Evelyn Learning helps organizations around the globe achieve their business goals through its learning content and technology services. We design and build our solutions on core principles of innovation, end-user experience, and customer satisfaction, such that they work across all platforms, formats, and devices in order to deliver and manage highly compelling and engaging digital content.
It is Evelyn Learning’s policy to respect your privacy regarding any information we may collect while using our software applications and websites, collectively called the Services.
Data Controller and Data Processor
We process two main types of personal data.
- Customer Data – Personal data that constitutes a part of the data that is provided by our customers and their end-users for processing.
- Other Data – Personal data about our customers, visitors and other individuals that is collected and processed directly by us.
Our Customers are controllers of the Customer Data. Evelyn Learning is the processor of Customer Data as well as the controller of Other Data.
Information we Collect
Customer Data You Provide
As customers, you provide us data for processing as a part of the usage of Evelyn Learning applications
Customer Data may be processed by us as a result of the customer’s use of the Services when our customers, or their end-users, input or upload information into the Service. We collect personal information from you when you create an account such as your first name, last name, email address and phone number.
- We collect any personal information that you include in your user profile and public profile, public contents, and during the use of our services such as annotations, file uploads, and notes.
Other Data that we Collect
We also collect and store the following information about you using analytical tools:
Information related to your use of our products and services such as your touch gestures, highlights, bookmarks, page views, and other applications you may use with our products and services is collected by Evelyn Learning. Our products provide information to us about its status such as uptime, available memory, and errors that may have occurred.
Website Visitor Data
We also collect data when you use our applications and websites
- Log Data – Our servers automatically collect information when you access or use our applications and services. This data is recorded in log files. Examples of such data include IP Address.
- Product Demo and Subscription – You provide us personal data as part of either signing up for our newsletters or to request for product demos.
- Contact Us Data – When you enquire about our products and services, we collect and store this data to communicate with you.
Data from Others
We currently use Google Analytics so as to collect information anonymously and report website trends without identifying individual visitors.
We use Google Analytics for analytics and measurements in order to understand how our services are being used. For example, we analyze data concerning your visits to our sites to perform operations such as optimizing product design.
We collect data through cookies
Evelyn Learning visitors can control cookies through their browser settings.
How we use your Data
How we use your personal data will depend upon the Services you use and how you use said Services.
Customer Data will be used by Evelyn Learning in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and as applicable by law. Evelyn Learning is a processor of Customer Data and the Customer is the controller.
Other Data is used by us to provide our services, send our newsletters and promotional material and to communicate with you by responding to your requests, comments, and questions.
Lawful Bases for Processing
We have lawful bases to process your personal data. We also use your consent as a basis for lawfully processing the personal data that you provide us.
We process your personal data only in the presence of a lawful basis. Presently, we use the Performance of Contract (i.e. to deliver the services to our customers) and consent as the lawful bases for processing. For certain processing purposes, we may also use legitimate interests, which are as provided under the Data Protection Regulations. If you are of the belief that certain services are not in your interest, you have a right to object.
In certain cases, we may also have a legal obligation to collect personal information from you or may otherwise need personal information in order to protect your vital interests or those of another customer.
Wherever you have consented to a particular processing, you have the right to withdraw the consent at any time by sending an email to our product support team at “email@example.com.”
How we use Customer Data
We use your data to authenticate you and authorize access to our services
We only process Customer Data on behalf of our customers, in accordance with the instructions provided in the applicable Services agreement with us. We use your data to provide our services and support to you. In each case, Evelyn Learning collects such information only if necessary and in accordance with the law to fulfil the purpose of the interaction with our services.
- To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services and our Services offerings. These communications constitute a part of the Services and you may not opt-out of them.
- Aggregated Analytics. We also use our Customer’s end-user data to derive aggregated analytics such as duration of book reading, Book Opened / Assigned, Reading Time, Pages Read, Reading Sessions, Avg. Reading Time / Session, Avg. Pages Read / Session, Notes Shared / Created, Highlights Shared / Created, Resources Viewed / Available etc.
- Customer Support. If you send us a request (for example via a support email or via one of our feedback mechanisms), we respond to your request to help you with your issues.
- For any other purpose as provided for in the Services Agreement between Evelyn Learning and the customer, or as otherwise authorized by the customer.
- In accordance with or as may be required by law.
How we use Other Data
We may set up product demos or send you marketing / promotional material. You may choose to restrict the collection or use of your personal information.
We will update you with improvements in our services, new features and also carry out direct marketing of our products and services from time to time. Direct marketing is carried out only if you consent to receive such communications from us.
We also send invitations to our events or conferences.
Users Under 16 Years of Age
Evelyn Learning’s Sites and Services do not knowingly collect personal information from users under the age of 16
If you are under the age of 16, you are not permitted to use the Sites and Services in any capacity other than as an end-user student.
Data Retention Policy
Customer Data – We retain your information for as long as you have an active Services account. We may also retain your personal information for an extended period of time under applicable statutory laws.
Evelyn Learning will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement, or for two years in case there are no such instructions and as required by applicable law. When you decide to close your account, we delete all your personal information, which includes any user-generated content.
You can request to access, update or correct your personal information. You also have the right to object to direct marketing. For all requests relating to your rights, you can contact us at “firstname.lastname@example.org.”
You may have additional rights pursuant to your local law applicable to the processing.
Customers Right to Control Data
Whenever you use our services, we aim to provide you easy means to access, modify, delete, object to or restrict the use of your personal information.
We strive to give you means to access and update/modify your data quickly or to delete it unless we need to keep that information for legal purposes.
Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly in the case of inaccurate information.
- Delete Data: You can ask us to erase or delete all or some of your personal data (if it is no longer necessary to provide Services to you).
- Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (if we have no legal right to keep using it) or to limit our use of it (if your personal data is inaccurate or unlawfully held).
- Withdraw your consent – Any consent that you provide, including for direct marketing, can be withdrawn at any time, by contacting us.
- Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of the personal data you provided in a digitally readable form.
We hold onto certain personal data even after account closure.
Once you choose to close your account, we generally delete your personal information within 30 days of closure. Certain information that is necessary for statutory obligations such as records of payment processing and invoicing data will be retained as necessary.
Your Information Shared With Others
Recipients of your Data
Your data will be shared with other recipients in order to provide you with services.
While we aim to limit the sharing of your data, under certain conditions, it is necessary to share your data with certain service providers. Examples of when and for what purpose your data is shared include data center / hosting services, email marketing services, etc.
The following categories of recipients will most likely receive your data in order for us to provide services to you
- Third-Party Data Center Services
- Third-Party SMTP Services
- Third-party temporary file upload tools
- Salesforce /Pardot CRM for direct marketing
To Comply with Laws. If we receive a request for information, we may disclose it if we reason to believe that disclosure is in accordance with or required by any applicable law, regulation or legal process.
Your publicly accessible data may be seen by others.
Your username, public profile information, and public content may be seen by other users of our products and services. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.
Cross Border Data Transfers
Your data will be stored and processed in multiple countries including outside of the European Union (EU) Region
Since we are an international company, your data will be processed outside of the EU region. Your data will be processed within Third-Party Data Centers in the USA and our data centers in India. Some countries where we process data may not have as protective laws as your own country and there are risks associated with such a transfer of data.
Evelyn Learning offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the European Union, and other international transfers of Customer Data. These clauses are contractual commitments between parties transferring personal data (for example, between Evelyn Learning and its Clients, suppliers or data processors outside the EU), binding them to protect the privacy and security of the data.
Security Measures to protect Your Data
We implement security controls to prevent breaches and unauthorized access to your data.
We maintain reasonable and appropriate security measures to protect Customer Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
Examples of security measures include physical access controls, encryption, HTTPS, restricted access to data, monitoring for threats and vulnerabilities, etc.
We also subject our services to internationally recognized certification and attestation standards.
Protection of Personal Information
Our Sites and Services uses commercial efforts to maintain safeguards for the protection of your Personal Information
Evelyn Learning takes all measures that are reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.
If you have questions or complaints regarding this Policy, you may contact us through email at email@example.com.