Privacy

Privacy Policy

This Privacy Policy (“Privacy Policy”) is designed to inform you as to how Evinced Inc. (referred to as the “Evinced”, “Company”, “we”, “us” or “our” in this Privacy Policy) handles your Personal Data in connection with your visit to our website https://www.evinced.com/ (“Website”). “Personal Data” shall mean any information about an individual from which that person can be identified.

Evinced offers AI fueled digital accessibility automation services to enterprise developers to weave accessibility into all facets of software development, including design, development, automated testing, QA testing, and production monitoring (the “Services”).

To the extent that the European General Data Protection Regulation (“GDPR”) or the United Kingdom General Data Protection Regulation (“UK GDPR”) apply to Personal Data that we process in accordance with this Privacy Policy, we act as act as a “data controller” with respect to such processing. To the extent that the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”) applies, we act as a “business”.

We encourage you to read this Privacy Policy carefully and to regularly check this page to review any changes we might make to the terms of this Privacy Policy. This Privacy Policy supplements other policies we may provide as part of our interactions with you or policies you may have received from other controllers and is not intended to override such policies.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below.

The Data We Collect About You
How We Collect Your Personal Data
How We Use Your Personal Data
Sharing Your Personal Data with Third Parties
Minors
International Transfers
Data Security
Data Retention
Your Rights
Accessibility
Contact Details
Changes to this Privacy Policy

If you are a resident of the state of California, please read the Privacy Notice for California Residents.

1. The Data We Collect About You

When you use our Website or contact us through it, we may collect the following types of Personal Data on you:

Identity Data includes your first and last name.
Contact Data includes your email address and telephone number.
Business Data includes your company name, industry and position.
Location Data includes your country/region.
Candidate Data (relevant to career applicants) includes contact information, address, Curriculum Vitae (resumé) information (including information such as skills, work experience, education), notes submitted with the application, URL of your LinkedIn and other online profiles, the position for which you have been or are being considered, the source who submitted your candidacy (e.g., recruiting agency, referral), email correspondences between you and the Company and between the Company and other sources (such as recruiting agency and referrals) about your candidacy, information from references, events in the lifecycle of your candidacy, your responses to questionnaires sent to you by us, information about your candidacy and employment options (such as availability to be hired and salary expectations), evaluations of your candidacy, internal discussions within the Company about your candidacy, and materials you or other parties (such as evaluators or background check providers) submitted in relation to your candidacy.
Usage Data includes information about how you use or interact with our Website (such as, when you entered the Website, how long you stayed on the Website and/or a specific page on the Website).
Technical Data includes information on your internet connection (such as your IP address and internet service provider name), on the device and software that you are using to access the Website (e.g., your web browser type and computer operating system).
Additional Inquiry Data includes additional information that you may provide when you contact us through the Website or when you use any of our Services.

We also collect, use and share aggregated data such as statistical data for any purpose. Such information does not reveal your identity and therefore is not considered Personal Data. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature available through the Website.

Protecting the Privacy Rights of Third Parties

If you provide us any Personal Data relating to others, you must make sure that you have permission to do so.

2. How We Collect Your Personal Data

We use different methods to collect data from and about you including through:

Direct interactions. When you contact us or otherwise provide your Personal Data directly to us.
Automated technologies or interactions. As you interact with our Website, we automatically collect the applicable Technical Data and Usage Data. We collect this data by using cookies, server logs, and other similar technologies.
Third parties or publicly available sources. We may receive Contact Data, Technical Data and Usage Data about you from third parties, such as Usage Data and Technical Data that we may receive from analytics providers, and from advertising and marketing partners, and Contact Data that we may receive from providers of B2B contact information. Your Candidate Data can also originate from other sources, such as your LinkedIn profile, recruitment agencies, headhunters and referrals.

You are not legally obligated to provide any Personal Data to Evinced. Any Personal Data that you choose to provide to Evinced, is provided at your own free will.

3. How We Use Your Personal Data

We will only use your Personal Data when permitted by law. We will commonly use your Personal Data in the following circumstances:

Where the processing is necessary in connection with the performance of any contract we have entered into with you or where it is necessary for taking steps at your request prior to entering a contract.
Where the processing is necessary for our legitimate interests (or those of a third party), and such legitimate interests are not overridden by your interests, fundamental rights, or freedoms. Legitimate interest means our interest in managing and conducting our business.
Where the processing is necessary for compliance with a legal or regulatory obligation.
Where you have provided your consent for such processing. Such consent can be revoked at any time.

Purposes for Which We Use Your Personal Data

Below is a description of the ways we use your Personal Data. To the extent that the GDPR and UK GDPR apply, we have mentioned the legal bases we rely on to use your Personal Data, and identified what our legitimate interests are where appropriate:

We use your Identity Data, Contact Data, Business Data, Location Data and/or Candidate Data to enter into a contract or to perform a contract with you. We also use your Usage Data and Technical Data for the performance of a contract with you (to provide our Services to you via the Website).
We use your Contact Data and Additional Inquiry Data to respond to your requests or questions, including in connection with the Services, and to manage our relationship with you, including by notifying you about changes to our Terms & Conditions or Privacy Policy. We do so for the performance of a contract with you, if it is necessary to comply with a legal obligation or if it is necessary for our legitimate interests.
We use your Usage Data, Technical Data, and Contact Data for marketing purposes, to deliver relevant and personalized content to you, send service messages (for example, for security purposes) and to measure or understand the effectiveness of our marketing efforts. We do so where it is necessary for our legitimate interests (to grow our business, to inform our marketing strategy and to maintain and secure the Services); or if we have obtained your prior consent (where laws require consent for such communications).
We use your Usage Data and Technical Data to improve our Website, Services, marketing, customer relationships and experiences, including by personalizing and customizing our content. We do so where it is necessary for our legitimate interests (to keep our Website updated and relevant, to develop our business and to inform our marketing strategy).
We use your Identity Data, Contact Data and Candidate Data to consider your application for career opportunities at the Company. We do so where it is necessary for our legitimate interests (recruitment of personnel and handling career applications) and to take steps prior to entering a contract with you.
In the event of a legal dispute between you (and/or a party on your behalf) to us (and/or a party on our behalf), we may use your Personal Data to the extent necessary in connection with handling such dispute. We do so where it is necessary for our legitimate interests (to defend and enforce our legal rights).
We may also use your Personal Data as: (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our Terms & Conditions, to maintain security of the Website and prevent fraudulent or illegal activity; (d) necessary to protect us from legal action or claims from third parties, including you and/or other users; or (e) necessary to protect the legal rights, personal/real property, or personal safety of the Company, users, employees, and affiliates. We do so based on our legitimate interest (to defend and enforce our legal rights and to protect and ensure the continuous operation of our Website).

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data.

Promotional Offers

You may receive marketing communications from us if you have requested information from us and you have not opted out of receiving marketing communications.

If you wish to stop receiving marketing communications from us, you may ask us to stop sending you marketing communications at any time by following the opt-out or unsubscribe link on any marketing message sent to you.

Cookies and Other Tracking Technologies

Our Website uses cookies. A cookie is a small piece of data or a text file that is downloaded to your computer or mobile device when you access certain websites. Cookies may contain text that can be read by the web server that delivered the cookie to you. The text contained in the cookie generally consists of a sequence of letters and numbers that uniquely identifies your computer or mobile device; it may contain other information as well. By agreeing to accept our use of cookies, you are giving us, and third parties we partner with, permission to place, store, and access some or all the cookies described below on your computer.

Types of cookies:

Strictly Necessary Cookies. These cookies are necessary for proper functioning of the Website, such as displaying content, logging in, validating your session, responding to your request for Services, and other functions.
Performance Cookies. These cookies collect information about the use of the Website, such as pages visited, traffic sources, users’ interests, content management, and other Website measurements.
Functional Cookies. These cookies enable the Website to remember a user’s choices – such as their language, user name, and other personal choices – while using the Website. They can also be used to deliver products or services, such as letting a user listen to audio or watch videos on the Website.
Media Cookies. These cookies can be used to improve the Website’s performance and provide special features and content. They can be placed by third parties who provide services to us or by our company.
Advertising or Targeting Cookies. These cookies are usually placed and used by advertising companies to develop a profile of your browsing interests and serve advertisements on other websites that are related to your interests. You will see less advertising if you disable these cookies.
Session Cookies. These cookies allow websites to link the actions of a user during a browser session. Session cookies permit users to be recognized as they navigate a website so that any item or page changes they make are remembered from page to page. Session cookies expire after a browser session; thus, they are not stored long term.
Persistent Cookies. These cookies are stored on a user’s device in between browser sessions, which allows the user’s preferences or actions across a site (or, in some cases, across different sites) to be remembered. Persistent cookies may be used for a variety of purposes, including remembering users’ choices and preferences when using a website or to target advertising to them.

Most web browsers can be set to disable the use of cookies. However, if you disable cookies, you may not be able to access features on our Website correctly or at all. Further details on how to disable cookies in different web browsers can be found here:

Internet Explorer: http://windows.microsoft.com/en-GB/internet-explorer/delete-manage-cookies

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer#w_cookie-settings

Safari: http://help.apple.com/safari/mac/8.0/#/sfri11471

Microsoft Edge: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

Opera: https://help.opera.com/en/latest/web-preferences/

In addition, our Website may use Google Analytics (or similar service providers) to collect information about the use of our Website. Google Analytics collects information from users such as age, gender, interests, demographics, how often they visit our Website, what pages they visit, and what other websites they have used before coming to our Website. We use the information we get from Google Analytics to analyze traffic, remarket our Services to users, improve our marketing, advertising, and to improve our Website. We have enabled Google Analytics advertising features such as remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. For more information on how Google collects and processes your data, visit https://www.google.com/policies/privacy/partners/. Google provides website visitors the ability to prevent their data from being used by Google Analytics. For more information see: https://tools.google.com/dlpage/gaoptout.

We may also use a technology called web beacons to collect general information about your use of our Website and your use of special promotions or newsletters. The information we collect by web beacons allows us to statistically monitor the number of people who open our emails. Web beacons also help us to understand the behavior of our customers, members, and visitors.

Third parties may use cookies, web beacons, and other storage technologies to collect or receive information from our Website and elsewhere on the internet, and use that information to provide measurement services and target ads.

Third-Party Links

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or interacting with such content may allow your data to be shared with the relevant third-party. We do not control these third-party websites and are not responsible for their privacy statements; we therefore recommend that you read the privacy policy of every websites you visit.

We work with data processors to whom we have instructed to collect, store and process Personal Data on our behalf for the purposes of providing our Services, for example, Comeet, as a recruiting and applicant tracking platform in order to handle Personal Data of job applicants. We store and process personal information related to you in the United States and Israel, including sites operated and maintained by cloud-based hosting service providers in the U.S.

We may share your applicable Identity Data, Contact Data, Usage Data and Technical Data with web analytics providers, email and marketing service providers and other vendors that assist us in maintaining the Website. For additional information, please see the description above in the section titled Cookies and Other Tracking Technologies.
We share Personal Data with additional third party service providers that provide us services in connection with the purposes listed in the “How We Use Your Personal Data” section above, including, providers of career application management platforms (like Comeet) in the context of your career application. These companies are authorized to use your Personal Data as necessary to provide these services or as otherwise authorized by us. Comeet’s privacy policy is available here.
If your Candidate Data is submitted to the Company by a third-party (such as an employee of the Company or a recruiting agency), the Company can give the third-party access to your name, photo and your general recruitment status.
If you apply to a job opening using a unique referral link that was provided to you by an employee of the Company, the Company may share some of your general recruitment status, without identifying you by name, with the person that provided you the referral link. The purpose of sharing the above information is to operate incentive programs (i.e. employee referral bonus programs) of the Company and to provide feedback to third-parties who submit candidates to the Company regarding their submission.
Personal Data may be shared with, or transferred to, our affiliated corporate group entities (entities controlled by, under common control with, or controlling us, directly or indirectly), for the purposes listed in the “How We Use Your Personal Data” section above.
We further may share your Personal Data with Evinced’s business partners to offer you additional Services or products.

We may also share your Personal Data with legal and regulatory authorities to the extent required by applicable law our professional advisors (e.g. lawyers, accountants) to the extent necessary for the provision of their services to us; and third parties to whom we may choose to sell, transfer, or merge our business (or parts thereof) or our assets, or parties whose business we wish to acquire.

5. Minors

We do not intend to collect Personal Data of anyone under the age of 18 and we do not knowingly collect Personal Data from children.

If you are a parent or legal guardian and have concerns about your child’s privacy, or if you believe that your child may have provided us with their Personal Data, please contact us using the Contact Details below. When you approach us as a parent or legal guardian, we may request that you provide certain information needed to confirm your identity.

6. International Transfers

We may transfer your Personal Data to countries outside of the country in which you reside (including outside of the European Economic Area (EEA) or the United Kingdom (UK)), that do not necessarily provide the same level of data protection as the country in which you reside and are not recognized by the European Commission and/or the applicable UK authority as providing an adequate level of data protection.

Our transfers of Personal Data outside of the EEA or the UK are done for the performance of a contract or implementation of pre-contractual relations with you, based on your consent, or subject to safeguards that ensure the protection of your Personal Data, such as standard contractual clauses approved by the European Commission and/or the applicable UK authority.

7. Data Security

We have put in place security measures intended to prevent your Personal Data from accidental or unlawful loss, use, alteration or disclosure. We also maintain reasonable technical and physical safeguards to protect your Personal Data. Unfortunately, we cannot guarantee against the loss or misuse of your Personal Data or secure data transmission over the Internet because of its nature.

8. Data Retention

We retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for legal or reporting requirements.

In order to determine the appropriate retention period for Personal Data, we consider the following criteria: the volume, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of Personal Data, the purposes for which we collect and process Personal Data, the timeframe during which we may require such Personal Data in connection with potential litigation, and applicable legal requirements.

9. Your Rights

Certain privacy laws, including the GDPR and UK GDPR, provide users with rights related to their Personal Data. To the extent that such laws apply to your Personal Data, you may have the following rights:

Request access. This means that you may receive a copy of the Personal Data we hold about you.
Request correction. This means that you may ask us to correct or complete inaccurate or incomplete data that we hold about you.
Request erasure. This means that you may ask us to delete or remove Personal Data that we hold about you. If we are unable to comply with such request, we will notify you of the specific legal reasons for our decision.
Object to processing. This means that you may object to the processing of your Personal Data where it is used for direct marketing purposes, or where we are relying on a legitimate interest and you feel that such interest is overridden by your rights and freedoms.
Request restriction of processing. This means that you may ask us to suspend the processing of your Personal Data if you believe that such data is inaccurate, if our processing is unlawful or if we no longer need to process such data for a particular purpose, but you need us to continue to hold the data.
Data Portability. This means that you may request that we transfer your Personal Data to you or to a third party. This right applies where we have obtained and processed the data from you based on your consent or where we used the information to perform a contract with you.
Withdraw consent at any time. This means that you may withdraw your consent where we are processing your Personal Data based on your consent.

If you wish to exercise any of the rights set out above, please contact us.

What We May Need From You

When you approach us with a request to exercise one of your rights, we may request that you provide us with information needed to confirm your identity as a security measure to ensure that your Personal Data is not disclosed to any person who has no right to receive it.

Time Limit to Respond

We try to respond to all legitimate requests within one month or less, if required by law. Where it takes us more than one month to respond (for example, where your request is particularly complicated or where you have made a number of requests) we will notify you and keep you updated.

10. Accessibility

If you have a disability and would like to access this policy in an alternative format, please contact us via our Contact Details listed below.

11. Contact Details

If you have any questions or concerns, please contact us at:

Email: privacy@evinced.com

You have the right to make a complaint at any time to data protection authorities. We would, however, appreciate the chance to address your concerns before you approach a data protection authority, so please contact us in the first instance.

12. Changes to this Privacy Policy

We reserve the right to change this Privacy Policy at any time. If we do so, we will post an updated version of this Privacy Policy so that our users and customers are always aware of what information we collect, use, and disclose. Your continued use of our Website and Services after any change to this Privacy Policy will constitute your acceptance of such change.

This version was last updated on July 18 2023.

Privacy Notice for California Residents

Scope

The CCPA provides California residents with specific rights regarding their Personal Data. This section applies only to users that are California residents, describes the rights under the CCPA and explains how to exercise those rights. This section does not apply to our handling of publicly available information from government records, de-identified or aggregated information or other information that is excluded from the CCPA’s scope. The term “Personal Information” shall have the meaning ascribed to it under the CCPA.

Personal Information We Collect, Use and Disclose

We may collect the categories of Personal Information listed below. We do not collect sensitive Personal Information. For each category, the source of the Personal Information, the business purposes for which it will be processed and the third parties to whom it may be disclosed are listed.

Identifiers, such as name, email address and IP address.

Business Purposes
- Enter into a contract or to perform a contract with you.
- Respond to your requests or questions and to manage our relationship with you, including by notifying you about changes to our Terms & Conditions or Privacy Policy (“Relationship Management and Response to Requests”).
- Marketing purposes, to deliver relevant and personalized content to you, send service messages, and to measure or understand the effectiveness of our marketing efforts (“Marketing Purposes”).
- In the event of a legal dispute between you (and/or a party on your behalf) to us (and/or a party on our behalf), in connection with handling such dispute (“Handling of Disputes”).
- Compliance related purposes, including: (a) as required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our Terms & Conditions, to maintain security of the Website and prevent fraudulent or illegal activity; (d) necessary to protect us from legal action or claims from third parties, including you and/or other users; or (e) necessary to protect the legal rights, personal/real property, or personal safety of our company, users, employees, and affiliates (“Compliance Purposes”).
Source
- When you contact us through our Website, subscribe to our communications, or otherwise provide such information directly to us (“Direct Interactions”).
- As you interact with our Website, we automatically collect applicable your IP address. We collect this data by using cookies, server logs, and other similar technologies (“Automated Interactions”).
- Reference providers, such as past employers, and publicly available sources.

Internet or other electronic network activity information, including, but not limited to, information regarding your interaction with the Website, or advertisement.

Business Purposes
- Marketing Purposes.
- Improve our Website, Services, marketing, customer relationships and experiences, including by personalizing and customizing our content.
- Handling of Disputes.
- Compliance Purposes.
Source
- Automated Interactions.
- We may receive such information from third parties, such as analytics providers and advertising or marketing partners, or from publicly available sources (“Third Parties”).

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, telephone number, and employment history.

Business Purposes
- Enter into a contract or to perform a contract with you.
- Relationship Management and Response to Requests
- Marketing Purposes.
- Handling of Disputes.
- Compliance Purposes.
Source
- Direct Interactions.

Inferences drawn from other Personal Information, such as a profile of a person’s preferences.

Business Purposes
- Marketing Purposes.
- Improve our Website, Services, marketing, customer relationships and experiences, including by personalizing and customizing our content.
- Handling of Disputes.
- Compliance Purposes.
Source
- Automated Interactions.
- Third Parties.

Disclosure to third parties (relating to the categories aforementioned)

Third party service providers that provide services to us in connection with the aforementioned business purposes, such as cloud storage providers (“Service Providers”).
Web analytics providers, email and marketing service providers and other vendors that assist us in maintaining the Website.
Business partners that can offer you additional services or products.
Legal and regulatory authorities, to the extent required by applicable law (“Authorities”).
Professional advisors (e.g. lawyers, accountants), to the extent necessary for the provision of their services to us.
Third parties that have submitted your details to the Company, or an employee of the Company whose referral link was used for the submission.
Third parties to whom we may choose to sell, transfer, or merge our business (or parts thereof) or our assets, or parties whose business we wish to acquire (“M**&A Counterparts**”).

Professional or employment related information (relevant to career applicants), such as current or past employment history.

Business Purposes
- Enter into a contract or to perform a contract with you.
- Handling of Disputes.
- Compliance Purposes.
Source
- Direct Interactions.
- Reference providers, such as past employers, and publicly available sources.
Disclosure to third parties
- Service Providers.
- Authorities
- Professional advisors.
- M&A Counterparts

This section describes our current practices and our practices during the 12 months preceding the “Last Updated” date of this Policy.

If you provide us any Personal Information relating to others, you must make sure that you have permission to do so.

Opt-out of the sale or sharing of Personal Information (“do not sell” / “do not share”)

We do not sell Personal Information or share it with third parties for cross-context behavioral advertising, and have not done so in the past 12 months.

We do not knowingly sell, or share with third parties for cross-context behavioral advertising, Personal Information of consumers under 16 years of age.

Data Retention

We retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for legal or reporting requirements.

In order to determine the appropriate retention period for Personal Information, we consider the following criteria: the volume, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, the purposes for which we collect and process Personal Information, the timeframe during which we may require such Personal Information in connection with potential litigation, and applicable legal requirements.

Our California Do Not Track Policy

Some browsers transmit “do-not-track” signals to websites. Because of differences in how browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

Your California Privacy Rights under CCPA/CPRA

Right to Know and Data Portability: you have the right to request certain information regarding our collection and use of Personal Information, and disclosure of Personal Information to third parties.
Right to Deletion and Rectification: you have the right to request that we delete any of your Personal Information that we collected from you and retained or that we correct inaccurate Personal Information we retained. We shall use commercially reasonable efforts to correct such inaccurate Personal Information. We may deny your deletion request in certain defined cases, for example, if retaining the data is necessary for us or our service providers to perform our contract with you, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, debug products, exercise free speech, engage in research, enable internal uses or comply with applicable laws and legal obligations.
Non-discrimination: limiting the use of your Personal Information may affect features and uses that rely on that data. You have a right not to receive discriminatory treatment by us for the exercise of such privacy rights as conferred by the CCPA. Unless permitted by the CCPA, we will not: deny you goods or Services, provide you a different level or quality of goods or Services or suggest that you may receive a different price or rate for goods or Services or a different level or quality of goods or Services.
Automated decision-making: you will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have notified you and allowed you to opt-out.
Submitting Requests regarding Your Rights

To make a request regarding your rights as detailed above, please submit a request using one of the methods in the Contact Details section below.

You may use a legally authorized person on your behalf to submit a request, if you provide a signed written permission to such person. Your request to know or delete must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative and should describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are 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 contact us using one of the methods in the Contact Details section below.

Accessibility