Privacy Policy
In accordance with the legal requirements of data protection law (in particular in accordance with the European Data Protection Regulation GDPR), we inform you below about the nature, scope and purpose of the processing of personal data by our company. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online services”).
Name and contact details of the responsible person(s)
Our responsible person(s) (hereinafter “responsible person”) within the meaning of data protection officer and controller:
Naomi Stubbé
Evolute Institute B.V.
Korte Lijnbaanssteeg 1
Office no. 4277
1012SL, Amsterdam
The Netherlands
E-Mail: [email protected]
Legal notice: https://evolute-institute.com/imprint/
Types of data, purposes of processing and categories of data subjects
In the following, we inform you about the type, scope and purpose of the collection, processing and use of personal data.
1. types of data we process
Inventory data (e.g. name, address, etc.), contact data (e.g. telephone number, e-mail, etc.), content data (e.g. text input, videos, photos, etc.), communication data (IP address, etc.), contract data (e.g. contract object, duration), payment Data (e.g. bank details, invoices, payment history)
2. purposes of processing
Processing of contracts, marketing / sales / advertising, handling contact requests and inquiries, assessment of prospective customers, office and organisational procedures, provision of services and customer support, feedback (e.g. collecting feedback via online forms), security measures
3. categories of data subjects
Visitors/users of the website, interested parties, prospective customers, business and contractual partners
The data subjects are collectively referred to as “users”.
Legal basis of the processing of personal data
Below we inform you about the legal basis for the processing of personal data:
- If we have obtained your consent for the processing of personal data, the legal basis is Art. 6 (1) p. 1 lit. a) GDPR.
- If the processing is necessary for the performance of a contract or for the implementation of pre-contractual measures, which are carried out at your request, Art. 6 (1) S. 1 lit. b) GDPR is the legal basis.
- If the processing is necessary for the fulfillment of a legal obligation to which we are subject (e.g. legal retention obligations), Art. 6 (1) p. 1 lit. c) GDPR is the legal basis.
- If the processing is necessary to protect vital interests of the data subject or another natural person, Art. 6 (1) p. 1 lit. d) GDPR is the legal basis.
- If the processing is necessary to protect our legitimate interests or the legitimate interests of a third party and your interests or fundamental rights and freedoms are not overridden in this respect, Art. 6 (1) p. 1 lit. f) GDPR is the legal basis.
- In addition to the data protection regulations of the General Data Protection Regulation, national regulations apply to data protection in Netherlands as governed by the Dutch Data Protection Authority (Dutch DPA).
Please note that, in addition to the regulations of the GDPR, the national data protection regulations may apply in your country or in our country of residence or domicile.
Disclosure of personal data to third parties and order processors
As a matter of principle, we do not pass on any data to third parties without your consent. If this should nevertheless be the case, then the transfer takes place on the basis of the previously mentioned legal grounds, e.g. in the case of the transfer of data to online payment providers for the fulfillment of a contract or due to a court order or because of a legal obligation to hand over the data for the purpose of criminal prosecution, to avert danger or to enforce intellectual property rights.
We also use processors (external service providers, e.g. for web hosting of our websites and databases) to process your data. If data is passed on to the processors as part of a contract processing agreement, this is always done in accordance with Art. 28 GDPR. In doing so, we carefully select our processors, regularly monitor them and have been granted a right to issue instructions regarding the data. In addition, the processors must have taken appropriate technical and organizational measures and comply with the data protection regulations according to GDPR.
Data transfer to third countries
The adoption of the European General Data Protection Regulation (GDPR) has created a uniform basis for data protection in Europe. Your data is therefore predominantly processed by companies to which GDPR applies. If, however, processing is carried out by services of third parties outside the European Union or the European Economic Area, these must meet the special requirements of Art. 44 et seq. GDPR. This means that the processing takes place on the basis of special guarantees, such as the officially recognized determination by the EU Commission of a level of data protection corresponding to the EU or the observance of officially recognized special contractual obligations, the so-called “standard contractual clauses”.
Insofar as we obtain your express consent to the transfer of data to the USA due to the invalidity of the so-called “Privacy Shield”, pursuant to Article 49 (1) sentence 1 lit. a) GDPR, we point out in this regard the risk of secret access by US authorities and the use of the data for monitoring purposes, possibly without any legal remedy for EU citizens.
Data transfer within the Organisation
We may transfer or otherwise provide access to personal information to other locations within our organisation. Insofar as this disclosure is for administrative purposes, the disclosure of the data is based on our legitimate business and economic interests or otherwise, if it is necessary to fulfil our contractual obligations or if the consent of those concerned or otherwise a legal permission is present.
Deletion of data and storage period
Unless expressly stated in this privacy policy, your personal data will be deleted or blocked as soon as you revoke the consent given for processing or the purpose for storing the data no longer applies or the data are no longer required for the purpose, unless their continued storage is necessary for evidentiary purposes or is contrary to statutory retention obligations. This includes, for example, data that must be stored for commercial or tax reasons or for which storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person. If the prescribed retention period expires, your data will be blocked or deleted, unless the storage is still necessary for the conclusion or fulfillment of a contract.
Table 1:
Categories of Personal Information | Retention Period |
Information that you provide by filling in forms on our Website. This includes information provided at the time of requesting further services. We may also ask you for information when you report a problem with our Website. | Unless this information also falls under one of the other categories of personal information identified in the column to the left and below this row (such that a longer retention period applies), this information will be retained for up to six (6) months after answering your question or fulfilling request, after which the personal data will be deleted. |
Records and copies of your correspondence (including email addresses), if you contact us. | Unless this information also falls under one of the other categories of personal information identified in the column to the left and below this row (such that a longer retention period applies), this information will be retained for up to two (2) years, after which the personal data will be deleted. |
Your first name and e-mail address, if you sign up for receiving our latest newsletter via our Website. | This information will be retained until you withdraw your consent or request us to delete this information. |
Your name, e-mail address, telephone number, date of birth, billing address and the contact details of your emergency contact to register for one of our programs. This information will be collected via an online questionnaire (Google Forms). | This information will be retained until your participation in our program(s) has concluded and for up to seven (7) years after such date, after which the personal data will be deleted, unless you request that we delete this information before the seven-year retention period has expired. |
Any information on your physical or mental health provided by you via our Application Forms prior to registering for an Evolute Institute Retreat program on the basis of which we may decide that we are unable to accept you into one of our programs due to safety. This information may contain sensitive data and will only be collected and disclosed on the basis of your explicit consent and written authorization. | Unless we decide that we are unable to accept you into one of our programs, this information will be retained until your participation in our program(s) has concluded and for up to one (1) year after such date, after which the personal data will be deleted, unless you request that we delete this information before the one-year retention period has expired. If we decide we are unable to accept you into one of our programs, we will retain this information for [six (6) weeks] after the later (i) informing you of such a decision or (ii) our final communication with you about such decision. |
Existence of automated decision making
We do not use automated decision making or profiling.
Provision of our website and creation of log files
If you only use our website for informational purposes (i.e. no registration and no other transmission of information), we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data:
– IP address;
– Date and time of access;
– Browser type;
– Language and browser version;
– Content of the retrieval;
– Time zone;
– Access status/HTTP status code;
– Websites from which the request came;
– Operating system.
A storage of this data together with other personal data of you does not take place.
This data is used for the purpose of user-friendly, functional and secure delivery of our website to you with functions and content as well as its optimization and statistical evaluation.
The legal basis for this is our legitimate interest in data processing, which also lies in the above purposes, in accordance with Art. 6 Para. 1 S.1 lit. f) GDPR.
Cookies
We use so-called cookies when you visit our website. Cookies are small text files that your Internet browser places and stores on your computer. When you visit our website again, these cookies provide information to automatically recognize you. Cookies also include the so-called “user IDs”, where user information is stored by means of pseudonymized profiles. When you access our website, we will inform you of the use of cookies for the aforementioned purposes by means of a reference to our data protection declaration and how you can object to this or prevent their storage (“opt-out”).
The following types of cookies are distinguished:
– Necessary, essential cookies: essential cookies are cookies that are absolutely necessary for the operation of the website in order to store certain functions of the website such as logins, shopping cart or user input, e.g. regarding the language of the website.
– Session cookies: Session cookies are required to recognize multiple use of an offer by the same user (e.g. if you have logged in to determine your login status). When you visit our site again, these cookies provide information to automatically recognize you. The information thus obtained is used to optimize our offers and to provide you with easier access to our site. When you close the browser or log out, the session cookies are deleted.
– Persistent cookies: these cookies remain stored even after you close the browser. They are used for login storage, reach measurement and marketing purposes. They are automatically deleted after a specified duration, which may differ depending on the cookie. You can delete the cookies at any time in the security settings of your browser.
– Cookies from third-party providers (third-party cookies esp. from advertisers): According to your preferences, you can configure your browser settings and, for example, refuse to accept third-party cookies or all cookies. However, we would like to point out at this point that you may then not be able to use all the functions of this website. Read more about these cookies at the respective privacy statements of the third-party providers.
- Data categories: User data, cookie, user ID (e.g. the pages visited, device information, access times and IP addresses).
- Purposes of processing: The information obtained in this way serves the purpose of technically and economically optimizing our web offers and providing you with easier and more secure access to our website.
- Legal basis: If we process your personal data with the help of cookies based on your consent (“opt-in”), then Art. 6 para. 1 p. 1 lit. a) GDPR is the legal basis (declared consent). Otherwise, we have a legitimate interest in the effective functionality, improvement and economic operation of the website, so that in that case Art. 6 para. 1 p. 1 lit. f) GDPR is the legal basis. The legal basis is also Art. 6 para. 1 p. 1 lit. b) GDPR if the cookies are set to initiate a contract, e.g. for orders.
- Storage period/deletion: The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.Cookies are otherwise stored on your computer and transmitted from it to our site. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your Internet browser, you can disable or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website in full.
Here you can find information about deleting cookies by browser:
Chrome: https://support.google.com/chrome/answer/95647
Safari: https://support.apple.com/de-at/guide/safari/sfri11471/mac
Firefox: https://support.mozilla.org/de/kb/cookies-und-website-daten-in-firefox-loschen
Internet Explorer: https://support.microsoft.com/de-at/help/17442/windows-internet-explorer-delete-manage-cookies
Microsoft Edge: https://support.microsoft.com/de-at/help/4027947/windows-delete-cookies
Objection and “Opt-Out”: You can generally prevent the storage of cookies on your hard drive, regardless of consent or legal permission, by selecting “do not accept cookies” in your browser settings. However, this may result in a functional restriction of our offers. You can object to the use of cookies from third-party providers for advertising purposes via a so-called “opt-out” via this American website (https://optout.aboutads.info) or this European website (http://www.youronlinechoices.com/de/praferenzmanagement/).
Processing of contracts
We process inventory data (e.g. company, names and addresses as well as contact data of users, e-mail), contract data (e.g. services used, names of contact persons) and payment data (e.g. bank details, payment history) for the purpose of fulfilling our contractual obligations (knowledge of who is a contractual partner; justification, content and execution of the contract; checking the plausibility of the data) and services (e.g. contacting customer service) pursuant to Art. 6 para. 1 p. 1 lit b) GDPR. The entries marked as mandatory in online forms are required for the conclusion of the contract.
In principle, this data is not passed on to third parties, unless it is necessary for the pursuit of our claims (e.g. transfer to lawyer for collection) or for the performance of the contract (e.g. transfer of data to payment providers) or there is a legal obligation to do so pursuant to Art. 6 para. 1 p. 1 lit. c) GDPR.
We may also process the data you provide to inform you about other interesting products from our portfolio or to send you e-mails with technical information.
The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected (see Table 1). This is the case for inventory and contract data when the data is no longer required for the performance of the contract and claims can no longer be asserted under the contract because they are time-barred (warranty: two years / standard limitation period: three years). We are obliged by commercial and tax law to store your address, payment and order data for a period of ten years. However, we restrict processing after three years if the contract is terminated, i.e. your data is only used to comply with legal obligations. Details in the user account remain until it is deleted.
Contacting us via contact form / e-mail / mail
When contacting us via contact form, fax, mail or e-mail, your information will be processed for the purpose of handling the contact request.
- Legal Basis: The legal basis for the processing of the data is, if you have given your consent, Art. 6 para. 1 p. 1 lit. a) GDPR. The legal basis for the processing of data transmitted in the course of a contact request or e-mail, letter or fax is Art. 6 para. 1 p. 1 lit. f) GDPR. The responsible party has a legitimate interest in processing and storing the data in order to be able to answer users’ inquiries, to preserve evidence for liability reasons and, if necessary, to be able to comply with its statutory retention obligations for business letters. If the contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 p. 1 lit. b) GDPR.
We may store your information and contact request in our customer relationship management system (“CRM system”) or a comparable system.
The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected (see Table 1). For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with you has ended. The conversation is ended when it is clear from the circumstances that the matter in question has been conclusively clarified. We store inquiries from users who have an account or contract with us until two years after termination of the contract. In the case of legal archiving obligations, the deletion takes place after their expiry: end of commercial law (6 years) and tax law (10 years) retention obligation.
You have the option at any time to revoke your consent to the processing of personal data pursuant to Art. 6 (1) p. 1 lit. a) GDPR. If you contact us by e-mail, you can object to the storage of personal data at any time. Data subjects: Communication partner (Recipients of emails, letters, etc.), Customers, Prospective customers.
Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. text input, photographs, videos), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
Provision of our Services
We process data of our customers and business partners (collectively referred to as “contractual partners”) within the context of contractual and comparable legal relationships as well as associated actions and communication with the contractual partners or pre-contractually, e.g. to answer inquiries and assess potential customers.
We process this data in order to fulfil our contractual obligations, safeguard our rights and for the purposes of the administrative tasks associated with this data and the business-related organisation. We will only pass on the data of the contractual partners within the scope of the applicable law to third parties insofar as this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of data subjects concerned (e.g. telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about further processing, e.g. for marketing purposes, as part of this privacy policy.
Which data are necessary for the aforementioned purposes, we inform the contracting partners before or in the context of the data collection, e.g. in online forms by special marking and/or symbols (e.g. asterisks or the like), or personally.
Refer to Table 1 for data retention periods. We delete the data after expiry of statutory warranty and comparable obligations, unless the data must be kept for legal reasons of archiving (e.g., as a rule 10 years for tax purposes).
If we use third-party providers or platforms to provide our services, the terms and conditions and privacy policies of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.
- Data subjects: Prospective customers, Business and contractual partners, Customers.
- Purposes of Processing: Assessment of prospective customers, Provision of contractual services and customer support, Contact requests and communication, Office and organisational procedures, Managing and responding to inquiries, Security measures.
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Other Online Services
Video Conferences, Online Meetings, Webinars
We use third-party platforms and applications (hereinafter referred to as “third party providers”) for the purposes of conducting video and audio conferences, webinars and other types of video and audio meetings. When selecting third-party providers and their services, we observe the legal requirements.
In this context, data of the communication participants will be processed and stored on the servers of third parties, as long as these are part of communication processes with us. This data may include, but is not limited to, registration and contact details, visual and voice contributions, chat entries and shared screen content.
If users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party provider processing may process usage data and metadata that can be processed by them for security purposes, service optimisation or marketing purposes. We therefore ask you to observe the data protection information of the respective third party providers.
- Legal basis: If we ask the users for their consent to the use of third party providers or certain functions (e.g. permission to record conversations), the legal basis of the processing is consent. Furthermore, the processing can be a component of our (pre)contractual services, provided that the use of the third party was agreed within this context. Otherwise, user data will be processed on the basis of our legitimate interest in efficient and secure communication with our communication partners. In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. text input, photographs, videos), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
Data subjects: Communication partners, Users (e.g. users of online webinar services).
Purposes of Processing: Provision of contractual services and customer support, Contact requests and communication, Office and organisational procedures, Direct marketing (e.g. by e-mail or postal).
Legal Basis: Consent (Article 6 (1) (a) GDPR), Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Services and service providers being used:
Google Hangouts / Meet: Messenger and conference software; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://hangouts.google.com/; Privacy Policy: https://policies.google.com/privacy.
Zoom: Video Conferencing, Web Conferencing and Webinars; Service provider: Zoom Video Communications, Inc., 55 Almaden Blvd., Suite 600, San Jose, CA 95113, USA; Website: https://zoom.us; Privacy Policy: https://zoom.us/docs/de-de/privacy-and-legal.html; Standard Contractual Clauses (Safeguarding the level of data protection when processing data in third countries): https://zoom.us/docs/de-de/privacy-and-legal.html (referred to as Global DPA).
YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Privacy Policy: https://policies.google.com/privacy; Opt-Out: https://adssettings.google.com/authenticated.
Newsletter and Electronic Communications
We send newsletters, emails and other electronic communications (hereinafter referred to as “newsletters”) only with the consent of the recipient or a legal permission. Insofar as the contents of the newsletter are specifically described within the framework of registration, they are decisive for the consent of the user. Otherwise, our newsletters contain information about our services and us.
In order to subscribe to our newsletters, it is generally sufficient to enter your email address. We may, however, ask you to provide a name for the purpose of contacting you personally in the newsletter or to provide further information if this is required for the purposes of the newsletter.
The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes storing the login and confirmation times as well as the IP address. Likewise the changes of your data stored with the dispatch service provider are logged.
- Deletion and restriction of processing: See Table 1. We may store the unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to provide evidence of prior consent. The processing of these data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the case of an obligation to permanently observe an objection, we reserve the right to store the email address solely for this purpose in a blocklist.
- Legal basis: The sending of the newsletter is based on the consent of the recipients or, if consent is not required, on the basis of our legitimate interests in direct marketing. Insofar as we engage a service provider for sending emails, this is done on the basis of our legitimate interests. The registration procedure is recorded on the basis of our legitimate interests for the purpose of demonstrating that it has been conducted in accordance with the law.
- Measurement of opening rates and click rates: The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file, which is retrieved from our server when the newsletter is opened or, if we use a mailing service provider, from its server. Within the scope of this retrieval, technical information such as information about the browser and your system, as well as your IP address and time of retrieval are first collected.This information is used for the technical improvement of our newsletter on the basis of technical data or target groups and their reading behaviour on the basis of their retrieval points (which can be determined with the help of the IP address) or access times. This analysis also includes determining whether newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until the profiles are deleted. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The measurement of opening rates and click rates as well as the storage of the measurement results in the profiles of the users and their further processing are based on the consent of the users.
A separate objection to the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled or objected to. In this case, the stored profile information will be deleted.
Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Meta/communication data (e.g. device information, IP addresses), Usage data (e.g. websites visited, interest in content, access times).
Data subjects: Communication partner (Recipients of emails, letters, etc.), Customers (e.g. website visitors, users of online services, retreat participants).
Purposes of Processing: Direct marketing (e.g. by e-mail or postal), Web Analytics (e.g. access statistics, recognition of returning visitors), Targeting (e.g. profiling based on interests and behaviour, use of cookies), Remarketing, Conversion tracking (Measurement of the effectiveness of marketing activities).
Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Opt-Out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options listed above, preferably e-mail.
Services and service providers being used:
Google Analytics: Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/en/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Advertisements: https://adssettings.google.com/authenticated.
- MailerLite: Service provider: MailerLite Limited, 38 Mount Street Upper, Dublin 2, D02 PR89 Ireland, Website: https://www.mailerlite.com/ Privacy Policy: https://www.mailerlite.com/legal/privacy-policy
Google Mail: Mail provider / Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/en/about/analytics/; Privacy Policy: https://policies.google.com/privacy.
Presence in social media
We maintain profiles or fan pages in social media. When you use and call up our profile in the respective network, the respective data protection information and terms of use of the respective network apply.
- Data categories and description of data processing: usage data, contact data, content data, inventory data. Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behavior and interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them). For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks. In the case of requests for information and the assertion of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need assistance, then you can contact us.
- Purpose of processing: communication with users connected and registered on the social networks; information and advertising for our products, offers and services; external presentation and image cultivation; evaluation and analysis of the users and content of our presences in the social media.
- Legal basis: The legal basis for the processing of personal data is our legitimate interest in the above purposes pursuant to Art. 6 (1) p. 1 lit. f) GDPR. Insofar as you have given us or the responsible party of the social network consent to the processing of your personal data, the legal basis is Art. 6 para. 1 p. 1 lit. a) in conjunction with. Art. 7 GDPR.
- Data transfer/recipient category: Social network.
The data protection notices, information options and objection options (opt-out) of the respective networks / service providers can be found here:- LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland) – Privacy policy: https://www.linkedin.com/legal/privacy-policy, Cookie policy and Opt-Out: https://www.linkedin.com/legal/cookie-policy
- Instagram: Social network and video platform; Service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.instagram.com/; Privacy Policy: https://privacycenter.instagram.com/policy/?entry_point=ig_help_center_data_policy_redirect
Management, Administration, and Organisation
We use services, platforms and software from other providers (hereinafter referred to as ” third-party providers”) for the purposes of organising, administering, planning and providing our services. When selecting third-party providers and their services, we comply with the legal requirements.
Within this context, personal data may be processed and stored on the servers of third-party providers. This may include various data that we process in accordance with this privacy policy. This data may include in particular master data and contact data of users, data on processes, contracts, other processes and their contents.
If users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party provider may process usage data and metadata that can be processed by them for security purposes, service optimisation or marketing purposes. We therefore ask you to read the data protection notices of the respective third party providers.
Information on legal basis: If we ask the users for their consent to the use of third party providers, the legal basis of the processing is consent. Furthermore, the processing can be a component of our (pre)contractual services, provided that the use of the third party was agreed within this context. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. text input, photographs, videos), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
Data subjects: Communication partner (Recipients of emails, letters, etc.), Users (e.g. website visitors, users of online services).
Purposes of Processing: Office and organisational procedures.
Legal Basis: Consent (Article 6 (1) (a) GDPR), Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Services and service providers being used:
Calendly: Online scheduling; Service provider: Calendly LLC., 271 17th St NW, Ste 1000, Atlanta, Georgia, 30363, USA; Website: https://calendly.com; Privacy Policy: https://calendly.com/pages/privacy.
- Pandadoc: Online signature; Service provider: PandaDoc, Inc., 3739 Balboa Street, Suite #1083, San Francisco, CA 94121, USA; Website: https://www.pandadoc.com/; Privacy Policy: https://www.pandadoc.com/privacy-notice/#about
Rights of the data subject
Objection or revocation to the processing of your data
Insofar as the processing is based on your consent pursuant to Art. 6 (1) p. 1 lit. a), Art. 7 GDPR, you have the right to revoke your consent at any time. This does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
Insofar as we base the processing of your personal data on the balance of interests pursuant to Art. 6 (1) p. 1 lit. f) GDPR, you may object to the processing. This is the case if the processing is not necessary, in particular, for the performance of a contract with you, which is presented by us in each case in the following description of the functions. When exercising such an objection, we ask you to explain the reasons why we should not process your personal data as we have done. In the event of your justified objection, we will examine the merits of the case and either discontinue or adapt the data processing or show you our compelling legitimate grounds on the basis of which we will continue the processing.
You may object to the processing of your personal data for purposes of advertising and data analysis at any time. You can exercise the right to object free of charge. You can inform us of your advertising objection using the following contact details:
Evolute Institute B.V.
Korte Lijnbaanssteeg 1
Office no. 4277
1012SL, Amsterdam
The Netherlands
E-mail address: [email protected]
Right to information
You have the right to request confirmation from us as to whether personal data relating to you is being processed. If this is the case, you have the right to information about your personal data stored by us in accordance with Art. 15 DS-GVO. This includes, in particular, information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the origin of your data if it has not been collected directly from you.
Right to rectification
You have a right to have incorrect data corrected or correct data completed in accordance with Art. 16 GDPR.
Right to deletion
You have a right to have your data stored by us deleted in accordance with Art. 17 GDPR, unless legal or contractual retention periods or other legal obligations or rights to further storage prevent this.
Right to restriction
You have the right to request a restriction in the processing of your personal data if one of the conditions in Art. 18 (1) a) to d) GDPR is met:
– If you dispute the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
– the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
– the controller no longer needs the personal data for the purposes of processing, but you need them for the establishment, exercise or defense of legal claims; or
– if you have objected to the processing pursuant to Article 21 (1) GDPR and it is not yet clear whether the legitimate grounds of the controller outweigh your grounds.
Right to data portability
You have a right to data portability pursuant to Art. 20 GDPR, which means that you can receive the personal data we hold about you in a structured, common and machine-readable format or request that it be transferred to another controller.
Right to complain
You have a right to lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority for this purpose, in particular in the Member State of your residence, workplace or the place of the alleged infringement.
Data security
In order to protect all personal data transmitted to us and to ensure that data protection regulations are complied with by us, as well as by our external service providers, we have taken appropriate technical and organizational security measures. Therefore, among other things, all data between your browser and our server is transmitted encrypted via a secure SSL connection.
People Under the Age of 18
Our Website and our services are not intended for anyone under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from anyone under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a person under 18 without verification of parental consent, we will delete that information.
Changes and Updates to the Privacy Policy
We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organisations in this privacy policy, we ask you to note that addresses may change over time and to verify the information before contacting us.
Last updated: March 2024