EVOLVINGDATA SAS PRIVACY POLICY
This privacy policy (“Privacy Policy”) governs how EVOLVINGDATA SAS, (hereinafter referred to as “Company”, “we”, “our” or “us”) collects, uses and shares personal information:
about each client, individual, entity, user or visitor (collectively “you” or “your”);
and/or
you provide to us when accessing our (i) website located at www.evolvingdata.net , or (ii) historic and real time data streaming application programming interface, namely ‘Data Timeline API’ (collectively referred to as the “Site(s)”).
Company is committed to protecting your Personal Information (defined below). As such, this Privacy Policy will inform you as to how we look after your Personal Information (defined below) when you visit our Site.
By accessing the Site, you accept the terms and conditions of Company’ Privacy Policy, and you consent to Company’ collection, transfer, processing, storage, use and disclosure of your Personal Information as described under this Privacy Policy.
You acknowledge and understand that reading this Privacy Policy and understanding the terms and conditions contained herein are in your best interest. Your acceptance of Company’s Privacy Policy is deemed to occur upon your first use of the Site. If you do not accept and agree with this Privacy Policy, please refrain from using and/or accessing Company’s Site immediately.
PURPOSE OF PRIVACY POLICY
This Privacy Policy governs your access to Company’s Site and aims to provide you with information on how we collect and process your Personal Information (defined below), what data we collect when you use the Site, why we collect the data, how the data is used, and your rights and choices. This Privacy Policy applies to Personal Information (defined below) and other information collected by us from or about visitors to, or users of, our Site.
PERSONAL INFORMATION COMPANY COLLECTS FROM YOU
The term “Personal Information” means any information about an individual from which that person can be identified. Personal Information does not include data where the identity of the individual has been removed (i.e., anonymous data).
Company may collect, use, store and transfer Personal Information as follows:
Identity data includes your first name and last name.
Contact data includes phone number, and email address, and any other data you have provided to us in order for us to be able to provide you with our services on the Site.
Technical data includes your Internet protocol address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Site.
Profile data includes your username and password, your interests, preferences, and feedback.
Usage data includes information about how you use our Site and the services we offer.
Marketing and communications data includes your preferences in receiving marketing from us and our third parties, and your communication preferences.
Company does not collect any special categories of Personal Information, including but not limited to your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data, and information about criminal convictions and offences.
HOW YOUR PERSONAL INFORMATION IS COLLECTED
Company uses various methods to collect Personal Information from and about you including through:
Direct interactions. You may provide us with your identity and contact data by filling in forms or by corresponding with us via email. This includes Personal Information you provide when you:
create a user account on our Site;
use the services we provide to you via the Site;
request marketing to be sent to you; or
provide us with feedback or contact us.
Automated technologies or interactions. As you interact with our Site, we will automatically collect technical data about your browsing actions and patterns. We collect this Personal Information by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We will receive Personal Information about you from various third parties and public sources as set out below:
(a)analytics providers include but is not limited to Google analytics; and
(b)contact and transaction data from providers of technical, platform and payment services such as Stripe and PayPal.
HOW WE USE YOUR PERSONAL INFORMATION
Company may collect and use your Personal Information for any or all of the following purposes:
providing you with access to the Site and use of the services as requested by you;
verifying your identity;
responding to, handling, and processing queries, requests, complaints, and feedback from you;
managing your relationship with us;
processing payment transactions;
sending you information, promotions, updates, marketing and advertising materials in relation to our services;
managing, developing and improving our business and operations to serve you better;
complying with legal and regulatory requirements;
enforcing Company’s legal rights and obligations;
any other purposes for which we have obtained your consent; and
any other purposes reasonably necessary, ancillary or related to the above specified purposes.
Wherever possible, Company aims to obtain your explicit consent to process your Personal Information. We may continue to process your Personal Information on this basis until you withdraw your consent. You may withdraw your consent at any time by sending us an email at support@evolvingdata.net. However, if you do so, please note that you may not be able to use the Site and make use of the services further.
AUTOMATIC COLLECTION OF INFORMATION
When you visit the Site, Company’s servers automatically record information about your computer hardware and software. This information is collected automatically and is used only to identify potential cases of abuse, resolve technical issues, optimizing the performance of the Site for a better user experience, and establish statistical information regarding your use of the Site and the Services. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.
PERSONAL INFORMATION SECURITY
Company implements administrative, technical and physical security measures that include encryption, firewalls, password management and secure socket layer technology, which are designed to protect your information from unauthorized access, loss, misuse and potential security breaches.
We will notify you and any applicable regulator of a breach where we are legally required to do so.
You acknowledge that no data transmission over the Internet or wireless network can be guaranteed. Therefore, while Company strives to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and another user on the Site and/or the Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third-party, despite Company’ best efforts.
STORING PERSONAL INFORMATION
Payment information is securely stored by Stripe and PayPal cannot be accessed by Company. Company does not collect or store sensitive cardholder data, such as credit card numbers, or card authentication data.
All Personal Information is stored securely on Amazon Web Services (AWS). As such, you acknowledge that Personal Information may be stored and processed on Amazon Web Services (AWS) servers or other datacentre providers, located around the world.
SHARING PERSONAL INFORMATION
Company may sometimes (i) share Personal Information with sub-contractors and/or marketers for the sole purposes of providing the services to you; and (ii) contract with third party service providers to supply specific components of the services to you or to provide us with information about your use of the Site and our services. These may include payment processing facilities, behavioral analytics, logistic partners, and messaging applications. In some cases, the third parties may require access to some or all of your Personal Information. Where any of your Personal Information is required for such a purpose, Company shall take all reasonable steps to ensure that your Personal Information will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law. Personal Information will only be shared and used within the bounds of the law.
DATA RETENTION
Company will only retain your Personal Information for a minimum of five (5) years or for as long as (i) you are a registered user on the Sites; and (ii) is reasonably necessary to fulfil the purposes we collected such Personal Information for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
YOUR RIGHTS REGARDING THE GENERAL DATA PROTECTION REGULATION
For the purposes of complying with the General Data Protection Regulation 2016/679 (“GDPR”), Company is considered as the data controller in relation to your Personal Information. As such, you have certain rights as provided under GDPR and applicable data protection laws in relation to your Personal Information. You have the right to:
Request access to your Personal Information (commonly known as a ‘data subject access request’). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel the processing of your Personal Information will impact on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: if you want us to establish the data’s accuracy; where our use of the data is unlawful, but you do not want us to erase the data; where you need us to hold the data even if we no longer require the data as you need the data to establish, exercise or defend legal claims; or you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use your Personal Information.
Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you. We will advise you if this is the case at the time you withdraw your consent.
TRANSFERS OF PERSONAL INFORMATION OUTSIDE OF EUROPE
You expressly agree that Company may transfer your Personal to countries outside of Europe. As such, Company will take appropriate steps to ensure that: (i) Company will comply with our obligations as provided under the GDPR or any other applicable date protection legislation, in respect of the transfer of your Personal Information while such Personal Information remains in Company’ possession or under our control; and (ii) the recipient/third party of the Personal Information outside of Europe is bound by legally enforceable obligations to provide a standard of protection that is at least comparable to that provided under the GDPR or any other applicable data protection legislation.
DATA CONTROLLER AND DATA PROCESSOR
Company is the data controller responsible for your Personal Information, but Company also acts as a data processor for Personal Information that we process on your behalf.
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below:
Full name of legal entity: EVOLVINGDATA SAS
Email address: support@evolvingdata.net
Postal address: 10-12 RUE ANDRAS BECK 92360 MEUDON
ANALYTICAL DATA FROM THIRD PARTIES
Company may collect or receive information that third party service providers may provide about you when using the Site and/or the services. Company may also obtain information from other sources and combine that with information Company collects through your use of the Site and services. The following information is collected and/or obtained from third parties:
Google Analytics: We use this analytical tool to help Company analyze (i) how users use the Site and/or the services by noting when you use the Site and the services, and (ii) usage data and performance data. The information collected will be disclosed to or collected directly by the applicable analytical tool Company is using. Such information is collected as a means to provide, improve, and develop the Site so as to create a safer and trusted environment when you use the Site.
Amazon Web Services: We use this service as a means of hosting Company’ Site and for providing the services. Amazon Web Services may collect all information you provide us with, and all information we automatically collect as a means of facilitating the functions of the Site and services.
Stripe and PayPal: We use these tools as payment gateway providers. Stripe and PayPal may collect information you provide to us as a means of processing payments you make on the Site for the services.
OUR POLICY TOWARD CHILDREN
Our Site and services are not directed to persons under the age of eighteen (18) years. We do not collect Personal Information from children under the age of eighteen (18) years. We therefore encourage you to obtain the assistance and consent of a parent/legal guardian when accessing our Site and using the services. A parent/legal guardian who becomes aware that his or her child has provided us with Personal Information without their consent, should contact us at support@evolvingdata.net and we will endeavour to delete the relevant data.
OPT-OUT RIGHTS
You can stop all collection of Personal Information by Company by not accessing the Site and the services, or by requesting to opt-out via email, at support@evolvingdata.net .
CHANGES AND AMENDMENTS TO PRIVACY POLICY
Company may update this Privacy Policy from time to time in Company’ sole discretion and will notify you of any material changes to the way in which Company treats Personal Information. When changes are made, Company will revise the updated date at the top of this page. We may also provide notice to you in other ways in our sole discretion, such as through the contact information you have provided. Any updated version of this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified. Your continued use of the Site and services after the effective date of the revised Privacy Policy will constitute your consent to those changes. However, Company will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
Contact Information
Should you have any questions or concerns regarding privacy while using the Sites, please send us a detailed message to support@evolvingdata.net , and Company will use its best endeavours to resolve your concerns.
