PRIVACY AND COOKIES POLICY – EVOLLU

Last updated: September 2020

SENSING EVOLUTION, LDA (ahead, EVOLLU), headquartered in Rua Comissão Iniciativa, 2ª, piso 7, Edifício Torre Brasil, 2410-098 Leiria, with Tax Registration Number 513758747, is the owner of the domain https://www.evollu.com, where is housed its WEBSITE.

EVOLLU IS FOCUSED ON PROTECTING THE PRIVACY AND PERSONAL DATA OF ITS CUSTOMERS AND USERS OF THE WEBSITE, WHEREFORE, IT HAS PREPARED AND ADOPTED THE PRESENT POLICY AND THE PRACTICES DESCRIBED HEREIN. THIS PRIVACY AND COOKIES POLICY EXPLAINS HOW WE USE YOUR PERSONAL DATA, BY WHICH WE ADVISE YOUR READING SO AS TO KNOW THE CONDITIONS UNDER WHICH YOUR PERSONAL DATA ARE COLLECTED AND FURTHER PROCESSED.

  1. WHAT IS THIS POLICY ABOUT?
    1. This Privacy and Cookies Policy explains how we collect and process the personal data that are necessary for the provision of services that are available trough the WEBSITE.
    2. Examples of these services are are hearing screening and commercialization of EVOLLU products.
    3. The objective is for these services to be provided in an expeditious and undisturbed way, describing the practices adopted for this purpose.
  2. WHAT ARE PERSONAL DATA?
    1. Personal data is any information relating to a person that identifies that person or makes it identifiable, regardless of the nature or support of the information, including the sound and image of that person.
    2. Examples of personal data we collect are: IP address, e-mail and name.
    3. The term “identifiable” refers to a person who can be identified, directly or indirectly, in particular by reference to an identification number or other specific elements of his or hers physical, physiological, psychic, economic, cultural or social identity.
  3. HOW DO WE USE YOUR PERSONAL DATA?
    1. EVOLLU will use the personal data you provide us for the following purposes:
      1. To communicate your personal data to EVOLLU partners, better identified in point 4, after completing the form at the end of the EVOLLU Questionnaire available on the WEBSITE, so that they can get in direct contact with you;
      2. To create a reserved area, if you are a natural person;
      3. To analyse and respond to your messages, customer support and requests for information;
      4. For operations and management of the WEBSITE;
      5. To keep record of your contact details;
      6. For commercial purposes, such as data analysis, audits;
      7. For fraud prevention and security of information systems;
      8. For the expansion of EVOLLU´s commercial activities.
    2. These data processing operations are an essential tool for your satisfaction and for the activity of EVOLLU and are carried out according to the applicable legislation and the best practices.
    3. Your personal data will not be reused for other purposes not previously identified or that have nothing to do with those purposes for which they were initially collected.
  4. PARTNER’s IDENTIFICATION:
    1. EVOLLU will communicate your personal data to its partners, if the user gives his consent for this purpose in the form which appears after completing the EVOLLU questionnaire.
    2. The partners above mentioned, are the following:
      1. Hidden Hearing, Lda., com sede na Rua Vítor Camara, Edifício D. Maria 1 – Piso 1-Ala B, Quinta da Fonte – 2770-229 Paço de Arcos e NIPC 503295450.
  5. WHAT ARE THE LEGAL BASIS FOR OUR PROCESSING OF PERSONAL DATA?
    1. The personal data that EVOLLU processes has specific legal basis according to the purposes for which they are intended.
    2. In the following table you can see the legal basis for processing operations regarding the above mentioned purposes:
    3. PURPOSES

      LEGAL BASIS

      To communicate your personal data to EVOLLU partners, better identified in point 4, after completing the form at the end of the EVOLLU Questionnaire available on the WEBSITE, so that they can get in direct contact with you.

      Consent for this specific purpose.

      To create a reserved area, if you are a natural person.

      Contractual obligation.

      To analyse and respond to your messages, customer support and requests for information.

      Consent for this specific purpose.

      For operations and management of the WEBSITE.

      Consent for this specific purpose (cookies);

      Legitimate interests pursued by EVOLLU;

      To keep record of your contact details.

      Consent for this specific purpose.

      For commercial purposes, such as data analysis, audits.

      Consent for this specific purpose Consent for this specific purpose (cookies);

      Legitimate interests pursued by EVOLLU;

      For fraud prevention and security of information systems.

      Legitimate interests pursued by EVOLLU;

      For the expansion of EVOLLU´s commercial activities.

      Legitimate interests pursued by EVOLLU;

  6. WHAT PERSONAL DATA WE COLLECT?
    1. The personal data that EVOLLU collects and processes are only those which are necessary and suitable for the abovementioned purposes.
    2. EVOLLU will collect and process the following personal data:
    3. PURPOSE

      DATA

      To communicate your personal data to EVOLLU partners, better identified in point 4, after completing the form at the end of the EVOLLU Questionnaire available on the WEBSITE, so that they can get in direct contact with you.

      Name, contact, location, age and gender.

      To create a reserved area, if you are a natural person.

      Email, Name.

      To analyse and respond to your messages, customer support and requests for information.

      Email, Name.

      For operations and management of the WEBSITE.

      Cookies data. 

      To keep record of your contact details.

      Email; Name.

      For commercial purposes, such as data analysis, audits.

      Cookies data.

      For fraud prevention and security of information systems.

      IP adress; Cookies data.

      For the expansion of EVOLLU´s commercial activities.

      Email; Name.

  7. HOW DO WE COLLECT YOUR PERSONAL DATA?
    1. We will collect your personal data through the forms on the WEBSITE, but also through the WEBSITE and the communication that it makes with your device and e-mail messages that you may send us.
    2. Your personal data is collected through your equipment as follows:
      1. Through your browser;
      2. Through cookies;
      3. Through pixel tags and other similar technologies;
      4. IP adress;
      5. Through your user data.
    3. EVOLLU is committed to process your data lawfully and legally.
    4. EVOLLU’s services are not intended for minors and no personal details of minors are or will being processed intentionally.
  8. WHAT ARE COOKIES?
    1. Cookies are small information files that help you identify your browser and can store information, for example, user settings and preferences. 
    2. With the exception of cookies specifically required for the performance of the website, the storage of other cookies will always depend on the acceptance and consent of the User, and this consent may be withdrawn at any time through specific browser tools.
  9. HOW DO WE USE COOKIES?
    1. We use cookies to display your preferences, such as:
      1. if you have agreed (or not) to our use of cookies on this WEBSITE;
      2. to identify you as a returning user;
      3. to remember your users’ custom preferences.
    2. Cookies allow us to collect, anonymously, statistics regarding the videos you have viewed on the WEBSITE.
  10. THIRD PARTY’S COOKIES
    1. Some cookies may be stored by third parties service providers, not just EVOLLU.
    2. Although EVOLLU seeks to only use providers which are able to provide sufficient guarantees regarding the appropriate technical and organisational measures in such a manner that processing will meet the requirements of the data protection legislation, you understand that EVOLLU is not responsible for the content and accuracy of a third party’s privacy and cookies policies.
    3. On Point 13 you will find a description of all the cookies we use, including cookies hosted by third parties.
  11. WHAT ARE COOKIES FOR?
    1. EVOLLU will store cookies on your equipment in order to personalize and make your navigation as easy as possible, but also for problem solving reasons, statistics, quality assurance, and to monitor system security.
    2. You may delete or block these cookies, but if you do it some features on this website may not work as intended.
    3. These cookies are not used for any purposes other than those described herein. 
  12. TYPE OF COOKIES.
    1. Cookies on our WEBSITE are used for a variety of different purposes, but, altogether, their use breaks down into the following categories:
      1. Strictly Necessary Cookies: These are essential for the provision of the WEBSITE and for all services requested, but do not perform any additional or secondary functions.;
      2. Analytical/Performance Cookies: These cookies provide statistical information about the use of the WEBSITE, that is, the analysis of the web.;
      3. Targeting Cookies: These cookies are used to create profiles or personalize content.
  13. COOKIES WE USE.
    1. The following table explains the way in which we use cookies on this WEBSITE. 
    2. Performance Cookies

      Host

      Name

      Description

      Life Span

      First Party

      (“evollu.com”)

      _gid

      Cookie generated by Google Analytics and used to distinguish users.

      24 hours

      First Party

      (“evollu.com”)

      _ga

      Cookie generated by Google Analytics and used to distinguish users.

      2 years

      First Party

      (“www.evollu.com”)

      pll_language

      Cookie generated by Polylang, which indicates in which language the website is.

      1 yeaar

      Targeting Cookies/ Advertising

      Host

      Name

      Description

      Life Span

      First Party

      (“evollu.com”)

      _gat_gtag_xxxxxxxxxxxxxxxxxxxxxxxxxxx

      Cookie gerado pelo Google Analytics, no entanto não existe muita informação sobre este cookie.

      Session

  14. CONTROL AND COOKIES’ MANAGEMENT.
    1. You can control and/or delete cookies anytime you wish. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from storing cookies. 
    2. However, in order to manage your cookies settings, you may have to manually adjust some preferences each time you visit a site. You should notice that without cookies, some services and functionalities of websites may not work.
    3. As an additional guarantee, you may, at any time, disable the cookies by configuring your browser according to the following instructions:
      1. To Google Chrome browsers, in http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647;
      2. To Microsoft Explorer browsers, in https://support.microsoft.com/pt-pt/help/17442/windows-internet-explorer-delete-manage-cookies;
      3. To Microsoft Edge browsers, in https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy;
      4. To Mozilla Firefox browsers, in https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences;
      5. To Apple Safari browsers, in http://support.apple.com/kb/ph5042.
  15. HOW DO WE PROTECT YOUR PERSONAL DATA?
    1. Your personal data are kept safe through the adoption of various security measures with technical and organizational nature that assure that only employees who need to access data, have access to the data and to the processes related with it, according to rules created for that purpose.
    2. In order to protect your personal data, we only use data center providers who provide us with adequate and documented security measures, namely that your personal data are stored in servers that are kept in controlled environments with limited access.
    3. Similarly, when browsing the WEBSITE, we protect your data through the use of encryption, such as Transport Layer Security (TLS), and your password is stored using an unidirectional hash, in other words, it cannot be retrieved (or disclosed) by anyone, including EVOLLU, and can only be redefined.
    4. Although we take all necessary precautions, we deem appropriate to protect the personal data you provide and we collect, one must be aware that no security system is impenetrable.
    5. Therefore, you should take certain precautions, such as keeping your password secret and not disclosing it to anyone; If you think your password has been misused, you should let us know right away; You should also be careful when starting and ending your session every time the browser closes.
  16. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
    1. Your personal data will be kept for the time required for the purposes for which they are intended, as set forth in this Privacy Policy, as follows:
    2. PURPOSE

      PERIOD

      To communicate your personal data to EVOLLU partners, better identified in point 4, after completing the form at the end of the EVOLLU Questionnaire available on the WEBSITE, so that they can get in direct contact with you.

      2 years

      To create a reserved area, if you are a natural person.

      Until one year after the last access to the reserved área.

      To analyse and respond to your messages, customer support and requests for information.

      1 year

      For operations and management of the WEBSITE.

      2 years

      To keep record of your contact details.

      1 year

      For commercial purposes, such as data analysis, audits.

      2 years

      For fraud prevention and security of information systems.

      2 years

      For the expansion of EVOLLU´s commercial activities.

      2 years

    3. If any specific or mandatory period of time is required by law, the data’s retention period will be such mandatory period. In all other cases, the personal data will be kept at most during the time indicated above, which EVOLLU deems as sufficient to fulfill its purposes.
    4. At the end of the storage period, all collected personal data will be deleted.
  17. HOW YOU CAN YOU EXERCISE YOUR RIGHTS:
    1. Before we explain how you can exercise your rights, you should know what they are. Thus, the law grants you the right to request us the exercise of the following rights:
      1. Access: the right to confirm whether your personal data is being processed or not, and, if so, the right to access your personal data;
      2. Rectification: the right to rectify any inaccuracy regarding your personal data  and to complete personal data that is incomplete;
      3. Erasure: the right to erase your personal data when one of the grounds listed in the legislation is applicable;
      4. Restriction of processing: the right to limit data processing, if one of grounds listed in the legislation is applicable;
      5. Objection: the right to object, at any time, to the processing of your personal data;
      6. Data portability: the right to receive your personal data, which you provided, in a structured, commonly used and machine-readable format.
    2. You also have the right to lodge a complaint with a supervisory authority (National Data Protection Commission at www.cnpd.pt).
    3. For the purpose of exercising the rights abovementioned, you should contact EVOLLU by sending an email to info@evollu.com.
    4. If you ask us to delete some or all of your personal data, some of the requested services may not be provided to you and EVOLLU will keep the necessary personal data to fulfill its legal obligations.
  18. WHEN DO WE COMMUNICATE DATA TO THIRD PARTIES?
    1. EVOLLU may use third parties to provide certain services, such as maintenance, technical support, marketing, billing or payment management, which may have access to some personal data, in particular, data required for contractual purposes. 
    2. EVOLLU ensures that the entities that have access to the data are credible and offer high guarantees of protection, and that data will never be transmitted beyond what is necessary to provide for the contracted service, nevertheless EVOLLU remains responsible for the personal data made available. 
    3. EVOLLU may also communicate its data to:
      1. companies in its business group with whom EVOLLU has commercial partnerships to create and offer benefits; or to
      2. other partners outside its business group. However, we will only make such communication without your authorization.
    4. EVOLLU may also transmit data to third parties in the context of investigations, inquiries and judical and / or administrative proceedings or of similar nature, provided that it is duly ordered by a court. 
  19. THIRD PARTY WEBSITES.
    1. The WEBSITE may contain links to other websites which may collect and process your personal data, and this processing is the sole responsibility of the owners of these websites, and EVOLLU does not take any responsibility for its policies and / or practices.
  20. DATA TRANSFERS TO OUTSIDE THE EUROPEAN UNION.
    1. If data transfers to non-EU countries occur, EVOLLU will comply with the law, in particular regarding to the data protection adequacy of the country to where the personal data will be transferred to, and the requirements applicable to such transfers. Therefore, personal data will not be transferred to jurisdictions that do not offer security and protection assurances.
  21. MINORS.
    1. The WEBSITE is not intended for minors under the age of 16, thus, we request that minors do not provide us with personal information through the WEBSITE, application, social media and/or emails.
  22. SENSITIVE PERSONAL DATA.
    1. EVOLLU asks you not to send us any sensitive data, in other words, personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union association, genetic information, biometric information, health or data relating to a natural person´s sexual life or sexual orientation.
    2. If you still send or make known to us these categories of personal data, these items will be deleted. 
  23. CHANGES TO PRIVACY POLICY.
    1. EVOLLU reserves the right to readjust or change this Privacy Policy at any time, as these changes are advertised.
  24. OUR CONTACT DETAILS.
    1. If you have any questions or concerns regarding this Privacy Policy, please contact us by writing us an email to info@evollu.com.
  25. LAST VERSION.

    27 september, 2020. Leiria (Portugal)