Updated on 16 April 2024

1. Introduction

At EvolveBPO (“EvolveBPO”), we take your privacy seriously. This Privacy Notice (this “Notice”) states our policy and practices regarding the collection and use of information you submit to us, or which we collect via various channels (including our websites; through written correspondence, including e-mail; or through any of our offices or websites globally). When we refer to EvolveBPO, “we”, “us” or “our” we mean our entire company, including our divisions, subsidiaries, and affiliates.

Through this Notice we aim to inform you about the types of personal data we collect, the purposes for which we use the data and the ways in which the data is handled. We also aim to satisfy the obligation of transparency under the EU General Data Protection Regulation 2016/679 (“GDPR”) and national laws implementing GDPR.
Please read this Notice carefully to understand our policies and practices regarding your data and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our websites or services. By accessing or using our websites, you agree to this Notice, subject to your rights as provided by this Notice or applicable law. This Notice may change from time to time (see Section 16 “Changes to Our Notice”).

2. The Data We Collect
Generally, we collect personal data from two groups of people: our marketing customers and our subscribers. “Personal data” means information that personally identifies someone or that relates to an identified or identifiable person, in accordance with applicable law.

Business Customer Data – When we enter into a relationship with our business customers, we will collect the personal data that we need to provide our services to them, including name; business contact information, including phone number, email address, and mailing address; company name; job title; and billing, transaction, and credit card information. We may also collect additional information provided by our customers when they communicate with us.

ii. Subscriber Data – We collect certain data about individuals when they subscribe to our content, including name; business contact information, such phone number, email address, and mailing address; company name; and job title. This information may be publicly available or provided directly to us, such as by our customers or other third-party providers, as permitted by applicable law. This data may include potential subscribers or other parties that have demonstrated an interest in our services or that have registered to attend our corporate events.
3. How We Collect Your Personal Data

i. Through the EvolveBPO Websites – Both customers and leads may access our websites and/or communicate with us. In general, you can visit the EvolveBPO websites without identifying yourself or revealing any personal data. However, you may choose to provide us with personal data (e.g., via our ‘say hello’ or ‘let’s connect’ web forms). Within the EvolveBPO websites, you can make requests for information, register to receive materials, and in some cases, order products or services.

ii. From You – You may provide us additional personal data, such as when you contact us by phone or mail, or when you register for or attend corporate events. In these cases, we will collect your contact information as well as information regarding your communications with us.

iii. From Other Sources – We may collect information, including personal data, from publicly available sources or from other third parties. To the extent that we collect your personal data from these sources, we will treat it in accordance with this Notice, and we will honour your rights regarding your personal data as outlined in this Notice.
iv. Through Your Browser or Device – We also collect certain data automatically when you use our websites. For more information, see Section 9 “Aggregate Information About EvolveBPO Online Visitors” and Section 10 “Use of Cookies.”

4. How We Use Your Personal Data

You can be assured that information you provide voluntarily will only be used in connection with your business relationship with EvolveBPO. We will hold and use your personal data for our legitimate business purposes including:

To present our websites and their contents to you;
To provide the services, products, or information you request. For example, if you fill out our ‘let’s connect’ web form, we will use the information provided to contact you about your interest in our services;
To better understand your needs and to provide better service;
To plan and host corporate events and to populate online profiles for attendees on EvolveBPO's websites;
From time to time and with your consent, to contact you for market research or to provide you with marketing information we think would be of particular interest. At a minimum, we will always give you the choice to opt-out of receiving such direct marketing or market research contact;
To carry out our obligations and enforce rights arising from any contracts entered into between you and us;
To protect against and prevent fraud, unauthorized transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users;
To notify you about changes to our websites, products, or services;
To comply with applicable legal requirements and industry standards; and
Otherwise with your consent or as described to you when you provide the data.
EvolveBPO uses credit card information only for payment processing and related purposes.

5. The Legal Basis for Processing Your Personal Data

Under GDPR, the main grounds that we rely upon in order to process personal data of customers, leads, other users of our websites, and event attendees are the following:

i. Necessary for entering into, or performing, a contract – In order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data.

ii. Necessary for compliance with a legal obligation – We are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency.

iii. Necessary for the purposes of legitimate interests - Either we, or a third party, will need to process your personal data for the purposes of our (or a third party’s) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include responding to requests and inquiries from you or a third party, optimising our websites and customer experience, our market research, informing you about our products and services, and ensuring that our operations are conducted in an appropriate and efficient manner.

iv. Consent – We may also ask for your consent to process your personal data in a particular way.

6. How We Share Your Personal Data

We may disclose your personally identifiable information:

i. To EvolveBPO affiliates – When you disclose your personal data to us, we may share it with EvolveBPO both inside and outside the European Economic Area (“EEA”). For more information regarding our affiliate locations, please see the “Contact Us” section below.

ii. To third-party service providers and contractors – We will share your personal data with trusted third parties where we have retained them to support our business and who are bound by contractual obligations to keep personal data confidential and to use it only for the purposes for which we disclose it to them. To the extent that any personal data is provided to third parties outside the EEA, or who will access the information from outside the EEA, we will use approved frameworks, including, with respect to any transfers outside of the EEA or access to the information as above, entering into standard contractual clauses as approved by the European Commission.

iii. To our customers – We may share certain lead information with our customers in accordance with applicable law to allow our customers to connect with potential leads for their products or services. We will not share sensitive personal data with our customers, nor do we share personal data with data brokers.

iv. As required by law – We may disclose your personal data as required by applicable law, regulation or as part of a legal process. If we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR and other laws, we may disclose certain personal data to such bodies or agencies.

v. To new business owners – If we or our business merges with or is acquired by another business or company, we will share your personal data with the new owners of the business or company and their advisors, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Notice.

vi. To fulfil the purpose for which you provide it.

vii. To carry out our obligations and enforce rights arising from any contracts entered into between you and us.
viii. Otherwise with your consent or as described to you when you provide the data.

7. How Long We Will Hold Your Information
We will retain your personal data for the time necessary to provide the services we perform for you or fulfill the purposes outlined in this Notice, and you can always request that we stop processing or delete your personal data. The next section sets out more information on your rights.

8. Your Rights Regarding the Information We Hold About You
You have certain rights in relation to personal data we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.

i. Right of Access – You have the right at any time to ask us for a copy of the personal data about you that we hold. Where we have good reason, and as permitted by law, we can refuse your request for a copy of your personal data, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so. To exercise this right, please contact us by us using the details in the “Contact Us” section below.

ii. Right of Correction or Completion – If personal data we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. To exercise this right, please contact us by us using the details in the “Contact Us” section below.

iii. Right of Erasure – In certain circumstances, you have the right to request that personal data we hold about you is erased, e.g., if the data is no longer necessary for the purposes for which it was collected or processed or our processing of the data is based on your consent and there are no other legal grounds on which we may process the personal data. To exercise this right, please contact us by us using the details in the “Contact Us” section below.

iv. Right to Object to or Restrict Processing – In certain circumstances, you have the right to object to our processing of your personal data, for example, if we are processing your data on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal data for direct marketing purposes. You may also have the right to restrict our use of your personal data, such as in circumstances where you have challenged the accuracy of the data and during the period where we are verifying its accuracy. To exercise these rights, please contact us by us using the details in the “Contact Us” section below.

v. Right of Data Portability – In certain instances, you have a right to receive any personal data that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that data to you or directly to a third-party organisation. This right exists only in respect of personal data that:
you have provided to us previously; and is processed by us using automated means.

While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation’s systems. We are also unable to comply with requests that relate to personal data of others without their consent. To exercise this right of data portability, please contact us by us using the details in the “Contact Us” section below.

vi. Right to Revoke Consent – To the extent that we are processing your personal data based on your consent, you have the right to withdraw your consent at any time. To exercise this right, please contact us by us using the details in the “Contact Us” section below.

Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your right.

9. Aggregate Information About EvolveBPO Online Visitors
We gather information and statistics collectively about all visitors to our websites for example:

which area users access most frequently,
which services users access the most,
the type of operating system and browser software,
the geographical location of browsers,
broad demographic information, and
to monitor mouse clicks and movements and scrolling activity.

We only use such data in the aggregate form. The information and statistics we collect helps us determine what is most beneficial for our users and how we can continually improve our online services to create a better overall experience for our users. Although such data may be shared with third parties, such as advertisers, the underlying data is not shared with anybody else.

10. Use of Cookies

We do automatically track certain information about your behavior while visiting our webpages. We use this information in order to measure our website’s performance, user traffic, improve its design and functionality and other internal management purposes.

The session cookie is never saved nor written to disk, and the information contained in the session cookie is only valid for that particular session and is discarded when the browser is closed. The information we collect in this way does not identify you personally and you remain anonymous unless you voluntarily choose to provide EvolveBPO with personal data.

11. Complaints
If you are unhappy about our use of your personal data, you can contact us using the details in the “Contact Us” section below. You are also entitled to lodge a complaint with the UK Information Commissioner’s Office using any of the below contact methods:

Telephone: 0303 123 11113
Website: https://ico.org.uk/concerns/
Post:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
If you live or work outside the UK or you have a complaint concerning our activities outside the UK, you may prefer to lodge a complaint with a different supervisory authority. A list of relevant authorities in the EEA and the European Free Trade Area can be accessed here.

12. Security
We have implemented measures designed to secure the information we collect and store about you and will use our reasonable efforts to protect your personal data from unauthorised disclosure and/or access including through the use of network and database security measures, but these cannot guarantee the security of any data which is collected and stored. We use encryption when collecting or transferring sensitive data, such as credit card information. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the EvolveBPO websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

13. Other Websites
Please note that clicking on links and banner advertisements on our websites can result in your browser accessing a third-party website, where data privacy practices are different to that of EvolveBPO.

We are not responsible for, and have no control over, data that is submitted to or collected by these third parties, and if you have any questions about their privacy practices, you should consult their privacy policies.

14. Internet-based Transfers
Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. Unfortunately, the transmission of data via the Internet is not completely secure. Although we take commercially reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to our websites via third party networks. Any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access.

15. Do Not Track

Your web browser may let you choose your preference as to whether you want to allow the collection of information about your online activities over time and across different websites or online services. At this time, our websites do not respond to the preferences you may have set in your web browser regarding such collection of your information, and our websites may continue to collect information in the manner described in this Notice.

16. Changes to Our Notice

It is our policy to post any changes we make to our Notice on this page. If we make material changes to how we treat our users' personal data, we will notify you by email to the primary email address specified in your account or through a notice on the EvolveBPO websites. The date the Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our websites and this Notice to check for any changes.

17. California Privacy Rights

If you are a California resident, you may find more information about the rights available to you in our Privacy Notice for California Residents.

18. Children’s Information

Our services are not directed to, and EvolveBPO does not knowingly collect or solicit personal data from, children under the age of 16. If we learn we have collected or received personal data from a child under the age of 16, we will delete that information. If you believe we might have any information from or about a child under the age of 16, please let us know.

19. Contact Us

If you have any enquires or if you would like to contact us about our processing of your personal data, including to exercise your rights as outlined above, please contact us centrally by any of the methods below. When you contact us, we will ask you to verify your identity.

Contact name: Privacy Team
Email: info@EvolveBPO.com
Telephone: +1 347 627 091199 Wall Street #3966 New York, NY 10005

Our registered office is at:
99 Wall Street #3966 New York, NY 10005

EvolveBPO - Privacy Notice for California Residents
Last updated Sep 5, 2022

This Privacy Notice for California Residents supplements the information contained in the general Privacy Policy of EvolveBPO (“EvolveBPO,” “we,” or “us”), which is incorporated in this privacy notice by this reference. This privacy notice applies solely residents of the State of California about whom we collect personal information (“consumers” or “you”), including, for example, visitors to our websites and our subscribers. We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018 (as amended, and together with the California attorney general’s implementing regulations, the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this Privacy Notice.

Information We Collect

We may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). In particular, we have collected the following categories of personal information from its consumers within the last 12 months for the business or commercial purposes described below:
Description
Examples
Source
Business or Commercial Purposes for Collection
Identifiers (“Identity Data”).
A real name, internet protocol address, email address
Directly from the consumer (e.g., when they sign up to receive emails from us)
From our business customers
Indirectly from the consumer (e.g., through our use of cookies on our webpage)
Conducting marketing campaigns on behalf of, and sharing potential leads with, our business customers
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (“Customer Records Data”).
A name, telephone number, employment (e.g., job title and company name)
Directly from the consumer (e.g., when they sign up to receive a newsletter) From our business customers

Internet or other similar network activity (“Internet Use Data”).
Information on a consumer’s interaction with a website, application, or advertisement.
Indirectly from the consumer (e.g., through our use of cookies on our webpage)
Conducting marketing campaigns on behalf of, and sharing potential leads with, our business customers
Professional or employment-related information (“Professional Data”).
Current or past job history (i.e., job title)
Directly from the consumer (e.g., when they sign up to receive emails from us)
From our business customers
Conducting marketing campaigns on behalf of, and sharing potential leads with, our business customers
Inferences drawn from other personal information (“Inferences”).
Profile reflecting a person’s preferences
Indirectly from the consumer (e.g., through our use of cookies on our webpage)
Conducting marketing campaigns on behalf of, and sharing potential leads with, our business customers

Personal information does not include:
Publicly available information from government records.
Deidentified or aggregated consumer information.
·Information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In addition to the business or commercial purposes for collection described above, we have in the preceding 12 months collected all categories of personal information described above for the following purposes:
To process your requests and transactions and to prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To create, maintain, customize, and secure your account with us.
For testing, research, analysis, and product development, including to develop and improve this Site and our products and services.
To provide, support, personalize, and develop this Site and our products and services.
To help maintain the safety, security, and integrity of this Site and our products, services, databases, other technology assets, and business.
To deliver content and product and service offerings relevant to your interests, including targeted offers and ads through this Site, third-party sites, and via email or text message (with your consent, where required by law).
We will continue to collect the categories of personal information described above for the business or commercial purposes described above. We may also use or disclose the personal information we collect for one or more of the following purposes:
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of EvolveBPO's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by EvolveBPO about the users of this Site is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Disclosures of Personal Information for a Business Purpose
In the preceding 12 months, we have not disclosed consumers’ personal information for a business purpose.
Sales of Personal Information
In the preceding 12 months, we have sold the following categories of personal information:
Identity Data.
Customer Records Data.
Professional Data.
We sell your personal information to the following categories of third parties:
Our business customers for their own internal marketing use.
For purposes of clarity, it is not EvolveBPO’ s practice to sell personal information to data brokers.
Your Rights and Choices
The CCPA provides you as California residents with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
·If we disclosed for a business purpose or sold your personal information, two separate lists disclosing:
Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Sales, identifying the personal information categories that each category of recipient purchased.
Deletion Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Complete the transaction for which we collected the personal information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise that consumer’s free speech rights, or exercise another right provided for by law.

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Calling us at 1 347 627 0911
Emailing us at info@EvolveBPO.com
Visiting: Webform
Contacting us by mail at:
EvolveBPO
99 Wall Street #3966 New York, NY 10005

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us, but we may require authentication of the consumer that is reasonable in light of the nature of the personal information requested.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (for a maximum total of 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by electronically.

Any disclosures we provide will only cover the 12-month period preceding the receipt of a verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless the request is excessive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Alternatively, we may decline to respond to the request and notify you of our reason for doing so.

Personal Information Sales Opt-Out and Opt-In Rights

To exercise the right to opt-out, you (or your authorized agent) may submit a request to us by visiting our “Do Not Sell My Personal Information” webpage. If your authorized agent submits a request on your behalf, the authorized agent must provide either (1) a copy of your written permission for the authorized agent to submit a request on your behalf and information sufficient to verify the authorized agent’s identity or (2) power of attorney pursuant to California’s Probate Code.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Once you make an opt-out request, we will wait at least 12 months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into our subscription program at any time by visiting.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.

Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties.

Provide you a different level or quality of goods or services, including denial of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please reach out to us through the information set forth below.

Changes to this Privacy Notice

EvolveBPO reserves the right to update or change this privacy notice at any time. When we make changes to this privacy notice, we will post the updated notice on this Site and update the date on which this privacy notice was last updated. The date this privacy notice was last updated is at the top of this page. You are responsible for periodically reviewing this Site and this privacy notice to check for any updates or changes. Your continued use of this Site following the posting of changes constitutes your acceptance of such changes.

If you have any questions or comments about this privacy notice or our privacy practices, your choices and rights regarding use of your personal information, or wish to exercise your rights under California law, please contact us at:

Calling us at 1 347 627 0911
Emailing us at info@EvolveBPO.com
Visiting: Webform
Contacting us by mail at:
EvolveBPO
99 Wall Street #3966 New York, NY 10005