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Evolve Platform Privacy Policy

This Privacy Policy describes how and why EvolveApp Inc. ("EvolveApp", "Company",

"we", "us", or "our") collects, uses, stores, and otherwise processes personal information

through the Website and any software applications, platforms, or services made available by

EvolveApp for use on a computer, tablet, mobile phone, or other device (collectively,

the "Services").

This Privacy Policy explains what personal information we collect, why we collect it, how we

protect it, and the rights and choices available to you regarding your personal information.

This Privacy Policy applies only to personal information collected through the Services.

Your use of the Services is also governed by our Platform User Agreement and any other

agreements or policies that may apply to your use of the Services.

1. DEFINITIONS

• "Applicable Law" refers to the Applicable Laws and regulations governing the

processing of Personal Data under this Policy, including applicable U.S. federal and

state laws, regarding electronic communications, data protection and privacy.

Additionally refers to General Data Protection Regulation (GDPR) in relation to the

users located within the territory of the European Union. Additionally refers to UK

General Data Protection Regulation (UK GDPR) together with the Data Protection

Act 2018 in relation to the users located within the territory of the United Kingdo

• "Company" 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

including its subsidiaries and affiliates, and any entities created as a result of the

reorganization of the Company.

• "Content Provider" means any individual or legal entity, other than EvolveApp Inc.,

who, pursuant to a separate agreement with EvolveApp Inc., uploads, submits,

publishes, or otherwise provides course content, materials, or information to the

Platform, and who may also provide personal data of its own users for the purposes of

account creation, course enrollment, or analytics, and who may access analytics or

reports about those users via the Platform.

• "Cookies" refers to small files sent by any mobile applications or websites, and

placed on smartphones, tablets, watches, and other mobile devices of the User, to

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improve the operation of such applications or websites, and the quality of content

hosted on them.

• "Customer" means any legal entity that enters into an agreement with the Company

for access to or use of the Platform or Services, provides one or more Users with

access to the Platform, and, acting independently or jointly with others, organizes

and/or carries out the processing of Users' Personal Data in connection with its use of

the Services, including by determining the purposes and means of such processing.

Customer may also act as a Content Provider, which uploads, submits, publishes, or

otherwise provides course content, materials, or information to the Platform, and who

may also provide personal data of its own users for the purposes of account creation,

course enrollment, or analytics, and who may access analytics or reports about those

users via the Platform.

• "Mobile App" refers to 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" includes any information relating to an identified or identifiable

natural person , and includes information about the User, provided by the User to the

Company and/or information automatically collected by the Company and/or third

parties, to the extent such information constitutes personal data under the Law.

Personal Data does not include information that has been irreversibly anonymized.

• "Platform" refers to 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 available as a Website and a Mobile App.

• "Policy" means this Privacy Policy governing the Platform, including any

amendments, modifications, updates or changes made from time to time.

• "Third Party" means any person or entity other than EvolveApp Inc., the User, or an

authorized processor/service provider.

• "User" refers to any natural person who has accessed and uses the Platform via the

Website or Mobile App , and who has agreed to comply with the applicable terms and

rules governing the use of the Platform. Unless expressly stated otherwise, references

to "you" or "your" in this Policy mean the User as defined herein.

• "User Agreement" means the agreement concluded between the Company and the

User regarding the terms, rules, and features of the User’s use of the Platform, as

published on https://app.evolveplatform.ai/en/privacypolicy. The User joins such an

agreement and has no right to make and/or demand any changes or additions.

"Website" means any web page or collection of web pages, 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

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such web pages, as well as any related digital or electronic services offered by

EvolveApp Inc through the Website, including all content, functionalities, services,

and software provided through it.

2. SCOPE OF THE POLICY

This Policy is used and applicable exclusively to Personal Data received from Users in

connection with their use of the Platform and collected through the Platform, our Website,

Mobile App, customer support channels, email communications, and related services.

The provisions of this Policy are intended to:

1. Define the types and categories of Personal Data collected, methods and purposes of

the use (processing) of such Personal Data, as well as the sources from which such

Personal Data is obtained.

2. Define the User’s rights regarding the privacy and confidentiality of their Personal

Data.

3. Identify the individuals and entities responsible for the processing and storage of

Personal Data, as well as Third Parties to whom such Personal Data may be disclosed,

in whole or in part.

This Policy does not apply to Third Party websites, applications, or services that may be

linked from the Platform and are governed by their own privacy terms.

By accessing or using the Website and/or installing the Mobile App on a smartphone, tablet,

watch, or other mobile device, the User acknowledges receipt of this Policy and consents to

the Company collecting, processing, retaining, and storing Personal Data under the terms and

conditions provided by this Policy.

The Company will process Personal Data only where it has a valid lawful basis under the

Applicable Law, which may include consent, performance of a contract, compliance with

legal obligations, and legitimate interests, as applicable to the relevant processing activity.

User Rights for Data Protection

Subject to the User’s location and Applicable Law, the User the User may have the following

rights:

1. Right to be informed: You have the right to receive information about the processing

of your Personal Data, including the basis and purposes of such processing, methods

used, information about individuals who have access to your Personal Data or to whom

such Personal Data may be disclosed based on the agreement or pursuant to the

Applicable Law, your privacy rights, as well as information regarding the identity and

contact details of the data controller and, where applicable, its representatives, data

protection officer, and categories of Third Parties or recipients involved in the

processing of Personal Data.

2. Right of access: You may request a copy of the Personal Data we hold about you and

information about how we process it..

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3. Right to rectification: You may request that we correct or update inaccurate or

incomplete Personal Data.

4. Right to erasure: You may request that we delete your Personal Data where applicable

and permitted by the Applicable Law.

5. Right to restrict processing: You may request that we limit the processing of your

Personal Data in certain circumstances.

6. Right to data portability: Where applicable, you may request a copy of your Personal

Data in a structured, commonly used, and machine-readable format or request that it be

transferred to another service provider where technically feasible.

7. Right to object: You can object to certain types of processing, including processing for

direct marketing and, in some cases, processing based on our legitimate interests.

8. Right to withdraw consent: If we process your Personal Data based on your consent,

you may withdraw that consent at any time without affecting the lawfulness of

processing carried out before withdrawal.

9. Right to lodge a complaint: You have the right to file a complaint with competent

local data protection authority, privacy regulator, or other competent supervisory

authority if you believe your privacy rights have been violated or seek judicial remedy

where permitted by Applicable Law Company.

You may have other rights in the field of data protection provided by the Applicable

Law or this Policy.

Company's Role in Processing Personal Data

Depending on the circumstances in which Personal Data is processed, the Company may act

either as a Data Controller (or Business) or as a Data Processor (or Service Provider).

(1) When the Company acts as a Controller (or Business)

The Company acts as a Data Controller where it alone determines the purposes and

means of processing Personal Data. In these circumstances, the Company determines

why and how Personal Data is processed and processes such Personal Data for its own

legitimate business purposes, including to provide and improve the Services, administer

user accounts, communicate with users, provide customer support, process payments,

maintain the security and integrity of the Services, comply with applicable legal

obligations, enforce its agreements, and pursue other purposes described in this Privacy

Policy.

(2) When the Company acts as a Data Processor (or Service Provider)

Where a Customer uploads, submits, or otherwise provides Personal Data to the

Company for processing on its behalf, and determines the purposes for which such

Personal Data is processed, the Company acts solely as a Data Processor. In such cases,

the Customer remains the Data Controller, and the Company processes Personal Data

only on the Customer's demands and instructions.

When acting as a Processor or Service Provider, the Company does not determine the

purposes for which the Personal Data is processed except as necessary to provide the

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Services, comply with Applicable Law, or as otherwise permitted under the applicable

data processing agreement.

Customers are responsible for ensuring that they have an appropriate legal basis for

collecting, using, and disclosing Personal Data to the Company and for providing any

notices required by applicable data protection laws.

This Privacy Policy applies to all Personal Data processed by the Company, regardless of

whether the Company acts as a Controller, Business, Processor, or Service Provider, except

where a separate privacy notice or agreement governs a particular processing activity.

3. COLLECTED DATA

Information automatically collected

In connection with the use of the Platform, the Company may automatically collect and

process the following information:

1. Traffic information, the potential number of clicks made, logs and other data

concerning the User’s activities .

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, and similar technical information.

3. Other similar technical data.

The Company may process such information to operate the Platform, improve service quality,

analyse performance, remedy technical errors, ensure information security, prevent fraud and

prevent violations of the Platform’s terms of use.

If this information directly or indirectly identifies the User, it shall be processed as Personal

Data in accordance with the laws of the Russian Federation.

Information provided by the Users

The User may provide the Company with the following categories of User’s Personal Data:

1. Full name.

2. A photograph depicting the User if the User uploads it to the User’s profile or uses it

for identification purposes.

3. Email address and / or phone number.

4. Information obtained through third-party authentication services used by the User to

access the Platform, including: Facebook, Google, Slack, and Microsoft. This may

include the User's account identifier and other information made available to the

Company by the relevant third-party service in accordance with the User's privacy

settings and the authorization granted by the User. The Company processes such

information only for purposes related to account creation, authentication, security, and

operation of the Platform.

5. Data contained in the User's personal account (profile), as well as other activity

associated with the User’s personal account (profile).

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6. Data concerning all content published by the User on the Platform, including, but not

limited to, the results of completed assignments, answers to questions, conversations

with the AI simulator, comments, grades, reviews, published reports, videos and

photographs, likes and/or any other forms of activity or content creation available to the

User on the Platform.

7. Other data voluntarily provided by the User when using the Platform.

If the User uploads images, videos, audio files or other materials containing the Personal Data

of the User or third parties to the Platform, the Company shall process such materials to the

extent necessary to provide the Platform’s functionality.

The User and the Customer agree to promptly update, verify, or correct such Personal Data as

necessary. The Company may reasonably rely on the accuracy and completeness of the

Personal Data provided and will treat such Personal Data as current unless and until it

receives notice, or otherwise becomes aware, that such Personal Data is inaccurate,

incomplete, or requires updating. Upon becoming aware that Personal Data is inaccurate or

incomplete, the Company will take such steps as are required under Applicable Law,

including, where appropriate, rectifying or erasing inaccurate Personal Data without undue

delay.

4. PURPOSE OF PERSONAL DATA COLLECTION AND PROCESSING

We collect and process Personal Data for the following purposes:

1. To operate and maintain the learning management system (LMS), including User

account administration, enrollment in courses, providing access to the Platform and its

functionality including access to course materials, tracking progress, issuing

certifications, recording and storing learning status, assessment results, grades,

achievements, learning history, and other educational records and statistics, and

generating internal usage and performance reports, to the extent necessary for those

purposes and on the Applicable Lawful basis under Applicable Law.

2. To provide a personalized and adaptive learning experience, including analyzing User's

learning activities, preferences and interactions with the Platform to recommend

relevant educational content, personalize course recommendations, and tailor learning

pathways.

3. To provide the Customer that gave the User access to the Platform with analytics and

reports concerning the learning process, within the scope of the access rights granted

and to the extent necessary to perform contractual obligations owed to the Customer.

4. To improve the operation, security, and functionality of the Platform, including

monitoring performance, preventing unauthorized access, troubleshooting,

maintenance, detecting, investigating, and responding to security incidents, protecting

Personal Data, and providing technical support.

5. To evaluate and improve the quality, effectiveness and performance of the Platform, its

educational content, services, and internal business processes, including through the

analysis of usage data and User feedback.

6. To communicate with Users regarding their accounts, enrollment, learning activities,

customer support requests, updates to the Platform, changes to this Policy or other

applicable terms, and other administrative or service-related notices.

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7. To comply with Applicable Laws, regulations, legal processes, court orders,

governmental requests, and contractual obligations, and to establish, exercise, or defend

legal claims where necessary.

8. To generate statistical analyses, research, and reports relating to the use and

performance of the Platform. Where reasonably possible and appropriate, such analyses

and reports will be based on aggregated or anonymized data that does not identify

individual Users

9. To provide Customers that grant Users access to the Platform with analytics, reports,

and other information regarding Users' learning activities, progress, participation, and

educational outcomes, to the extent authorized by the Customer, necessary for the

performance of the applicable agreement, or otherwise permitted under Applicable

Law.

10. To perform the Company's contractual obligations to Users and Customers in

connection with the provision of the Platform and the Services.

11. To process Personal Data for any other specific purpose that has been clearly

communicated to the User at or before the time of collection, where such processing is

based on the User's consent or another lawful basis under applicable data protection

laws.

Principles relating to processing of personal data

The processing of Personal Data is carried out based on the principles:

1. Personal Data is processed lawfully, fairly, and in a transparent manner in relation to

the Data Subject.

2. Personal Data are collected for specified, explicit, and legitimate purposes and are not

further processed in a manner incompatible with those purposes.

3. Personal Data are adequate, relevant, and limited to what is necessary in relation to the

purposes for which they are processed.

4. Personal Data are accurate and, where necessary, kept up to date. Every reasonable step

is taken to ensure that inaccurate Personal Data, having regard to the purposes for

which they are processed, are erased or rectified without delay.

5. Personal Data is kept in a form which permits identification of Data Subjects for no

longer than is necessary for the purposes for which the Personal Data are processed.

6. Personal Data are processed in a manner that ensures appropriate security, including

protection against unauthorized or unlawful processing and against accidental loss,

destruction, or damage, using appropriate technical and organizational measures.

Conditions for Processing Personal Data

We process Personal Data only where we have a lawful basis to do so under Applicable Law.

Depending on the circumstances, we may process Personal Data on one or more of the

following legal bases:

1. The need to provide the User with access to the Platform and its functionality,

including organizing the learning process, completing educational materials, tests and

assessments, and recording learning outcomes.

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2. The performance of the Company’s obligations to the Customer that provided the

User with access to the Platform under the applicable contracts and agreements.

3. The processing of Personal Data provided by the Customer for the purposes of

administering Users, managing corporate learning, and producing learning reports and

analytics.

4. Ensuring the proper and secure operation of the Platform, including User

authentication, access management, technical support, service monitoring and error

correction.

5. Ensuring the information security of the Platform, preventing unauthorized access,

and identifying, analysing and investigating information-security incidents.

6. Complying with Applicable Laws and regulations, lawful requests from competent

authorities and the Company’s other legal obligations.

7. Pursuing other lawful purposes for processing Personal Data provided for by this

Policy, agreements with the Organization and Applicable Law.

8. Based on the User’s freely given, specific, informed, and unambiguous consent. The

User may withdraw consent at any time without affecting the lawfulness of processing

based on consent before its withdrawal;

Where Personal Data has been anonymized so that the User cannot be identified directly or

indirectly, such data may subsequently be used and disclosed to third parties and shall no

longer be subject to this Policy. The Company may use such data for statistical, analytical

and other lawful purposes without obtaining additional consent from the Personal Data

subject, unless otherwise provided for by the Applicable Law.

The Company shall take all necessary legal, organizational and technical measures to

protect the confidentiality of the Personal Data received, except where the User has made

such data publicly available.

Personal Data shall be processed both by automated means and without the use of automated

means.

5. THIRD PARTY ACCESS TO PERSONAL DATA

The Company uses Google Analytics to understand how Users interact with the Platform,

improve Platform functionality and performance, enhance User experience, and evaluate the

effectiveness of content, services, and marketing activities.

Google Analytics may collect and process certain information about Users' interactions with

the Platform, including:

1. Information about site visits to the Platform, including frequency, duration, and

navigation patterns.

2. Information about interactions with the Platform features, content and services.

3. Information regarding the popularity and performance of Platform content.

4. Technical information, including IP address, browser type, device information,

operating system, and usage data.

5. Approximate location information derived from technical data, such as IP address of

the User.

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The Company may process such data for the purposes specified in this Policy, provided that a

legal basis exists under the Applicable Laws, including the User’s consent where required..

Google Analytics processes information in accordance with Google's applicable privacy

terms and policies available at: https://policies.google.com/privacy .

Disclosure of Personal Data to Third Parties

The Company shall not disclose Personal Data to third parties except where such transfer

is necessary to operate the Platform, perform obligations owed to the Customer and/or the

User, or comply with Applicable Law

The Company may disclose Personal Data to:

1. The Company’s service providers and contractors involved in operating the Platform,

including providers of cloud infrastructure, data-storage services, technical support,

monitoring, communication services and other technological solutions used to provide

the services.

2. Services and technology providers used to process data and provide the Platform’s

functionality, including automation, analytics and educational-content processing

functions.

3. Its affiliates, branches, and representatives, both within the territory of the United States

of America and in other countries, or to other legal entities operating under the

"Evolve" brand that participate in providing the Services, provided that such disclosure

is necessary for the purposes set out in this Policy and is carried out in accordance with

Applicable Law.

4. Successors of the Company who have arisen as a result of its liquidation,

reorganization, or bankruptcy and who have acquired exclusive rights to the Platform,

provided that such successor continues to process Personal Data in accordance with this

Policy and Applicable Law.

5. Third parties exclusively for the purposes of providing the User with certain content or

access to it.

6. Third parties who act as Customers of the Company by preparing certain content and

sharing data about their Users, as explicitly stated in the description of each course.

7. Third parties who act as Data Controllers using the Platform as a Learning Management

System (LMS).

The Company discloses Personal Data only if:

1. such disclosure is necessary for the applicable purpose, and a valid lawful basis exists

under Applicable Law;

2. the Company has taken reasonable steps to ensure that the recipient provides an

adequate level of protection for Personal Data, where required by Applicable Law;

3. the disclosure is otherwise permitted under this Policy, the User has been informed of

such disclosure, and, where required by Applicable Law, the User has provided

consent.

When providing particular functions of the Platform, the Company may engage providers of

specialized technology services, including artificial-intelligence services, communication

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services, multimedia-content generation services and other cloud services. When such

functions are used, the relevant providers may receive only the data necessary to provide the

applicable service.

The Company shall take the necessary legal, organizational and technical measures to ensure

that the service providers and contractors engaged by the Company provide an appropriate

level of Personal Data protection and use such data solely for the processing purposes

entrusted to them.

Cross-Border Transfers of Personal Data

Depending on the Platform configuration and the functional modules connected to it, the

Company may engage service providers whose infrastructure is located outside the country of

the Customer.

In such cases, Personal Data shall be transferred only to the extent necessary to provide

the relevant Platform functionality, perform obligations owed to the Customer and operate

particular services.

The use of particular Platform functions, including artificial-intelligence functions, the

delivery of service notifications and other integrations with third-party services, may

involve the transfer of data to the relevant service providers.

Personal Data Provided by Customers

1. In some cases, Customers may upload or otherwise provide to the Platform personal

data of their own users (such as employees, partners, students, or other learners) in

order to enable those users to access courses, track progress, and receive reports or

certifications.

2. For the personal data of users provided to the Platform by Customers, to the extent that

the Company processes such personal data on behalf of the respective Customer for the

provision of the Platform, the Company processes such data on behalf of the Company

acts as a data processor, and the Customer acts as the data controller.

3. Customers are solely responsible for ensuring that they have an appropriate legal basis

under Applicable Law for the collection and provision of such personal data to the

Platform.

6. PROCEDURE FOR SUBMITTING COMPLAINTS AND REQUESTS TO THE

COMPANY

Request to Object to or Restrict Processing Personal Data

Each User has the right to object to the processing of their Personal Data and/or request

restriction of processing and/or storage of their Personal Data, where provided by Applicable

Laws. Such an objection can be expressed as follows:

• The request must be sent to the Customer’s Platform administrator or the Company at

the following address: support@evolveplatform.ai.

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Request for Information about Personal Data and Exercise of Data Subject Rights

If the User has questions related to the application or use of this Policy, the order and/or

method of processing Personal Data, or wishes to exercise their rights under Applicable

Laws, the User may ask such a question as follows:

• The request must be sent to the Customer’s Platform administrator or the Company at

the following address: support@evolveplatform.ai.

The Company may request additional information to verify the identity of the User and will

respond to requests within the timeframe required by Applicable Law.

Changes (updates, additions, corrections) or Deletion of Personal Data

The User has the right to request access to, correction of, updating, or deletion of their

Personal Data in accordance with Applicable Law.

The User may update certain Personal Data through their account settings or by contacting

the Company. The User may also request deletion of their Personal Data, and the Company

will consider and process such requests in accordance with applicable legal requirements.

The Company may refuse or limit a request for deletion only where permitted by Applicable

Law, including where retention of Personal Data is necessary to comply with a legal

obligation, establish, exercise, or defend legal claims, prevent fraud or misuse, or for other

legally recognized purposes.

Upon agreement with the Customer, the Company reserves the right, at any time, to suspend

or delete the User’s account (personal account/profile) and delete Personal Data relating to

such User where permitted by Applicable Law, if the User has violated the terms of this

Policy and/or the User Agreement.

The Company may suspend, restrict, or delete a User account and associated Personal Data

where necessary due to a violation of applicable terms, policies, or legal requirements,

subject to applicable data protection obligations.

Where a User account is deleted, the Company will delete or anonymize Personal Data

associated with the account unless retention is required or permitted by Applicable Law.

Certain User-generated content or records may be retained where necessary for legitimate

purposes, including legal compliance, security, dispute resolution, or protection of the rights

of the Company or other Users.

7. PERSONAL DATA RETENTION PERIOD AND PROCEDURE

Personal Data is stored only for as long as necessary to fulfill the purposes for which it was

collected and processed, unless a longer retention period is required or permitted by

Applicable Law. The retention period is determined based on the nature of the Personal Data,

the purposes of processing, applicable legal and regulatory requirements, and the need to

establish, exercise, or defend legal claims. Upon expiration of the applicable retention period,

or following deletion of a User’s account, the Company will delete, anonymize, or securely

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dispose of Personal Data, except where retention is necessary for compliance with legal

obligations, resolution of disputes, prevention of fraud or misuse, or enforcement of

agreements. The storage and hosting of Personal Data are entrusted to Amazon.com, Inc.

(“Service Provider”), which processes Personal Data on behalf of the Company and

maintains the confidentiality and security of such data through appropriate technical and

organizational measures in accordance with Applicable Laws and contractual obligations.

8. PERSONAL DATA PROTECTION PROCEDURE

Protecting the confidentiality of Personal Data is a paramount and important task for the

Company. The Company adheres to all required international standards, rules, and

recommendations for the protection of Personal Data.

The Company has implemented a number of technical and organizational methods aimed at

protecting Personal Data from disclosure or unauthorized access by third parties.

9. FINAL PROVISIONS

Availability of the Policy Text for Review

The Company is committed to regularly reviewing and updating its data protection practices

to ensure ongoing compliance with Applicable Laws and best practices in the field of data

privacy.

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 August 1, 2026.

Amendment and Addition to the Policy

This Policy may be updated from time to time to reflect changes in the Company's data

processing practices, the Services, or Applicable Laws. Unless otherwise required by the

Law, any changes will become effective upon posting the updated Policy on the Platform.

Company

If this Policy is updated, the effective date will be revised accordingly. Where required by the

Law, the Company will provide additional notice, such as by email or through a notice within

the Platform. If any changes materially affect the processing of Users' personal data or

otherwise have a significant impact on Users, advance notice will be provided where required

by Applicable Law.

Users are encouraged to review this Policy periodically to stay informed of any updates.

Continued use of the Platform after the updated Policy becomes effective constitutes

acceptance of the revised Policy.

If the User does not agree with this Policy, the User should discontinue use of the Platform.

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Applicable Legislation

This Policy is developed and maintained in accordance with the applicable data protection

and privacy laws, including, where applicable, the laws of the United States and its individual

states, as well as the General Data Protection Regulation (GDPR), and the United Kingdom

General Data Protection Regulation (UK GDPR) and related data protection legislation.

Risk of Disclosure

While the Company takes appropriate technical and organisational measures to protect

Personal Data, the User acknowledges that no method of transmission over the Internet or

method of electronic storage is completely secure. The Company shall not be responsible for

any unauthorized access to Personal Data caused by circumstances beyond its reasonable

control, provided that the Company has implemented appropriate safeguards in accordance

with Applicable Law.