Privacy Notice

Last Updated: November 2021

This Privacy Notice (“Notice”) explains how information is collected, used, and disclosed by Evidation Health, Inc. (“Evidation,” “we,” “us,” or “our”) in connection with your use of our website at www.evidation.com, or any other online services that link to this Notice (collectively, our “Services”). This Notice applies to only those websites, services, and applications included within the Services and does not apply to any third-party websites, services, or applications (including those of our Partners), even if accessible through the Services.

Evidation provides other offerings and services, which are not subject to this Notice. The Privacy Notice for our consumer platform “Evidation” that rewards healthy actions and helps users participate in research, is available at https://www.my.evidation.com/privacy. Participation in research or other programs, including sponsored programs, run by Evidation may be subject to specific informed consent and/or disclosures for the relevant research or other program. This Notice does not apply to such offerings, which are not part of the Services as defined herein.

When you use the Services, you consent to our collection, use, retention, disclosure, and protection of information about you as described in this Notice.

IF YOU DO NOT AGREE TO THIS NOTICE, PLEASE DO NOT USE THE SERVICES.

Information We Collect:

As a result of using the Services, you may either directly or indirectly, provide certain information to us.

The types of information we collect on the Services includes:

contact information (such as name, postal address, email address and phone number), typically from prospective or current customers;

other information you submit to us through the Services (such as information provided by filling in forms or sending us emails).

Automatically Collected Information:

When you utilize our Services, certain information is automatically collected. For example, we and our third party service providers may automatically collect your Internet Protocol (IP) address (and associated city and state or province for the IP address), computer operating system, browser type, other system settings, as well as the language your system uses and the country and time zone where your device is located, device identifiers, the website you visited before our Services, the number of clicks, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services and upload or post content, error logs, and other similar information. Even if you do not register with our Services, or submit information directly, our Services may collect this automatically collected information.

Location information: When you use the Services, we and our service providers may automatically collect general location information (e.g., IP address, city/state and or zip code associated with an IP address) from your computer or mobile device.

Cookies & similar technologies: We and our third-party service providers also collect information about you, your usage of the Services and your devices through cookies, web beacons, and similar technologies. A “cookie” is a small data file placed on your device to identify your device in the future and help us better understand user behavior, personalize preferences, perform research and analytics, deliver tailored advertising, and improve the products and services we provide. We, or our third-party service providers, may also use certain of these technologies in emails to end users, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded. A “session cookie” disappears after you close your web browser, or may expire after a fixed period of time. A “persistent cookie” remains after you close your web browser and may be accessed every time you use our Services. We and our third-party service providers may use both session and persistent cookies on our Services. You should consult your web browser to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, some features may be adversely affected up to and including being unable to use certain features of our Services.

We may utilize the services of third parties in conjunction with this automatically collected information. These third parties may collect information about you over time such as about your use of our Services, as well as your online activities across other websites or online services.

Online analytics: We may use third-party web analytics services, such as those provided by Google Analytics. These service providers use cookies and other technologies described in this Notice to help us analyze how users use our Services. The information collected by the technology will be disclosed to or collected directly by these service providers. To prevent Google Analytics from using information for analytics, a user may install the Google Analytics Opt-Out Browser Add-on by clicking here.

We neither have access to, nor does this Notice govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of ad targeting as described below.

Advertising: You may receive tailored advertising on your computer through a web browser. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative (NAI) NAI Opt-Out link, or the Digital Advertising Alliance’ (DAA) DAA Opt-Out link. to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page.

Do Not Track

We do not currently employ technologies that recognize “Do Not Track” signals from your browser.

How We Use Information

We use the information collected to provide our Services to you or as otherwise described in this Notice. For example, we may use your information to:Operate and improve our Services, including development of new features and functionalities;

Respond to your feedback, comments, or questions, or to otherwise send you information about our Services;

Analyze how you use and interact with our Services;

Protect our Services and the information collected against fraudulent, illegal, or otherwise unauthorized activity, including any investigation into such activity;

For any other purpose described in this Notice, or the Terms of Use.

We may combine information that we collect from you through the Services with information that we obtain from affiliated and non-affiliated third parties, and information derived from any other products or services we provide.

We may aggregate and/or de-identify information collected through the Services. We may use de-identified or aggregated data for any purpose.

How We Share Information

We will not sell, rent, or otherwise share your information with our clients without your express consent as detailed below.

In certain circumstances, we may share your information with our affiliates, service providers, and third-party business partners. For instance: 

Service Providers. We may share your information with third parties that help us operate our business and provide the Services, such as for email management, data hosting, analytics, fraud and safety protection and legal and accounting services. 

When Required by Law or as Necessary to Protect Our Users and Services. We may share information when we believe that doing so is necessary to protect, enforce, or defend the legal rights, privacy, safety, or property of Evidation, our employees or agents or users, or if we reasonably believe that is necessary in order to comply with laws, regulations, legal process (such as subpoenas or warrants), or any other legal or regulatory request. 

Business Transfers. We may disclose or transfer your information to a third party if we sell, transfer, divest, or disclose all or a portion of our business or assets to another company in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding or take steps in anticipation of such a transaction. Otherwise with Your Consent or at Your Direction. In addition to the sharing described in this Notice, we may share information about you with third parties whenever you consent to or direct such sharing.

Security

We use technical and administrative safeguards to protect the integrity of your information. No method of Internet transmission or via mobile device, or electronic storage, however, is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

Links to Other Sites

Our Services may contain links to other websites and services. Any information that you provide on or to a third-party website or service is provided directly to the owner of the website or service and is subject to that party’s privacy policy. Our Notice does not apply to such websites or services and we’re not responsible for the content, privacy or security practices and policies of those websites or services. To protect your information, we recommend that you carefully review the privacy policies of other websites and services that you access.

International Transfer

Your information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your information to us, we may transfer your information to the United States and process it there (or any other country in which we operate). Your submission of information using the Services represents your agreement to such transfer.

Singapore

For the purposes of the Personal Data Protection Act (“PDPA”), we are a “data intermediary” as defined in the Act. Our Singapore based Data Protection Officer can be contacted at singaporedpo@evidation.com.

European Economic Area

Individuals located in certain countries, including those countries within the European Economic Area, have certain statutory rights in relation to their information (“personal data”). If you are located in the EEA and/or are visiting this website from the EEA (or other applicable countries), under the EU General Data Protection Regulation (GDPR) we are considered a Controller of your personal data. When an Evidation customer licenses Evidation’s offerings or services, or when Evidation is otherwise acting on behalf of a customer, Evidation is considered a “processor” of the personal data, and Evidation’s customer is the “controller”. Subject to any exemptions provided by law, you may have the right to request access to personal data, as well as to seek its correction, update, or deletion. You may also have the right to object to our handling of their personal data and to withdraw any consent you have provided. Where we process personal data on behalf of a customer, we may refer the request to the relevant customer and cooperate with their handling of the request, subject to any special contractual arrangement with that customer. To exercise these rights, please contact us at the information provided below.

To the extent that our processing of your personal data is subject to the GDPR, we process such data pursuant to our legitimate business interests, because it is necessary for our contractual relationship, and/or with your consent. We may also process your personal data for direct marketing purposes, and you may object to our use of your personal data for such direct marketing purposes at any time. As a processor, we process personal data to meet our contractual commitments to our customers, for other purposes requested or permitted by our customers, and for legal compliance.

You can reach our Data Protection Officer at dpo@evidation.com. Additionally, for the purposes of Article 27 of the GDPR, we have appointed Reed Smith LLP as our EU Representative. Reed Smith are authorised to receive communications relating to our European personal data practices on our behalf. Reed Smith can be contacted using the following contact details:

Evidation Health Inc.

c/o Reed Smith LLP

Ref: COD/HS

The Broadgate Tower

20 Primrose Street

London EC2A 2RS

EvidationGDPRRep@reedsmith.com

California Privacy Information

Shine the Light.  California residents have the right under certain circumstances to request information from us regarding the sharing of certain categories of “personal information” (as defined by applicable California law) during the prior year to third parties for their direct marketing purposes. As noted above, we do not share your personal information with third parties for their direct marketing purposes unless we have your explicit permission. For any questions regarding this, please contact us at the information below.

California Consumer Privacy Act (CCPA). Under the CCPA, you have rights with respect to your personal information.  This includes the:

Right to Know:

You can request information about, and access to, personal information that we have collected, disclosed, or sold in the past 12 months, including the categories of

Requests can be made through webform, which can be accessed through your Evidation account, or by emailing help@evidation.com. All requests must be verified to ensure it is a valid request. You may also nominate an authorized agent to make a request under the CCPA on your behalf.

Additionally, we are required to inform California residents of the following:

Any queries or requests in relation to these rights can be made using the contact information listed below.

If you are a member of our Evidation consumer platform community and would like to learn more about how we handle personal information, you can read more in our separate Privacy Notice for the platform.

Nevada Privacy Rights

Pursuant to Nevada law, you may direct a business that operates an internet website not to “sell” certain ”covered information” (each as defined by such law). As noted above, we do not sell your personal information. For any questions regarding this, please contact us at the information below.

Contact Us

For any questions regarding this Notice, or our data practices, please direct your inquiry to:

Evidation Health

Attn: Privacy

63 Bovet Rd #146

San Mateo, CA 94402

privacy@evidation.com

Changes to this Notice

We may update this Notice from time to time to reflect changes or updates to our technology, data practices, and other factors. Changes to this Notice will become effective when published in the revised Notice, unless otherwise noted. Please check the “Last Updated” date at the top of this page to see when this Notice was last revised. Your continued use of the Services following the effective date of these changes indicates your consent to the practices disclosed in the updated Notice.