Privacy Policy

This privacy policy (“Privacy Policy”) governs how we, EverC Ltd., and any other member of the EverC group (together, “EverC”, “we”, “our” or “us”) use, collect and store Personal Data we collect or receive from or about you (“User”, or “you”) such as in the following use cases:

1. When you browse or visit our website, http://www.everc.com (“Website”);
2. When you make use of, or interact with, our Website
   1. When you click on “Free Trial”
   2. When you subscribe, create an account and make use of the eKYC Inspector
   3. When you download Success Stories, Whitepapers & Brochures
   4. When you want to become a partner
   5. When we process your job application
   6. When you subscribe to the email list / blog or leave a comment on our blog
   7. When you contact us (e.g. customer support, when you submit an inquiry, or leave us a message)
3. When you attend a marketing event and provide Personal Data
4. When you exchange business cards with us
5. When we acquire your Personal Data from third-party sources
6. When we use the Personal Data of our customers
7. When we use the Personal Data of our suppliers
8. When you interact with us on our social media profiles (e.g., Facebook, Twitter, LinkedIn)

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Person- al Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

    
Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below. If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

Finally, please note that some of the above mentioned personal data will be used for fraud detection and prevention, and for security purposes. The above mentioned personal data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize your personal data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

3.1. Personal Data. The Personal Data we collect will be stored until we no longer need the information and proactively delete it or until you send a valid deletion request. Please note that we may retain it for a longer or shorter period, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. How We Share Your Personal Information. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

3.2. Cookies. This depends on the cookie in question. Some cookies (e.g. essential cookies) cannot be disabled. You may also control and delete these cookies through your browser settings. Read more in our cookie policy https://www.everc.com/cookies

Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

In addition to the recipients described in Section 1, we may share your information as follows:

• With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.

• To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.

• In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events;

• Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and

• Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

If you want to receive the list of recipients of your Personal Data, please make your request by contacting us at privacy@EverC.com

• Storage of Personal Information: 

  Amazon Web Services (AWS) with a Primary IT operation in US East, Northern Virginia (6), with a Disaster Recovery (DR) site in EU (Ireland), EU-West-1. Both data centers are owned and operated by AWS.

• Internal transfers: We ensure transfers within the EverC group will be covered by an agreement entered into by members of the EverC group (an intra-group agreement) which

  contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to;

• External transfers: Where we transfer your Personal Data outside of EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data. Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

7.1. The following rights (which may be subject to certain exemptions or derogations), shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

• You have a right to access information held about you. Your right of access is normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
•  You have the right to request that we amend any Personal Data we hold that it is inaccurate or misleading.You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;The right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
• The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
• You have the right to object to profiling;You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority
• The right to withdraw your consent. Please note that t there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.
• You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.

7.2. The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the CCPA:

• You have the right to know what Personal Information is being collected about you;You have the right to request the erasure/deletion of your Personal Data (e.g. from our records and the records of our service providers). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
• You have the right to know whether your Personal Information is sold or disclosed and to whom;
• Restriction of, or object to, processing of your Personal Information, including the right to opt in or opt out of sale of your Personal Information to third parties, if applicable, where such requests are permitted by law;
• You have the right to equal service and price, even if you exercise your privacy rights;
• You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence (e.g. the Attorney General in your State). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

You can exercise your rights by contacting us at privacy@EverC.com or, if you are an individual protected by CCPA, you can make your requests by email. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your re- quest promptly or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

We do not offer our products or services for use by children. If you are under 18, you may not use the Website, or provide any information to the Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children. If we learn that we have collected Personal Information from a child under 18 years, we will delete that information as quickly as possible. If you believe that we might have any such information, please contact us at privacy@EverC.com.

Should you ever decide to delete your Account, you may do so by emailing privacy@EverC.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public. 

The Website may enable you to interact with third party websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service.

We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

• Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website.

• We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt- out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/. 

• Firebase Analytics. We also use a similar tool called “Google Analytics for Firebase”. By enabling this tool, we enable the collection of data about App Users, including via identifiers for mobile devices (including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from Google Analytics for Firebase to maintain and improve our App(s). We do not facilitate the merging of personally identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger. Finally, please note that Google Analytics for Firebase’s terms (available at https://firebase.google.com/terms/) shall also apply.

• Mixpanel. We collect personally identifiable information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/. If you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers) You may also clear the Mixpanel opt-out cookie.

• Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share informa- tion is governed by the Facebook Tools Terms, available at: https://www.facebook.com/legal/technology_terms/ You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/choices or http://www.youronlinechoices.eu

• We reserve the right to use other analytic tools

• You may stop or restrict the placement of technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/,https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.

a.    Our California Do Not Track Notice. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We may collect personally identifiable information about an individual consumer’s online activities over time and across different websites when a consumer uses the website. If you choose to operate your web browser “Do Not Track” signals or any other mechanism that provides consumers the ability to exercise choice regarding the collection of such information, we will abide by your request and stop collecting such information. We may allow third parties such as such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different websites when a consumer uses the website.

b.    Deletion of Content from California Residents. If you are a California resident under the age of 18 and a registered user, California business and professions code section 22581 permits you to remove content or personal information you have publicly posted. To remove, please send an email to privacy@EverC.com. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or personal information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

c.    CCPA. This Privacy Policy for California Residents supplements and is expressly made part of the information contained in this Privacy Policy, and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Privacy Policy to comply with the California Consumer Privacy Act of 2018 ("CCPA"). Any terms defined in the CCPA have the same meaning when used in this Privacy Policy. We, including our Website, collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, our websites and agents, may have collected the mentioned categories of Personal Information in Section 1 from consumers within the last twelve (12) months.

d.    Your Choices. You have certain choices about your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time and prevent further processing by contacting us as described in this Privacy Policy. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our services and for other legal purposes as described above in section 7. While we cannot guarantee privacy perfection, we will address any issue to the best of our ability as soon as possible. We will process such requests in accordance with applicable laws.  To protect your privacy, we will take steps to verify your identity before fulfilling your request.

e.    Sale of Personal Information. We do not sell any personal information and we do not disclose any personal information for any business purpose. Therefore, we have not sold or disclosed consumers’ personal information for a business purpose in the preceding 12 months.

f.    Sources. We obtain the mentioned categories of Personal Information in Section 1 from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website.
• From third-party business partners, who provide data services available in the public domain.
  
  

g.    Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject "BLOCK" to privacy@EverC.com. Please note that the email must come from the email account you wish to block. California Civil Code Section 1798.83 permits our customers who 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 send an email to privacy@EverC.com. Please note that we are only required to respond to one request per customer each year.

h.    Non-Discrimination. If you decide to exercise your rights, you will not receive any discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA. However, note that some features of our Website, our products and/or our services will not function without your Personal Information. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

EverC uses different automated technologies to process data from third party sources to help us detect fraud, malware and illegal activities. To the extent EverC is considered a controller and such practices are deemed to be subject to the GDPR, please note that we do not provide a specific notification to data subjects because we believe that an exception of Article 14 of the GDPR would apply. In particular, providing information to a potential suspect or fraudster would seriously frustrate the fraud-prevention purposes. For the same reason, we cannot obtain the consent of the person in question and legitimate interest is the most appropriate legal basis (Recital 47 of the GDPR). However, we have included this paragraph in our privacy policy to inform, in a generic manner, that these practices happen.

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@EverC.com.