Evolve Limited is committed to protecting your personal information.
Who we are
We are the data controller responsible for your personal data and we are registered with the Information Commissioner’s Office with reference number XXXXXXXX.
We have appointed a data protection officer (“DPO”). Our DPO has a number of important responsibilities including:
- monitoring Evolve’s compliance with the GDPR and other data protection laws;
- raising awareness of data protection issues, training Evolve staff and conducting internal audits; and
- cooperating with supervisory authorities such as the ICO on our behalf.
How to contact us
FAO Data Protection Officer
24 Rose Street,
Information we collect and use
Information about you that we collect and use includes:
- Information about who you are e.g. your name, date of birth and contact details
- Information connected to your product or service with us e.g. qualifications
- Information about your contact with us e.g. meetings, phone calls, emails
- Information that is automatically collected e.g. via cookies when you visit one of our websites
A cookie is a small file, it’s saved onto your computer or other device when you visit our website.
Cookies store small pieces of information. For example, they will remember you’ve visited our website or performed a certain action.
Cookies also let us know which pages of our website you visited; they help us develop and market our products and services.
- Persistent cookies – these stay valid, and will work until their expiry date (unless you delete them before they expire)
- Session cookies – these expire when you close your web browser
Where we collect your information
We may collect your personal information directly from you, from a variety of sources, including:
- an application form for a product or service
- phone conversations with us
- emails you send to us
- meetings with one of our advisors
- participating in research surveys to help us understand you better and improve our products and services
- our online services, for example our website or online applcations
If you are a guest to our systems, the information we collect and use will have been provided by the license holder on your behalf.
We may also collect personal information on you from places such as business directories and other commercially or publicly available sources e.g. to check or improve the information we hold (like your email) or to give better contact information if we are unable to contact you directly.
What we collect and use your information for
We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:
- you have given us your permission [consent] to send you information about products and services offered by Evolve and/or selected third parties we have chosen to work with which we believe may be of interest and benefit to you
- it’s necessary to provide the product or service you have purchased, licensed or been given guest access
- it’s necessary for us to meet our legal or regulatory obligations e.g. tell you about changes to Terms and Conditions
- it’s in the legitimate interests of Evolve, for example:
- to deliver appropriate information and guidance, allowing you to get the best outcome from our product or service
- where we need to process your information to better understand you and your needs, allowing us to send you more relevant communications about Evolve products and servces
- using artificial intelligence or computer algorithms to improve the products and services offered to you
- to develop new products and services
If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our products or services.
Who we may share your information with
We may share your information with third parties for the reasons outlined in ‘What we collect and use your information for.’
These third parties include:
- Companies within Evolve
- Your employer
- Companies we have chosen to support us in the delivery of the products and services we offer to you and other customers e.g. research, consultancy or technology companies; or companies who can help us in our contact with you, for example an internet service provider
We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.
Where your information is processed
The majority of your information is processed in the UK and European Economic Area (EEA).
However, some of your information may be processed by us or the third parties we work with outside of the EEA, including countries such as the United States and Switzerland.
Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK/EEA data privacy laws e.g. we will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations.
How we protect your information
We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.
Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically.
Our security controls are aligned with good practice, providing a controlled environment that effectively manages risks to the confidentiality, integrity and availability of your information.
How long we keep your information
We will keep your personal information only where it is necessary to provide you with our products or services while you are a customer.
We may also keep your information after this period but only where required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.
Your individual rights
You have several rights in relation to how Evolve uses your information. They are:
Right to be informed
Right of access
You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (DSAR).
Right to request that your personal information be rectified
If your personal information is inaccurate or incomplete, you can request that it is corrected.
Right to request erasure
You can ask for your information to be deleted or removed if there is not a compelling reason for Evolve to continue to have it.
Right to restrict processing
You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.
Right to data portability
You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way.
Right to object
You can object to Evolve processing your personal information where: it’s based on our legitimate interests (including profiling); for direct marketing (including profiling); and if we were using it for scientific/historical research and statistics.
How to make a complaint
If you are still unhappy, you can complain to our Supervisory Authority. Their contact details are:
UK – ICO