Effective Date: January 1, 2020
Last Updated: December 31, 2019
Evertio, Inc. (“Evertio,” “we,” “us,” or “our”) values the privacy of those (“you,” “your,” “customer(s),” and “user(s)”) who visit our website and/or use our apps or services (collectively, “Services”) and any other individuals that we obtain their Personal Information from (defined below). We are the data controller of the Personal Information we process, and is therefore responsible for ensuring that the systems and processes we use are compliant with data protection laws, to the extent applicable to us.
This policy applies to information we collect on the Services, in email, text, and other messages between you and the Services, and when you interact with our advertising and applications on third-party websites and services (if those applications or advertising include links to this Policy).
Information we collect and information you provide
We may collect your information in a variety of ways through your use of the Services including when you visit or browse the Services and the pages, fill out and submit a form or your email address, or access and use our Services. The type of information we collect varies and may include:
1. Personal Information you voluntarily provide to us.
Personal information is information that can be used to identify you as an individual (“Personal Information”). When you contact us or access and use our Services, we may collect a variety of information, including, but not limited to, first name, last name, personal address, phone number, email address, Location Data, certain Usage Data (defined below), such as IP address. You are not required to provide Personal Information to us.
We collect Personal Information from a number of sources, either directly from the data subjects, publicly available sources, or from colleagues.
“Location Data” is a category of Personal Information collected about the location of a mobile device or computer, including: the location of the mobile device or computer used to access the Services derived from GPS or WiFi use; the IP address of the mobile device or computer or internet service used to access the Services (however, depending on the jurisdiction and applicable law, IP address may be considered non-personal information, and if that’s the case, it will be treated as such); and other information made available by a user or others that indicates the current or prior location of the user.
2. Non-personal Information we collect when you access or use our Services.
Non-personal information is information that does not necessarily identify you as an individual (“Non-personal Information”). This may include a variety of information, including, but not limited to, Usage Information (defined below) and information related to your interaction with our Services.
“Usage Information” or “Usage Data”—information about an individual’s online activity that, by itself, does not identify the individual, such as: your activity in using our Service (for example, terms you search for, videos you watch, your views and interactions with content and ads, purchase activity, people with whom you communicate or share content, and activity on third-party sites and apps that use our services), technical information, including your browser type, service provider, IP address (IP address, by itseslf, may or may not identify your as an individual under the applicable laws and therefore this type of information is also listed under Subsection 1 “Personal information you voluntarily provide to us” above), operating system and web pages visited; information about what you’ve searched for and looked at while using the Services or how you interact with the Services; metadata, which means information related to items you made available through the Services, such as the date, time or location that a shared photograph or video was taken or posted.
Generally, we do not consider Usage Data as Personal Information because Usage Data by itself usually does not identify an individual. Personal Information and Usage Data, as well as different types of Usage Information, may be linked together and, once linked, may identify an individual person. Some Usage Data may be Personal Information under applicable law and will be treated as such. If we do combine Non-personal Information with Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
Do Not Track
California law requires us to disclose how we respond to web browser Do Not Track (“DNT”) signals. We do not respond to or take any action with respect to a DNT configuration set in your internet browser, and therefore, do not disable tracking.
How we collect information
- When we receive your information from cookies and other data collection tools.
- We, along with the service providers that help us provide the /or Services, use small text files called cookies. Cookies are small computer files sent to or accessed from your web browser or your computer’s or tablet’s hard drive that contain information about your computer, such as a user ID, user settings, browsing history and activities conducted while using the Services. Cookies are not themselves personally identifiable, but may be linked to Personal Information that you provide to us through your interaction with the Services. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. Cookies help us improve the Services by tracking users’ navigation habits and storing users’ password, customizing users’ experience with the Services; enabling us to analyze technical and navigational information about the Services and to provide features, insights, and personal content preferences; and helping to detect and prevent fraud and for performance analytics and research. Some web browsers (including some mobile web browsers) provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Services.
We may also use other third party services, such as:
- Mailchimp, which manages our email services and landing pages, including our newsletters, promotional emails, and administrative messages. Mailchimp also helps us to understand whether and when our emails are opened, whether we already have sent a particular message to you, on which links have been clicked within emails or landing pages, subscription preferences, and helps us market to you. You can learn more about Mailchimp’s privacy practices here.
Why we use information we collect
We may collect, process, use or disclose your Personal Information for the following purposes (“Purposes”). Each of the Purposes is justified by a “legal basis”, that is, a specific condition.
Our Purposes are as follows:
- To design and improve our Services and our content;
- To help provide technical and services support and client/user communications;
- To enhance your overall Services experience;
- To provide to you any Services offered or will be offered on the website;
- To respond to your requests, verify your identity, and carry out requests made by you in relation to our Services;
- To protect the rights, property or safety of us or third parties, including our other clients and users of our Services;
- To maintain our records;
- To provide notification to users about updates, Website, Services, and changes to our terms, conditions, and policies;
- Where you have given consent; and/or
- As otherwise permitted or required by applicable law.
Our legal basis for this collection, processing, use, or disclosure of your information above is that it is in our legitimate interest or a third party’s interest to do so as it is necessary: for our compliance with legal obligations, consistent with applicable laws; to establish, enforce, or defend our legal rights; to protect the rights of third parties; for fulfillment of Services; to develop and grow our business and Services and promote the our reputation; and/or to provide client services to you. In some cases, this processing is necessary to perform a contract to which you are a party.
We may also use your information:
- To conduct market research, implement marketing strategies, send you updates (by email, text message, telephone), newsletters, promotions, or new services;
- To administer any promotional programs that you enter into; and
- To identify potential business opportunities.
Our legal basis to use your information for marketing and client development purposes is that it is in our legitimate interest to develop and grow our business and Services and promote our reputation. Because of this legitimate interest, we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly. You can opt out anytime by emailing us at firstname.lastname@example.org and/or proceed with the link available to unsubscribe in the email sent to you, as applicable.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
How and we share and disclose your information
We share and publish Personal Information we collect with certain third parties, as we deem necessary, with your consent, or as we see appropriate in connection with delivering, operating, maintaining and/or providing the Services to you. They include:
- Third parties we use such as a payment or credit card processing company for clients to pay for our Services, a company that builds our maintains our Services, a company that assists us with client insight analytics, such as Google Analytics and FullStory, and a company that provides data hosting, software, cloud services to store your information, or other technology services. We will share your Personal Information only as necessary for the third parties to provide those services. Additionally, if we use or partner with third parties to provide specific services or information to you, those third parties may be allowed to use your Personal Information to provide such services. We do not share your Personal Information with third parties for their direct marketing purposes.
- Our professional advisers, such as lawyers and accountants.
- Third party postal or courier providers who assist us in delivering our postal marketing campaigns to you.
- Law enforcement and public and governmental authorities as it may be necessary by law, legal process, litigation, and/or requests whether they come within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. This also applies to Non-personal Information.
- Other third parties if we determine that disclosure is reasonably necessary to enforce our terms and conditions, to fulfill legal duties and avoid conflicts of interest, to protect our operations or clients, as well as our rights, property, or interests, or to prevent misuse or unauthorized use of the Services.
- Relevant third parties in the event of a reorganization, merger, or sale where we may transfer any and all Personal Information we collect to the relevant third party.
- Other third parties when you have agreed that we may do so.
Except as otherwise stated in this Policy, we do not sell, rent, or otherwise share Personal Information to anyone and may only share it with third parties described above.
The Personal Information you provide may also be provided to our partners and third parties we believe may offer products or services of interest to you. We offer you the opportunity to opt out of receiving promotional e-mail, calls or mail. Please contact us using the contact information provided at the end of this Policy should you choose to opt out. This mechanism does not allow a user to opt out of receiving transactional e-mail, such as registration confirmation, product updates and responses to direct requests.
We may collect, use, transfer, and disclose Non-personal Information for any purpose, in any manner, and to any third party as we deem appropriate or necessary. We may also sell, share, or disclose Non-personal Information from time to time at our sole discretion.
Links to Third Party Services
How can you review, update, or delete the data we collect from you?
Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact us at email@example.com. We will respond to your request within 30 days. If we are unable to accommodate your request, we will let you know why we are unable to do so.
Data retention and storage
The Personal Information we collect is stored in one or more databases hosted by one or more third parties. We require companies performing Services on our behalf to protect your Personal Information in a manner appropriate to the type and sensitivity of the information, and to use it only in connection with those Services.
We retain and use Non-personal Information for as long as needed and as we deem appropriate and necessary for any purposes, including but not limited to, to develop, improve, and provide Services, comply with our legal obligations, resolve disputes, perform fraud prevention efforts, and enforce our agreements.
Security of your information
To help protect the privacy of Personal Information you transmit through use of our Services, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. When you provide your payment information to us, this information is stored on our third party provider’s secure servers. Our third party provider uses encryption technology to ensure safeguards are in place. We have appropriate security measures to prevent Personal Information from being accidentally lost, or used or accessed unlawfully.
We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, security system, or method of electronic storage, is 100% secure. Although we do our best to protect your Personal Information, we do not guarantee the security of any information you transmit to us or provide online. Any transmission of Personal Information is at your own risk. If you have any questions about security on our Services, you can contact firstname.lastname@example.org.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) access to certain parts of our Services, you are responsible for keeping this access confidential. We ask you not to share this access with anyone. We urge you to be careful about giving out personal or private information in public areas of the Services. The information you share in public areas may be viewed by any user of the Services.
The services are not directed to individuals under the age of thirteen (13), and we request that they not provide Personal Data through the services.
Transferring Personal Information from the European Union (US) to the United States (US)
Your privacy choices
You may request us to have access, correct, amend, update, or delete your Personal Information, or update your preferences, including opting out of particular communications, by contacting email@example.com. Please remember that limited communications may be necessary in order to complete your transaction or for you to participate in our Services.
Your California Privacy Rights
If you are a California resident, you may be entitled to additional rights over your personal information. For more information about those rights and how to exercise them, please see our California privacy notice here, which is incorporated by reference into this policy.
Questions, concerns or complaints
20283 Santa Maria Ave # 2132
Castro Valley, CA 94546