Last updated: 20 March 2023
This privacy notice explains the processing of your personal data by Evrnu, SPC, 2540 Westlake Ave N Suite B, Seattle, WA 98109 (“Evrnu,” “we,” “our,” or “us”), when visiting the Evrnu website or using Evrnu services, and your rights under the GDPR.
1. Data categories, purposes of processing your data, legal bases
Based on your use of our website and services, certain personal data may be collected, stored and used by Evrnu. In addition, some aspects of your use may require you to submit information that is personal to you, such as your name and email address. This information will only be used by Evrnu for the provision of the related services. Providing personal information is always at your sole discretion, but avoidance of providing such information may mean that you cannot benefit from certain aspects of our services.
We process your personal data for the performance of a contract with you (legal basis is Art. 6 (1) lit. b GDPR):
For the provision of our website (including information that is automatically collected and processed by our webserver such as your IP address, date and time of your visit, the website you are coming from, the subpages visited on our website, the browser type and version used, etc.).
For the provision of services on our website (this includes information you choose to send to us by using the contact form on our website as well as related metadata such as date and time of your request and your IP address).
For communication with us by other means such as via email or telephone.
We also process these categories of personal data for our legitimate interests (Art. 6 (1) lit. f GDPR):
For the detection and prevention of misuse of our website and services.
For the optimization of our website and services.
b) Evrnu Newsletter
If you choose to subscribe for our newsletter, we will process your personal data for the purpose of providing you with information about Evrnu services and products on the basis of your consent (Art. 6 (1) lit. a GDPR). To better understand our newsletter recipients, pixel tags and cookies in our emails may be used to track your interactions with those messages, such as when you receive, open, or click a link in an e-mail message from us. You withdraw your consent at any time with effect for the future, e.g., by using the unsubscribe link in the footer of each email.
2. Recipients of your data
Your personal data will be transferred to our service providers that process your personal data on our behalf, e.g., to host and manage our website, services and content (such as images). Should this involve transfers of your personal data to third countries outside the EU, we ensure an appropriate level of data protection through contractual measures. You have the right to receive copies of such contracts.
In particular, we use external services from Microsoft (Microsoft Azure App Service, a cloud computing-based platform for building and hosting websites and apps) and Cloudflare (Cloudflare Global CDN, a content delivery network that allows us to host and provide you with content on our website). By using these services, certain of your personal data (such as your IP address, date and time of your visit as well as information about the subpages you visit) may be transmitted to such service providers. Contact details:
Microsoft Azure App Service is a service by Microsoft (Microsoft Corporation, One Microsoft Way, Redmond, Washington 98052 USA) with Microsoft Ireland Operations Limited (Microsoft Ireland Operations, Ltd., Attn: Data Protection, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland) as Microsoft’s data protection representative for the European Economic Area and Switzerland.
Cloudflare Global CDN is a service by Cloudflare (Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, Attn: Data Protection Officer).
3. Duration of the data processing
We will only process your personal data as long as this is necessary for the respective purpose or as long as there are legal retention obligations. After the respective processing purpose ceases to apply and retention obligations end, your data will be routinely deleted.
4. Your rights
You have the following rights in relation to the personal data we hold about you.
a) The right to access your personal data.
What this means for you: We will provide you with access to your personal data that is undergoing processing, together with some further information which you are entitled to receive, such as the purpose of the processing (i.e. why we process it), the categories of data being processed (i.e. what types of data is being processed, such as name, address etc.) and who else we may engage with to receive your personal data on our behalf.
What you can do: You can request that we provide you with access to the personal data that we process about you (i.e. a copy of it).
There may be valid reasons for refusing to comply with some access requests (or parts of an access request), for example in order to protect the rights of other individuals.
b) The right to prevent processing of your personal data in certain circumstances.
What this means for you: We will, in certain circumstances and to the extent required by law, restrict our processing of your personal data.
What you can do: You can request that we restrict the processing of your personal data in particular if the data is inaccurate, if the processing is unlawful, if we no longer need the personal data, or if you exercise your right to object (see below). If you seek to exercise this right, we may need to work with you to understand the issues and to determine the extent to which we are required to restrict the processing of your data.
c) The right to rectify information.
What this means for you: We are required to take steps to ensure the accuracy of the personal data that we process.
What you can do: If you become aware that the personal data that we hold about you is incorrect, or if your situation changes (for example you change address) please let us know and we will update our records.
d) The right to data portability.
What this means for you: In some circumstances, we will be required to provide certain personal data to you or another organization at your request in a commonly used and machine-readable format.
What you can do: In particular, you have the right to request the transfer of your personal data to another organization (i.e. another data controller) in a structured, commonly used machine-readable format, so that the other organization can, at your request, read and use it. This allows your personal data to be easily transferred from one IT environment to another in a safe and secure way.
e) The right to erasure of your data (also known as the "right to be forgotten").
What this means for you: In certain circumstances and where we are required to do so by law, we must ensure that personal data is deleted at your request. This right is not "absolute", and it is likely that there will be scenarios where we are entitled to continue to retain and process your data, even if you have asked us to erase your data.
What you can do: If you make this request, we will need to balance certain legal, contractual and business interests against your right to request the deletion of the relevant data.
f) The right to object to certain processing of your data.
What this means for you: If you object to our processing of your personal data, we will consider certain legal, contractual and business interests and obligations and balance these against your right to object to the processing.
What you can do: You may object to the processing of your personal data in certain circumstances, in particular where we process your personal data on the basis of legitimate interests (legal basis is Art. 6 (1) lit. f GDPR). You can also object to our use of your personal data for direct marketing purposes.
g) The right to withdraw your consent at any time with effect for the future
If you have given your consent to the processing of your personal data (legal basis is Art. 6 (1) lit. a GDPR), you can withdraw your consent at any time with effect for the future by contacting us (please find our contact details below).
h) The right not to be subject to a decision based solely on "automated processing", (i.e. the right not to be subject to a decision made about you automatically by a computer or algorithm without human intervention).
We are required to keep records of the automated processing that we carry out and in certain circumstances, to give people the right to object to being subject to decisions made in this way as well as providing information about the way that the decisions are made.
You may object if a decision is made wholly by a computer or algorithm without human input. You will also be given information about this type of processing.
5. Contact; complaint to supervisory authority
If you want to exercise any of these rights, you should make a request to [email protected].
You also have the right to complain about our use of your personal data to the competent supervisor authority. For example, you can contact the UK’s Information Commissioner's Office via their website: https://ico.org.uk/concerns/ or by calling +44 (0)303 123 1113.