Evollu Privacy Policy

Last updated: June 2017

Framework

The Portuguese legal regime regarding the protection of personal data is contained in Law 67/98 of October 26th and legislation that complements or implements this law. This legislation applies to any processing of information that directly or indirectly refers to an identified or identifiable natural person (the data owner).

In turn, the processing of personal data includes, but is not limited to, registration, collection, consultation, use, adaptation, alteration, storage, destruction of data, among other operations.

Sensing Evolution, SA (hereinafter referred to as “Evollu”) recognizes that privacy is important for the persons with whom it relates, in the scope of its commercial activity and in the provision of its services, whether these persons, customers, potential customers, suppliers or others (hereinafter referred to as “data subject”).

Scope

The Privacy Policy applies to the processing of personal data that Evollu (the controller), hereinafter referred to as Evollu, performs in the course of its business activities and its provision of services (hereinafter referred to as “services”).

Evollu treats personal data in accordance with current Portuguese legislation and informs the data owner about how it collects, uses, discloses, transfers and stores, that is, in general terms, about how it handles personal information of the Holder of the data. This Privacy Policy provides an overview of Evollu practices regarding the processing of personal data. This policy applies to any processing of personal data that Evollu carries out in the course of its commercial activities, as well as in the rendering of its services.

About Privacy Policy

It is important that the data subject reads the Privacy Policy carefully, since whenever you use the Evollu services or if you interact with Evollu, and if this proves the need for Evollu to treat your personal data, the data owner agrees with Practices described in the Privacy Policy.

If the data subject does not agree with the practices described in the Privacy Policy in the context of the provision of services, you should not use those services.

It is important that the data subject periodically checks the updates made to the Privacy Policy. In case of update, it will be placed from the date of the last update in the Privacy Policy itself. By accessing or using Evollu services after an upgrade or by posting a notice, you agree to the new practices identified. The most up-to-date version of the Privacy Policy is available here. You can check the “effective date” to confirm the date of the last update of the Privacy Policy.

The Evollu Privacy Policy applies to the processing of your personal data and your responsibility for certain specific services (for example, Evollu websites and online applications,
regardless of whether you use a computer, mobile phone, tablet, TV or Device to access those services).

Data Collected

Evollu collects and handles various types of data, including:

• Data that the data owner provides directly.
• Data that you collect and deal with as part of the relationship with the data owner.
• Data you get from other sources.

Evollu may also require your consent to collect data not described in the Privacy Policy. Therefore, specific privacy supplements that include additional information about Evollu practices with respect to certain services may also apply. Such supplements will be applicable depending on the use that the data subject makes of the respective services.

“Personal data” means any information capable of identifying a natural person. Evollu does not collect “sensitive personal data”, including data on racial or ethnic origin, religion, political opinion, health status or sexual orientation.

Data that owner provides directly

The data owner may provide data directly, whether in the contractual relationship, for contract execution, for the provision of services or in the scope of marketing activities. For
example, the provision of information such as name and e-mail address, contact details, shipping and billing addresses and credit card information are included.

In the case of commercial communications for marketing purposes, the data subject will consent in advance to his / her sending, without prejudice to being able, at any moment, to oppose this same sending, by means of a written request to that effect, directed To Evollu.

Children

Evollu does not intentionally collect (through websites or otherwise) any data that concerns children except with the consent of their parents or guardian. If Evollu is aware that a child under the age of eighteen has provided his or her personal data, we will dispose of it in accordance with applicable law to ensure that it is not transferred to third parties, or used (for Direct marketing or any other form of marketing).

Use and share data

Evollu treats the appropriate and relevant data of the data owner, in a legitimate manner and in accordance with the principle of good faith, for specific and specific purposes.

Evollu may use the data owner’s personal data to provide you with information about products and services, promotions, special offers, as well as other information that may be of interest to the data subject.

This information may be sent via email, telephone, SMS and / or any other form of electronic mail, letter, fax, smartphone applications, social networking websites, Web 2.0, any mobile phone content not mentioned in this list, or any other method that becomes relevant.

In addition to the data provided, Evollu may collect data on the use that the data owner makes of the services, through software included in your device or other means.

In general, the data owner may use an Evollu website or service without providing any personal data. However, certain pages or services are requested personal data. Such data will be requested, in particular, when the data owner registers a product, requests a service, responds to an inquiry, participates in a contest, exchanges e-mail with Evollu, or participates in certain activities on the website.

The data owner may choose not to proceed with any activity in which personal data is requested. If you do not provide the requested personal data, you may not be able to continue with the activity in question or affect the ability to execute and manage a contract with Evollu.

Evollu uses the data it collects (and can combine them with other information on the data subject collected for the same purposes) based on one or more conditions of legitimacy for this purpose, among other purposes:
• Provide the requested services.
• Send information about products, services and personalized content, with prior consent for this purpose.
• Manage and execute the contract with the data holder.
• Manage the relationship with the data owner, including the management of complaints.
• Evaluate and analyze the market, customers, products and services (including asking for opinions about Evollu products and services and conducting surveys).
• Understand how services are used so they can better and develop new services.
• Provide maintenance and repair of the device of the data subject.
• Hold sweepstakes, contests or promotions, under the terms legally permitted.
• Providing information on updates, new products and services, as well as for sending newsletters and informational emails.

Evollu also uses the data it collects, in the forms described at the place of collection, or otherwise, with the consent of the data owner. If necessary to pursue any of the purposes outlined above, Evollu may share the data subject’s data with:
• Business partners – trusted companies that can provide information about products and services of the data subject’s interest.
• Service providers – companies providing services to or on behalf of Evollu.
• To comply with legal obligations or the defense of legitimate interests – when requested to Evollu or to protect Evollu and its data holders, within the scope permitted by applicable legislation.

Evollu may receive data about the data owner from publicly available commercial sources (as permitted by law), which may combine with other data that it receives from or about the data owner.

Evollu services may contain links to third-party websites and services that are beyond your control. Evollu tries to ensure that its websites only link to websites that share the same privacy and security rules. However, you are not responsible for the security or privacy of any processing of data collected by these websites or other services. The data owner must exercise caution and analyze the statements of privacy and processing of personal data applicable to the websites and services of third parties that use.

After the data owner has left Evollu’s websites, Evollu does not respond for the protection and privacy of any personal data that it may provide on other websites.

Maintaining data security

Evollu has implemented technical and organizational measures to protect data against access, alteration, destruction or other forms of illegal or unauthorized treatment. Evollu protects the security of the personal data, namely, through the use of password, when necessary; And limiting access to personal data.

While we make reasonable efforts to protect data from the data owner, no website, webcast, computer system or wireless connection is completely secure.

Evollu makes reasonable efforts to ensure that it retains the data owners’s data only for as long as is necessary for the purpose for which it was collected or as required under any contract or applicable law.

The data owner must adopt behaviours to maintain the security of his data, namely:
• Do not use name and password for authentication that are obvious.
• Regular change of password on a regular basis.
• Do not divulge the password to other people.

The data owner has the right to access and update his personal data, to request details about the data processed and to request the correction of inaccuracies in that data. In certain situations the user may be charged a small fee to offer this possibility. Evollu may refuse to process orders that are abnormally repetitive, require a disproportionate effort, compromise the privacy of others or are extremely impractical. If the data subject intends to exercise the mentioned rights, you should contact Evollu accordingly through the contacts available on the website.

Consent for internacional data transfer

By using or participating in any service and / or providing your data, you consent to the collection, transfer, storage and processing of your data outside your country of residence in accordance with this Privacy Policy. The transfer of personal data outside the European Economic Area will be carried out under contracts governing the transfer of data that comply with applicable law.

Cookies, beacons and similar technologies

Cookies are small files that store data on the computer, mobile phone, or other device of the data subject that uses certain services. They allow the entity putting the cookie on the device to recognize it on different websites, services, devices and / or browsing sessions. When you use a web browser to access services, the data subject can configure the browser to accept all cookies, reject all cookies, or be notified when a cookie is sent. Each browser is different, so the data holder should consult the “Help” menu of the browser to learn how to change preferences regarding cookies. The operating system of the data subject’s device may contain additional checks on cookies. It should be noted, however, that some services may be designed to work with the use of cookies and that their deactivation may affect the possibility of accessing such services or parts thereof.

Evollu may use other types of local storage technologies such as “Flash cookies” and local HTML5 storage for Evollu services. These technologies are similar to cookies as they are stored in the data holder’s device and can be used to store some data about your preferences and activities. However, these technologies may use different parts of the device from normal cookies, and as such, the data owner may not be able to control them using the normal browser settings and tools.

Evollu may use technologies called beacons (or “pixels”), which communicate data from the data holder device to a server. Beacons can be embedded in online content, videos and e-mail, allowing a server to read certain types of data from the data owner’s device, knowing when the user has accessed certain content or e-mail messages, determine the time and date that the data owner saw the beacon and the IP address of your device.

By accessing and using Evollu services, the data owner consents to the storage of cookies, other local storage technologies, beacons and other data in their devices.

Social Plug-ins

The Evollu services can use plug-ins (extensions) in social networks (“Plug-ins”). When you use a service that contains Plug-ins, information can be transferred directly from your device to the operator of your social network. Evollu has no influence on the data collection made by the Plug-in. If you have an account with a social network, your use of Evollu services may be indicated to your account. If you interact with Plug-ins, for example by clicking “Like,” “Follow” or “Share”, or write a comment, that information may automatically appear on your social network profile. Even if you are not logged in to your social network through your account, it is possible that Plug-ins will transmit your IP address to their network operators. Please take this into consideration when using Evollu services.

If you are a user of one or more of the following social networks and do not want the operator to link your use of the Evollu services to the user data already stored by the Operator, log out of the social network before using the Evollu services.

Who can I contact with questions or concerns?

info@evollu.com or through the contact page, in www.evollu.com.