Our Privacy Policy

This is the Privacy Policy of Evolvement Change LLC (after this: “Evolvement Change“). We take your privacy very seriously. Please read this privacy policy carefully. It contains essential information on who we are and how and why we collect, store, use, and share your personal data. It also explains your rights concerning your personal data and how to contact us or supervisory authorities if you have a complaint.

We collect, use, and are responsible for specific personal data about you. If you live in the European Union, that data is subject to the General Data Protection Regulation (“GDPR“), and we are responsible as ‘controller’ of that personal data for the purposes of those laws.

 

Personal data we collect about you

 

We may collect and use the following personal data about you:

  • your name and contact information, including job title, email address and telephone number, and details of the organization you work for

  • your contact history with us

  • Information about how you use our website, IT, communication, and other systems

 

How your personal data is collected

  • We collect most of this personal data directly from you— for example, when you register for a class or via email and/or contact forms on our website.

 

How and why we use your personal data

 

Under data protection law, we can only use your personal data if we have a proper reason for doing so, e.g.:

  • To comply with our legal and regulatory obligations.

  • For the performance of our agreed-upon services with you or to take steps at your request before entering into an agreed-upon service with you.

  • for our legitimate interests or those of a third party; or

  • where you have given consent.

 

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The information below explains what we use (process) your personal data for and our reasons for doing so:

What we use your personal data for and Our reasons

What: To provide you with downloads, demos, webinars, or other information or assistance you have requested

Reason: For our legitimate interests or those of a third party, i.e., to provide you with the requested information.

What: To provide services to the organization, you work for

Reason: For the performance of our contract with you. For our legitimate interests or those of a third party, i.e., providing our customers with the service they have contracted for.

What: To prevent and detect fraud against you or us

Reason: For our legitimate interests or those of a third party, i.e., to minimize fraud that could damage you and us.

 

What: Conducting checks to identify users of our services and verify their identity

Reason: To comply with our legal and regulatory obligations.

 

What: Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies

Reason: To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, i.e., to help ensure we act as a responsible business services provider.

 

What: Ensuring business policies are adhered to, e.g., policies covering security and internet use

Reason: For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures to deliver the best service to our customers.

 

What: Operational reasons, such as improving efficiency, training, and quality control

Reason: For our legitimate interests or those of a third party, i.e., to be as efficient as possible so we can deliver the best service to our customers at the best price.

 

What: Ensuring the confidentiality of commercially sensitive information

Reason: For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information. To comply with our legal and regulatory obligations.

 

What: Statistical analysis to help us manage our business, e.g., about our financial performance, customer base, product range, or other efficiency measures

Reason: For our legitimate interests or those of a third party, i.e., to be as efficient as possible so we can deliver the best service for you at the best price.

 

What: Preventing unauthorized access and modifications to systems

Reason: For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could damage you and us. To comply with our legal and regulatory obligations

 

What: Updating and enhancing customer records

Reason: For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products

 

What: Marketing our services to:—existing and former customers; —third parties who have previously expressed an interest in our services;—third parties with whom we have had no previous dealings.

Reason: For our legitimate interests or those of a third party, i.e., promoting our business to existing and former customers. Where we engage in direct email marketing, we will ask for your consent to this (unless you work for a prospective customer who is a company or other corporate organization or a public body)

 

What: To enforce or review or defend claims under our customer agreements or other contracts

Reason: For our legitimate interests or those of a third party, i.e., ensuring that our rights and obligations are adequately maintained in any dispute.

Promotional communications

We may use your personal data to send you updates (by email, phone, or post) about our services, including exclusive promotions or new services.

 

We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where permission is required, we will ask for this consent separately and clearly.

 

We will always treat your personal data with the utmost respect and never sell it to other organizations.

 

You have the right to opt-out of receiving promotional communications at any time by:

  • contacting us at the contact points below

  • using the ‘unsubscribe’ link in emails

 

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 our business structure.

 

Who we share your personal data with

 

There are very few occasions where we might share your data.

 

We may disclose and exchange information with law enforcement agencies, regulatory bodies, and others to comply with our legal and regulatory obligations. 

 

We may also need to share personal data with other parties, such as potential buyers of some or all of our business or during a merger, company sale, or corporate restructuring. Usually, information will be anonymized, but this may not always be possible. 

 

Where your personal data is held

 

Information may be held with our service providers, representatives, and agents as described above (see above: ‘Who we share your personal data with’). Some of these third parties may be based outside the USA.

 

How long your personal data will be kept

 

We will keep your personal data as long as you engage with us or provide services to you or the organization you work for. After that, we will keep your personal data for as long as is necessary:

  • to respond to any questions, complaints, or claims made by you or on behalf of the organization you work for;

  • to keep records required by law.

 

We will not retain your personal data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal data.

 

When it is no longer necessary to retain your personal data, we will delete or anonymize it.

 

Your rights

 

You have the following rights, which you can exercise free of charge:

 

Access

 

The right to be provided with a copy of your personal data (the right of access)

 

Rectification

 

The right to require us to correct any mistakes in your personal data

 

To be forgotten

 

The right to require us to delete your personal data—in certain situations

 

Restriction of processing

 

The right to require us to restrict processing of your personal data—in certain circumstances, e.g., if you contest the accuracy of the data

 

Data portability

 

The right to receive the personal data you provided to us in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations

 

To object

 

The right to object:—at any time to your personal data being processed for direct marketing (including profiling);—in certain other situations to our continued processing of your personal data, e.g., the processing carried out for the purpose of our legitimate interests.

 

Not to be subject to automated individual decision making

 

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

 

For further information on each of those rights, including the circumstances they apply, please contact us.

 

If you would like to exercise any of those rights, please:

  • email, us using the contact details below; and

  • let us have enough information to identify you;

  • let us have proof of your identity; and

  • let us know what right you want to exercise and the information to which your request relates.

 

Keeping your personal data secure

 

We have appropriate security measures to prevent personal data from being accidentally lost, used, or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. 

 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach. We are legally required to do so. 

 

How to complain

 

We hope to resolve any query or concern you may raise about our use of your information. 

 

The GDPR also gives you the right to lodge a complaint with a supervisory authority, particularly in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

 

Changes to this privacy policy

 

This privacy notice was published on August 5th, 2021, and last updated on August 5th, 2021.

 

We may change this privacy notice from time to time—when we do, we will inform you via our website or, if appropriate, by email.

 

Contact details

 

Evolvement Change LLC
384 Waterfront Dr.
Saint Johns, Florida 32259 USA

 

You can also contact us via this website or email us at info@evolvementchange.com.