you are not satisfied with our response or believe we are not processing your personal information in accordance with the law, you can complain to the Information Commissioner’s Office (ICO).

CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at:

Garth Vladislavich

Evolve Technologies Limited

Room 433/434, Royal Exchange Building, Manchester, M2 7EP

contactus@evolving.technology