EVRYTHNG Platform Privacy Policy

Last updated: 12 March  2021 

Welcome to EVRYTHNG’s Platform Privacy Policy.


EVRYTHNG respects your privacy and is committed to protecting your personal data. We created this privacy policy to give you confidence as you visit and use the EVRYTHNG Platform (the “Platform”) and to demonstrate our commitment to fair information practices. This Privacy Policy will inform you as to how we look after your personal data when you use our Platform (regardless of where you use it from) and tell you about your privacy rights and how the law protects you. 

 

This Platform Privacy Policy also describes how we process personal data on behalf of our commercial users, developers and other platform users (collectively “Customers”) in connection with the EVRYTHNG Platform Services. This Platform Privacy Policy does not apply to any information or data collected by EVRYTHNG as a controller for other purposes such as information collected on our websites or through other channels for marketing purposes. Please find the EVRYTHNG privacy policy that contains this information by clicking https://evrythng.com/privacy/. 

EVRYTHNG processes Customer data under the direction of our Customers, and has no direct control or ownership of the personal data we process on behalf of our customers. Customers are responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring personal data to EVRYTHNG for processing purposes. For detailed privacy information related to an EVRYTHNG customer who uses the EVRYTHNG Product Cloud, please contact our customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Privacy Policy.

Terms not otherwise defined herein shall have the meaning as set in the EVRYTHNG Terms of Use or the EVRYTHNG Platform Terms. In the event of conflict between the Platform Privacy Policy and the EVRYTHNG Terms of Use, the EVRYTHNG Terms of Use will control.  If you are a commercial user, the Master Platform Agreement and/or Platform Terms of Use (as applicable) will control in the event of any conflict.

We keep our privacy policy under regular review. We reserve the right, at any time, to add to, change, update, or modify this privacy policy, simply by posting such change, update, or modification on this page and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on this page. It is your responsibility to review this privacy policy from time to time to ensure that you continue to agree with all of its terms. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This Platform is not intended for children and we do not knowingly collect or save any information from children under the age of 13.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. 

 

About us

EVRYTHNG is made up of different legal entities, comprising EVRYTHNG Limited, EVRYTHNG Inc. and EVRYTHNG Sárl (together the “EVRYTHNG Group”). This privacy policy is issued on behalf of the EVRYTHNG Group so when we mention “EVRYTHNG”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the EVRYTHNG Group responsible for processing your data. 

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our DPO using the details set out below.

Use of the EVRYTHNG Platform

Customer Data

If you choose to process personal data through the EVRYTHNG Platform, you agree to comply with all applicable data protection legislation. By processing personal data through the EVRYTHNG Platform, you agree to the terms of the Data Processing Agreement available at https://evrythng.com/data-processing-agreement. 

You agree that EVRYTHNG shall have the right to collect and analyse data and other information relating to the provision, use and performance of various aspects of the Platform Services and related systems and technologies. EVRYTHNG will be free to (i) use such information and data to enhance its services and for other development, diagnostic and corrective purposes in connection with its services, and (ii) maintain anonymised data, which is obtained in the course of performing services, in EVRYTHNG’s databases for continuous product enhancement, validation of its professional norms and standards development, and for benchmarking and industry standards, provided that (i) such data will only be used or disclosed in an aggregated or other de-identified form (not capable of identifying any individual), and (ii) EVRYTHNG will ensure that where such data is derived from a customer or subscriber’s data, neither customer, subscriber nor any specific transaction or event will be identifiable from any such data or information. 

 

How and why we collect and use information

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

 

  • Identity Data includes your first name and last name.
  • Contact Data includes your email address.
  • Technical Data includes data related to the device/browser, IP address and on-site/app activities to measure and report statistics about user interactions on the Site. 
  • Usage Data includes the pages and functionality that you have accessed through your use of the platform
  • Marketing and Communications Data includes your communication preferences in receiving marketing emails, product announcements, newsletter and industry news communications and one to one communication. 

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

  1. Information you voluntarily provide
    If you contact us (by email or through our website), we may keep a record of that correspondence. We may delete your personal data automatically after 24 months of inactivity (e.g. when you do access the platform or related webpages such as our documentation hub). 

 

    • EVRYTHNG registration and customer support

In order to access the Platform we will need to capture your name and email address. In addition to this if you contact EVRYTHNG for customer support then you may provide us with additional information (personal and contact information such as name, company name, position/title, email address, telephone number) to help us support you with your query.

 

    • EVRYTHNG Platform and use of cookies

We use information-gathering tools, such as cookies, to collect information as you navigate our Platform and Services. Through such tools, we receive and store information about how you use our websites and Services. For example, we receive information that your browser or device sends to our servers whenever you visit an EVRYTHNG website. Your browser or device may tell us your internet protocol (IP) address used to connect your computer to the Internet, computer and connection information such as browser type, version, language and time zone settings, browser plug-in types, operating system, and type of device you are using. When you visit an EVRYTHNG website, your browser may also tell us information such as the actions you take on our website, the page that led you to our website. Our servers collect similar information when you are logged into our Platform and interact with the Services available there.

The information we receive through cookies and similar technologies may be associated with you, depending on the website or Services you are using. In addition, third parties may be able to collect information about your online activities when you use our websites or Services using cookies or other technologies. We use first-party and third-party cookies, web beacons, and similar technologies in accordance with the information and options that may be provided to you when those technologies are used.

For more information about the types of cookies we use and managing cookies, please see Your rights in respect of your Personal Information below.

If you report a problem with the Platform and/or any services, we may keep that information for two years in case we need to contact you in relation to the issue for which you contacted us, for operational performance improvement and/or nuisance caller management. We will not use it for marketing purposes.

 

2.  Information we collect about you and your device

When you use the Platform, we may use technology such as that provided by Google Analytics to collect information about your interactions. You can find more information about Google Analytics here. In essence, Google Analytics enables us to analyse how you and others interact with our Platform. 

The information we collect may include:

      • Your IP address;
      • The type of browser you use (e.g. Chrome or Safari);
      • The number of sessions per browser on each device;
      • The type of device (e.g. Samsung) and operating system (e.g. Android) you are using;
      • Referrer information;
      • Time zone;
      • User preferences; and
      • Which features you accessed

         

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.

     

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

     

  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending any marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time using the contact details below. If you withdraw your consent, this will not affect the lawfulness of any processing carried out by us using your consent before such withdrawal.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

PURPOSE/ACTIVITY

TYPE OF DATA

BASIS FOR PROCESSING

To register you as a new user

Identity Data

Contact Data

Performance of a contract with you.

To manage our relationship with you which will include:

  1. Notifying you about changes to our terms or privacy policy
  2. Sending you requested marketing materials
  3. Sending you Newsletters or Campaign marketing materials

Identity Data

Contact Data

a)

  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

For b) and c) based on Consent

To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Technical Usage

  • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  • Necessary to comply with a legal obligation

To use data analytics to improve our Platform, products/services, marketing, customer relationships and experiences

Technical Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Platform updated and relevant, to develop our business and to inform our product and marketing strategies)

To contact you 

Contact details

If requested by you for services such as our Platform status alerts (https://status.evrythng.com)

Based on Consent

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

This is who we share your information with

We will only share your information with other organisations where we have your permission to do so in accordance with this privacy policy or where we believe it is necessary for a legitimate reason connected with this Site or in order to provide our services.

We work with analytics providers and we may receive information about you from them. Below is a non-exhaustive list of third parties we work with. We may work with third parties not listed below or stop working with the third parties listed below.

NAME OF THIRD PARTY

WHY WE WORK WITH THEM

Google Analytics

To monitor Website performance & user experience. All information shared with google analytics is anonymised

Google Tag Manager

To monitor Website performance & user experience. All information shared with google tag manager is anonymised

HubSpot (Marketing module)

To manage marketing information, distribution of emails and newsletters.

Salesforce (Sales module)

  Tracking of interactions with leads and customers

hotjar

Website Heatmaps & Behavior Analytics Tools

Google looker

To create analytics reports and charts based on the data in our platform as part of the Platform Services

Amazon Web Services

To host our services

Google Cloud Platform

To host machine learning services

To service user authentication where a customer requires it

Alibaba Cloud

To host our services in China [not used to process the data of any users based  outside of China]

Okta

To service user authentication where a customer requires it

MongoDB Atlas

For primary data storage

Atlassian

EVRYTHNG service desk for customer support

LogEntries

Application logging

Sentry

Application logging

NewRelic

Application logging

Heap

To monitor Website performance & user experience. All information shared with Heap is anonymised

We may also disclose personal information to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

In addition, we may disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to (1) conform to the edicts of the law or comply with legal process served on EVRYTHNG or its parent company, subsidiaries or affiliates, (2) protect and defend the rights or property of EVRYTHNG or the users of the Site, or (3) act under exigent circumstances to protect the safety of the public or users of the Site.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

Cookies 

We may use cookies to improve your experience using our Platform and services. Cookies are small pieces of data that are stored on your computer, mobile phone or other device. Pixels are small blocks of code on web pages that do things like allow another server to measure viewing of a web page and are often used in connection with cookies. HTML5 Local Storage is a small database located inside your browser which web pages can use to store data to speed up their processing. 

Cookies do lots of different jobs, like letting you navigate between pages efficiently, storing your preferences, and generally improving your experience of our services. Cookies make the interaction between you and our services faster and easier. We use cookies to distinguish you from other users of our Platform and our services. This helps us to provide you with a good experience when you use the Platform and also allows us to improve the Platform and the services. Cookies and other things like local storage also help us authenticate you to deliver personalised content to you.  You can find the full detail on cookies in our Cookie Policy.

International transfers

Some of our external third parties are based outside the UK and/or EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the UK and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commision.
     
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

     

  • Where we use providers based in the US, we may transfer data to them if they have entered into a contract with us which incorporates the European Commission’s Model Clauses


Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside of the UK and/or EEA.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Links to third party sites

If you follow any of the third-party links, plug-ins or applications you find on this Site, our privacy policy does not extend to third party sites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Your legal rights

We think it is important that you are able to control your personal information.

You have the right to ask us not to process your information for marketing purposes. You may exercise your right to prevent such processing at any time by contacting us at the address stated at the end of this Privacy Policy.

The law gives you the right to request a copy of the personal information we hold about you. We first require you to prove your identity with two pieces of approved identification. We will supply, correct or delete personal information about you on our files. In addition, you may request rectification or erasure of personal information as well as the restriction of processing of your personal information. We will comply with your requests in accordance with the applicable law. 

You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. 

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

If you want to stop using the Platform and the services, you may do so. If you do, you may also want to remove any cookies that we have placed on any device used to access the Platform and the services.

If you have any questions about our privacy policy, please contact our Data Protection Officer by email at privacy@evrythng.com or by mail at: EVRYTHNG Ltd., Unit 4, 122 East Road, London N1 6FB, United Kingdom.

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