Privacy Policy

Please read this Privacy Policy carefully together with our Terms of Use to understand our policies and practices regarding your Personal Data (as defined below) and how we will treat it.

This Privacy Policy applies to the website ("Website") and the associated 'Evolv' mobile application ("App") hosted on the Apple App Store and Google Play ("App Store"), (together, the "Platform", "Services" or "Apps") which are operated by Evolv Life Limited (collectively, "Evolv", "we", "our" or "us").

Important Information and Who We Are

By using the Evolv Platform or Services, you consent to the data practices described in this Privacy Policy. If you do not agree with any part of this Privacy Policy, then we cannot make our Platform or Services available to you and you should stop accessing and using them.

This Privacy Policy explains how we collect and use your Personal Data and is provided in accordance with our obligations under applicable privacy and data protection law, including the UK General Data Protection Regulation (UK GDPR), Regulation (EU) 2016/679 (EU GDPR), and the Data Protection Act 2018 ("Applicable Data Protection Law").

For the purposes of this Privacy Policy, the term "Personal Data" means any information which identifies you or which allows you to be identified when combined with other information. It does not include data where your identity has been removed ("Anonymised Data"). For the purposes of Applicable Data Protection Law, Evolv Life Limited is the data controller.

Information We Collect and How

Basic Identifiers and Contact Information

We collect some information from you when you provide it to us directly, such as via an email or online form, through the support feature embedded in our Services, or through another form of enquiry. This information may include your name, email address, and phone number as well as other information.

Account Information

When you create an account, we collect your account information.

Device Information

When you download and use our Services, we automatically collect information on the type of device you use, operating system, resolution, application version, mobile device identifiers (such as your device ID, advertising ID), language, time zone and IP address.

Usage Information

We collect information automatically about your activity through our Services, such as the date and time you used a service, features you have used, your in-app purchases history, subscriptions, your interaction with advertisements, and data generated when you use our Services.

Location Information

We may collect, with your consent, location information such as approximate geolocation using your IP address.

Information from Third Parties

We may receive information about you from our third-party service providers (such as analytics providers), who collect this information through our Services in accordance with their own privacy policies.

Health Data and Special Category Data

The information you provide when using our Services may include health-related information. Such categories of data may be considered Special Categories of Personal Data for the purposes of Applicable Data Protection Law. We process this data on the basis of your explicit consent, which you provide when you choose to input such information into the App.

Aggregated Anonymised Data

The anonymised information we collect from you may be combined with the information provided by other anonymous users to produce aggregated anonymised data sets ("Aggregated Data"). Aggregated Data is not considered to be Personal Data as it does not reveal your identity.

Aggregated Data may be used for the operation of the Platform and the Services we provide to you, and to provide general statistics regarding use of our Platform and Services. However, if we combine or connect Aggregated Data with any of your Personal Data that enables you to be directly or indirectly identified, we will treat such data as Personal Data to be used in accordance with this Privacy Policy.

Use of Cookies and Analytics

The Evolv Platform may use "cookies" and similar technologies to provide and personalise our Services. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

Our Platform uses cookies and similar technologies to distinguish you from other users of our Platform. This helps us to provide you with a good experience when you browse our Platform and allows us to improve our Platform.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Platform may become inaccessible or not function properly.

Providing Personal Data to Third Parties

You should be aware that when using our Platform and Services, you may be providing your Personal Data to third-party providers. The charges for using our Platform and Services are administered by the App Store you use to download our Apps and Services (e.g. Apple App Store and Google Play). We recommend that you refer to the privacy policy of the relevant App Store.

Children

We do not knowingly collect personally identifiable information or Personal Data from children under the age of 16. If you are under the age of 12, you must ask your parent or guardian for permission to use our Platform or Services.

Purposes for Which We Will Use Your Personal Data

We may collect and use your personal information and Personal Data to operate our Website and Platform, and to provide the Services you have requested.

The legal bases we rely upon to use your Personal Data may include the contract we have with you, your consent, and our legitimate interests, or where we need to comply with a legal or regulatory obligation. Please contact us if you require further details.

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Examples of the ways in which we use your Personal Data include:

To provide and maintain our Services, including to register you as a new user, recognise you when you return to our App, and perform essential business operations. Legal basis: performance of a contract with you.

To administer and protect our Services (including troubleshooting, data analysis, testing, support, fraud prevention, reporting and hosting of data). Legal basis: legitimate interests for running our business.

To personalise your experience and deliver content and features relevant to your interests. Legal basis: consent and/or legitimate interests.

To communicate with you about updates, new features, and service-related announcements. Legal basis: legitimate interests and/or consent.

Purposes for Which We Will Share Your Personal Data

We may share your Personal Data for certain purposes with our business partners or affiliates in accordance with Applicable Data Protection Law, as set out below.

Sharing with Service Providers and Partners

We may share your Personal Data with our third-party business service providers who perform functions on our behalf. These may include IT service providers and system administrators; data hosts and providers of programming or technical support; professional advisers including lawyers, bankers, and auditors; and third-party analytics partners to analyse website traffic and understand customer needs and trends.

For Corporate Transactions

We may transfer your Personal Data if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganisation, dissolution, bankruptcy or other change of ownership or control.

When Required by Law

We may also share Personal Data if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or to protect the rights, property, or safety of our business, our customers or others.

To Enforce Legal Rights

We may also share Personal Data: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

Cross-Border Data Transfers

Sharing of Personal Data sometimes involves cross-border data transfers, including transfers outside of the UK and/or EEA in accordance with the law. We only transfer Personal Data to entities in third countries that have provided appropriate safeguards to ensure that their level of data protection is in agreement with this Privacy Policy and applicable law.

Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Your passwords are stored in encrypted form. We do not disclose your account details or email addresses to anyone except when legally required to do so. However, it is your responsibility to keep your password secure.

Information between your browser/App and the Platform is transferred in encrypted form using Secure Socket Layer (SSL) or equivalent encryption technology. When transmitting sensitive information, you should always make sure that your browser can validate the Platform's certificate.

We limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

We will keep your Personal Data for at least [RETENTION PERIOD] from the date of the last interaction for insurance and liability purposes. Should you opt out of using our Services, you will be able to re-join and access your Personal Data within this period.

The retention of your Personal Data will be reviewed regularly for relevance. Any Personal Data deemed no longer relevant will be deleted.

Where we have taken steps to anonymise your Personal Data (so that it can no longer be associated with you) we may use this indefinitely for analytical, research and statistical purposes and to help us improve our products and services.

Your Rights

Right to Withdraw ConsentWhenever we rely on your consent to process your Personal Data, you have the right to withdraw your consent at any time. Please contact us using the contact details provided at the end of this Privacy Policy. This will not affect the lawfulness of any processing carried out before you withdraw.

Right of AccessYou have the right to make a request to access your Personal Data collected through our Platform and Services (known as a "Data Subject Access Request" or "SAR"). We aim to respond to all SARs within one month. We do not charge a fee for responding to a SAR. However, we may charge a reasonable fee if your SAR is manifestly unfounded or excessive.

Right of RectificationYou have the right to ask us to rectify Personal Data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Right to ErasureYou have the right to ask us to erase your Personal Data in certain circumstances.

Right to Restriction of ProcessingYou have the right to ask us to restrict the processing of your Personal Data in certain circumstances.

Right to Object to ProcessingYou have the right to object to the processing of your Personal Data in certain circumstances.

Right to Data PortabilityYou have the right to ask that we transfer your Personal Data to another organisation, or to you, in certain circumstances.

Opt-Out and UnsubscribeWe respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from us by contacting us at [CONTACT EMAIL] or selecting the "Unsubscribe" option on any email communication.

Changes to This Privacy Policy

We may occasionally update this Privacy Policy to reflect company and customer feedback and any changes in data protection regulations. We encourage you to periodically review this Privacy Policy to be informed of how we are protecting your information.

Contact Information

Evolv welcomes your questions or comments regarding this Privacy Policy. If you believe that we have not adhered to this Privacy Policy, please contact us at [PRIVACY EMAIL ADDRESS].

Evolv Life Limited[REGISTERED ADDRESS LINE 1][REGISTERED ADDRESS LINE 2][CITY, POSTCODE][COUNTRY]

Questions, comments and requests regarding this Privacy Policy are welcome and should be addressed to [PRIVACY EMAIL ADDRESS].

We ask that you try to resolve any issues with us first, although you have a right to lodge a complaint with the Information Commissioner's Office (ICO) at any time about our processing of your personal information.

The ICO is the UK regulator for data protection and upholds information rights.

Information Commissioner's OfficeWycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AFTelephone: 0303 123 1113

‍