Evolve Platform Privacy Policy
Definitions
Website: Any web page or collection of web pages including all content,
functionalities, services, and software provided through them, managed or controlled
by EvolveApp Inc, and accessible over the internet, including but not limited to the
primary web address used by EvolveApp Inc, as well as any related subdomains,
microsites, or web pages. This term encompasses both desktop and mobile versions of
such web pages, as well as any related digital or electronic services offered by
EvolveApp Inc through these web pages.
Law: Refers to the applicable laws of the State of Delaware, USA, regarding data
protection and privacy. Additionally refers to General Data Protection Regulation
(GDPR) in relation to the users located on the territory of the European Union.
Mobile Application: Software (including all existing additions and improvements)
designed to operate on smartphones, tablets, watches, and other mobile devices,
developed for specific platforms (iOS, Android, Windows Phone, etc.).
Personal Data: A collection of personal data and/or non-personalized information
about the User, provided by the User themselves to the Platform owner and/or
automatically collected by the Platform owner and/or third parties.
Platform: A computer program represented in objective form as a collection of data
and commands which includes source code, databases, audiovisual works, other
legally protected intellectual property objects, and all documentation for its use. The
Platform is presented in the form of a Website and a Mobile Application.
Policy: This Privacy Policy of the Platform (with all existing amendments and
changes).
User: A legal or natural person who has accessed the Platform via the website or
Mobile Application.
User Agreement: The agreement concluded between the Platform owner and the
User regarding the terms, rules, and features of the User’s use of the Platform. The
User joins such an agreement and has no right to make and/or demand any changes or
additions. The User can review the terms of the User Agreement at the following link:
https://app.evolveplatform.ai/en/privacypolicy.
Platform Owner: Refers to the following entity, which owns exclusive rights to the
Platform:
EvolveApp Inc
8 The Green
Dover, Delaware (DE), 19901
Contact: support@evolveplatform.ai
Cookies: Small files sent by any mobile applications or websites, and placed on
smartphones, tablets, watches, and other mobile devices of the User, to improve the
operation of such applications or websites, and the quality of content hosted on them.
Scope of the Policy
This Policy is used and applicable exclusively to Personal Data received from the User in
connection with their use of the Platform. The provisions of this Policy are aimed at:
1. Defining the types and kinds of Personal Data received, directions and purposes of the
use (processing) of Personal Data, as well as the sources of obtaining such Personal
Data.
2. Defining the User’s rights regarding the protection of the confidentiality of their
Personal Data.
3. Identifying individuals responsible for the processing and storage of Personal Data, as
well as third parties to whom such data is disclosed (fully or partially). The rules of
this Policy do not apply in cases of processing by third parties of Personal Data
voluntarily provided by the User. By opening the Website and/or installing the Mobile
Application on a smartphone, tablet, watch, or other mobile device, the User agrees to
the terms of this Policy and consents to the Platform Owner collecting, processing,
retaining, and storing Personal Data under the terms and conditions provided by this
Policy. If the User does not agree with the terms of the Policy and/or if any terms of
the Policy are unclear to them, the User must immediately cease using the Platform.
User Rights for Data Protection
Upon providing Personal Data, the User automatically obtains the following rights:
1. To receive information about the processing of their data (the basis and purposes of
such processing, methods used, information about individuals who have access to the
data or to whom they may be disclosed based on the agreement or Law).
2. To receive information about the location and identification data of individuals
processing Personal Data.
3. To receive information about the terms of storage of Personal Data.
4. To receive information about the planned or actual cross-border transfer of Personal
Data.
5. To receive information about the location and identification data of individuals
storing Personal Data.
6. To contest the actions or inaction of the Platform Owner at the authorized body for
the protection of personal data rights or in court.
7. To receive compensation for damages and/or compensation for moral harm in court as
a result of violations of the User’s rights to the protection and security of their
Personal Data committed by the Platform Owner and/or third parties.
8. To exercise other rights in the field of data protection provided by Law or the
provisions of this Policy.
List of Collected Personal Data
Non-personalized information about users
In connection with the use of the Platform, the Platform Owner may automatically collect and
process the following non-personalized information about the User:
1. Information about traffic, the possible number of clicks, logs, and other data.
2. Information about the device (identification number, mobile network), from which
access is performed, operating system, platform, browser type, and other browser
information, IP address. Personal data about users The User provides the Platform
Owner with the following personal data:
Personalized information about users
3. Full surname, name.
4. User's gender.
5. Photograph of the User.
6. User's email address.
7. Data from the following social network should this network be used for user’s
authentication: Facebook, Google. The Platform Owner may collect, process, and
store the User ID of any of the social networks used by the User within the Platform.
If the User's registration on the Platform is carried out using one of their accounts in
social networks, the User thereby provides automatic consent to the Platform Owner
for the collection, processing, and storage of Personal Data, which became available
to the Platform Owner through the selected social network.
8. All photos, video clips, audio files, and other types of media stored on the device from
which access to the Platform is performed.
9. Data contained in the User's personal account (profile), all internal correspondence of
the User (if any), as well as other activities of the personal account (profile) of the
User.
10. Data about all publications made by the User on the Platform, including but not
limited to, comments, ratings, reviews, report publications, videos, and photos,
placing likes, ratings, and/or any other forms of activity available to the User on the
Platform, and/or created content.
11. Data and information obtained as a result of combining certain Personal Data of a
specific User, as well as data and information about the User obtained from third
parties (partners, marketers, researchers). The User is the only responsible party for
the completeness of the provided personal (personal) data and is obliged to change
them (update, verify, correct) on a regular basis. The Platform Owner assumes that all
personal (personal) data provided by the User are accurate, and that the User
maintains such information in a current state.
Purposes of Collection and Processing of Personal Data
Definition of processing purposes
The collection and processing of Personal Data are carried out for the following purposes:
1. For analyzing User behavior, as well as identifying User preferences for a certain type
of content.
2. For the operational and correct operation of the Platform, improving the functioning
of the Platform, improving the content of the Platform, improving the internal
architecture and functionality of the Platform.
3. For identifying the User.
4. For providing personalized experience and effective learning.
5. To comply with the requirements of the Law.
6. For technical support of the Platform, identifying problems in its operation and their
elimination.
7. To maintain communication with the User (communication).
8. To fulfill other obligations of the Platform Owner, which arose before the User.
9. To conduct statistical research.
10. For any other purposes, provided that separate consent from the User is obtained.
The processing of Personal Data is carried out based on the principles:
(1) legality of the purposes and methods of processing; and
(2) data security; and
(3) compliance of the purposes of processing Personal Data with the purposes previously
defined and declared during the collection of such Personal Data; and
(4) compliance of the volume and nature of the processed Personal Data with the declared
purposes of their processing.
Conditions for processing personal data
The processing of Personal Data is carried out in cases:
(1) obtaining consent from the User; or
(2) achieving the purposes of the Platform Owner provided by an international treaty or
Law; or
(3) provision by the User of their Personal Data to an unlimited number of persons; or
(4) fulfilling other obligations of the Platform Owner to the User, including, but not
limited to, providing certain content to the User; or
(5) saving the life or health of the User, when consent to the processing of his Personal
Data cannot be obtained in advance. In the case of anonymization of Personal Data,
which does not allow directly or indirectly identifying the User, subsequent use and
disclosure of such data to third parties are allowed and the rules of this Policy no longer
apply to them. The Platform Owner takes all possible measures to protect the
confidentiality of the received Personal Data, except in cases when the User has made
such data publicly available. The processing of Personal Data is carried out using
automation means and without the use of such means of automation.
Third Party Access to Personal Data
Use of analytical platforms
The Platform Owner uses the analytical platform Yandex to
(1) track the frequency of site visits by Users; and
(2) track the ways the User uses the Platform and/or its content; and
(3) identify the type and kind of content that is popular among Users; and
(4) determine the location of the User.
The User also gives their consent to the Platform Owner to use information obtained about
the User from Yandex. For these purposes, the Yandex analytical platform may collect data
about the IP address, geolocation, user behavior, as well as their preferences and interests
regarding certain content. The Yandex analytical platform accesses Personal Data to provide
the Platform Owner with insights on how effectively their platform operates, which content is
popular, how effectively ads are placed within it, and for purposes of developing and/or
improving the existing marketing strategy of the Platform Owner.
By registering on the Platform, the User agrees to the privacy policy of Yandex and to the
automatic installation of corresponding cookies on the User's device.
Disclosure of Personal Data to Third Parties:
The Platform Owner may disclose Personal Data to:
1. Its affiliates, branches, and representatives, both within the territory of the United
States of America and in other countries.
2. Successors of the Platform Owner who have arisen as a result of its liquidation,
reorganization, or bankruptcy and who have acquired exclusive rights to the Platform.
3. Third parties exclusively for the purposes of providing the User with certain content
or access to it.
4. Third parties who act as partners of the Platform Owner in preparing certain content
(Service Provider), as explicitly stated in the description of each course.
5. Third parties who act as Data Controllers using the Platform as a Learning
Management System (LMS)
The Platform Owner discloses Personal Data only if:
1. They are confident that third parties will comply with the terms of this Policy and take
the same measures to protect the confidentiality of Personal Data as the Platform
Owner does.
2. Consent for such disclosure has been expressed by the User through registration in the
application and joining this Policy.
Third-Party Advertising:
The Platform's content may include advertising banners and/or links to third-party websites.
The use of such websites by the User (by following a link or any other means) may result in
the collection, processing, and use of Personal Data, and the possible automatic transfer of
cookies to the User's device from which the transition to the third-party site is made. The
Platform Owner bears no responsibility for the methods, practices, and order of processing
Personal Data by third-party sites. Consequently, the Platform Owner is also not responsible
in case Personal Data is disclosed to an unlimited number of people in connection with the
use of such sites by the User.
The Platform Owner strongly recommends that each User thoroughly familiarize themselves
with the personal data protection policies of the sites they use.
Advertising in the Mobile Application: The Platform Owner places various advertising and
marketing materials on the Platform, taking into account the preferences of the User
regarding certain content. Placement of advertisements on the Platform involves the
installation of certain cookies on the User's device.
Procedure for Submitting Complaints and Requests to the Platform Owner: Request to
Stop Processing Personal Data:
Each User has the right to express their objection to the Platform Owner against the
processing and/or storage of their Personal Data. Such an objection can be expressed as
follows:
The request must be sent to the Platform Owner at the following address:
support@evolveplatform.ai
Request for Information about Personal Data:
If the User has questions related to the application or use of this Policy, the order and/or
method of processing Personal Data, the User may ask such a question as follows:
The request must be sent to the Platform Owner at the following address:
support@evolveplatform.ai
Changes (updates, additions, corrections) or Deletion of Personal Data:
The User has the right at any time to independently change or delete their Personal Data,
except when such change or deletion may lead to a violation of the rules of this Policy; or to a
violation of the Law; or the nature of such Personal Data is evidence in any judicial process
that arose between the Platform Owner and the User. For this, the User needs to delete their
personal account (cabinet) on the Platform.
The Platform Owner has the right at any time to delete the User's personal account, as well as
all Personal Data about the User, if they violated the terms of this Policy and/or User
Agreement.
In case of deletion of Personal Data about the User, all publications made by the User
(comments, ratings, reviews, report publications, videos, and photos, placing likes, ratings)
and/or any other forms of activity available to the User on the Platform are also subject to
automatic deletion.
Periods and Order of Storage of Personal Data:
Storage is carried out by third parties at the direction of the Platform Owner. The User
consents to the storage of their Personal Data by third parties at the direction of the Platform
Owner, provided that such third parties maintain the confidentiality of the received Personal
Data. The functions of storing information are entrusted to the following entity:
AMAZON.COM, INC. ("Custodian").
Storage is carried out for the entire period of the User's use of the Platform.
The Platform Owner undertakes to immediately destroy or anonymize the User's Personal
Data after they cease using the Platform.
Procedure for Protecting Personal Data: Protecting the confidentiality of Personal Data is
a paramount and important task for the Platform Owner. The Platform Owner adheres to all
required international standards, rules, and recommendations for the protection of Personal
Data.
The Platform Owner has implemented a number of technical and organizational methods
aimed at protecting Personal Data from disclosure or unauthorized access by third parties.
Final Provisions: Availability of the Policy Text for Review:
Users can review the terms of this Policy at the following link:
https://app.evolveplatform.ai/en/privacypolicy. This edition of the Policy is effective from
November 1, 2024.
Amendment and Addition to the Policy:
This Policy may be changed from time to time. The Platform Owner bears no responsibility
to the User for changing the terms of this Policy without permission and/or consent from the
User.
The User themselves must regularly check the provisions of this Policy for possible changes
or additions.
Applicable Legislation:
This Policy is developed in accordance with the applicable data protection laws of the State
of Delaware, USA, as well as the General Data Protection Regulation (GDPR).
Risk of Disclosure:
Regardless of the protective measures taken by the Platform Owner to protect the
confidentiality of received personal data, the User is hereby duly informed that any transfer
of Personal Data over the Internet cannot be guaranteed to be secure, and therefore the User
makes such a transfer at their own risk.
