Introduction: Who We Are and Why We Collect Your Information
EVA, LLC (“EVA” “we” or “us” or “our”) provide a virtual conference platform called EVA (the “Platform”) to our customers, which includes online registration, event hosting, and related back-end support (collectively, the “Services”).
When you register for an event hosted by one of our customers, you may be providing to us, and we may be collecting and processing, personal information about you, potentially including sensitive and special categories personal information about you and others.
What Information Does EVA Collect?
Information You Provide to Us
We may collect and process Personal Information about you when you visit the Platform, register for and attend a conference, and otherwise interact with the Platform or Services, or may include, but is not necessarily limited to, the following: name, home address, work address, email address, travel information, job title, employer information, health information, and any other information related to event registration matters.
We may collect and process Personal Information from and about you when you visit our application, register for or subscribe to any service, communicate with us, and otherwise interact with the Platform, Services, or us. For example, when you log in to our Platform to register for a conference, we may collect your name, phone number, user name or e-mail address in combination with a password or security question. You can choose not to provide us with certain information, although that may affect the functionality of the Platform and Services.
Information Collected Automatically
When you use our Services, certain information is passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as Internet Protocol (IP) addresses and cookies. These are described in more detail below:
IP Addresses. The Services use IP addresses. An IP address is a number assigned to your device by your internet service provider to access the internet. In most consumer cases an IP address is dynamic (changing each time you connect to the internet), and not static (unique to a particular user’s device).
- E-mail and Other Communications
We may communicate with you by email or other means. When we do this, in addition to the information contained in the email, we may collect a confirmation when you open email. This confirmation helps us improve our service. If you do not want to receive email or other mail from us, please indicate your preference by visiting our email preference page. Please note that, if you do not want to receive legal notices from us, those legal notices will still govern your use of the applications, and you are responsible for reviewing such legal notices for changes.
- Information Obtained from Third Parties
In some situations, you may use the Services as part of a contract EVA has with your employer (each a “Customer Employer”) to provide the Services to its employees. When that occurs, we may receive the following Personal Information about users from the Customer Employer: name, contact information (including phone number, work address, and email address), job title and duties, conferences to register for, and any other information related to event registration matters.
- Special Categories of Personal Information:
- Personal Information EVA Has Collected in the Last 12 Months
What Does EVA Do With Personal Information?
EVA collects and uses Personal Information:
- To respond to inquiries and comments;
- To fulfill your requests concerning the Platform and the Services;
- To provide you with information about products or services that we believe will interest you;
- To satisfy our contractual obligations with Customer Employers;
- To tailor content, recommendations, and advertisements we and third parties display to you on the Website, through the Services, and elsewhere online;
- To operate, maintain, develop, and grow EVA and the Platform;
- To operate, develop, maintain, and improve the Platform and Services;
- To conduct market research;
- To analyze how visitors use the Platform and Services;
- To investigate and resolve disputes and security issues;
- To comply with regulatory and legal obligations; and
- For any other lawful, legitimate business purpose.
EVA may anonymize or aggregate Personal Information it collects. It may also use that information and other non-Personal Information it collects when you use or interact with the Platform or Services to better understand our users and their behaviour and to improve the user experience of the Platform and Services.
Will EVA Share Any of the Personal Information it Collects?
We share Personal Information with third parties as described below.
- Agents and Service Providers
We employ other companies and people to perform tasks on our behalf and may need to share Personal Information with them to provide products and services to you. Unless we tell you differently, our agents and service providers do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
- Customer Employers
If you have received access to the Platform and/or Services pursuant to a contractual relationship we have with your employer, we may share Personal Information with your employer to fulfill our contractual obligations and continue to provide access to you.
- Business Transfers
We may choose to buy or sell assets. In these types of transactions, Personal Information is typically one of the business assets that is transferred. Also, if we (or all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred or acquired.
- Protection of EVA and Others
We reserve the right to access, read, preserve, and disclose any information that we reasonably believe necessary to comply with law or court order, enforce or apply our conditions of use and other agreements, or protect the rights, property, or safety of EVA our employees, our users, or others, including exchanging information with other organizations for fraud protection and credit risk reduction.
- With Your Consent
Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.
- Personal Information EVAREG LLC Has Sold in the Last 12 Months:
EVAREG LLC does not sell Personal Information, however, we share Personal Information with Customer Employers as part of the Services provided to those clients, as described in Section V.G below, which may qualify as a sale of Personal Information under applicable Privacy Laws, including the CCPA and CPRA.
- Personal Information EVAREG LLC Has Disclosed to or Shared with Third Parties in the Last 12 Months
EVAREG LLC has disclosed the following categories of Personal Information to Customer Employer clients in the 12 months immediately preceding the Effective Date: names; contact information; employers; job titles and duties; pictures; likenesses; social media accounts; courses enrolled in; and test answers and scores. EVAREG LLC relies on third party vendors to support the Services, including, but not limited to, cloud hosting platforms for all data storage. As a result, all Personal Information collected and described in Section III.G has been disclosed to third party vendors in the 12 months immediately preceding the Effective Date.
What Is EVA’s Legal Basis for Collecting and Using Personal Information?
Attention: Data Protection Office
9711 Washingtonian Blvd,
Gaithersburg, MD 20878
How Long Does EVA Retain Personal Information?
Except upon the request of an individual, as explained in Section VII below, and except as the law permits and requires, EVA will determine the retention period for Personal Information based on the following criteria:
- The nature of our relationship with the relevant individual and the Customer Employer, if applicable;
- The existence of other ongoing or expected projects with the relevant Customer Employer;
- The nature of the Personal Information in question; and
- Our business needs.
What Are Users’ Rights to Control Their Personal Information?
To the extent required by the Privacy Laws, except where permitted or required by law (including, but not limited to, compliance with a legal obligation, to further a public interest, and establishing and/or exercising a legal claim or defense), you have the following rights regarding EVA’s collection and processing of your Personal Information.
- Requests to EVA
You may request the following from EVA with respect to your Personal Information:
- Correction, updating, deletion, or restriction of collection and processing of your Personal Information;
- A description of the categories of your Personal Information that EVA collects or processes;
- A description of the categories of sources from which EVA collects or processes your Personal Information;
- The expected period for which EVA will store your Personal Information;
- The purpose that EVA collects and processes your Personal Information;
- A description of how EVA collects and processes your Personal Information;
- A copy of your Personal Information retained by EVA to be delivered in a structured, commonly used and machine readable format to review or to transfer or transmit to another entity without hindrance, to the extent that that is technically feasible;
- Categories of third parties with whom EVA shares your Personal Information, and list of third parties with whom EVA has shared your Personal Information;
- Categories of your Personal Information that we have shared with third parties, including customers, and the categories of third parties to which we have shared each particular category of Personal Information;
- The specific Personal Information EVA has collected or processed about you.
If you request that your Personal Information be erased or deleted or that EVA otherwise restrict its collection and processing of Personal Information, EVA may terminate or limit your access to the application and service. If EVA has not collected or processed your Personal Information, or has not shared your Personal Information with another party, EVA will inform you of that in response to any of the above requests. Some information may remain in EVA’s backup media after erasure or deletion for a period of time. When you request that EVA’s update information, EVA may retain a copy of the unrevised information in EVA’s records. EVA also may use any anonymized aggregated statistical data derived from or incorporating Personal Information after it is updated, erased, or deleted, but not in a manner that would identify you.
We will confirm receipt of all such requests and provide information about how EVA will process the request within 30 days of receipt, and substantively respond to all such requests within 60 days, unless a shorter period is required by the Privacy Laws. Those periods may be subject to lawful extension, and there may be a delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized third party.
Our verification process varies based on the source and nature of the request, but may include: comparing data in the request against Personal Information we retain; contacting you using other contact information; requesting further information, although we will avoid doing so to the extent possible; and the consideration of certain factors, including the type, sensitivity, and value of your Personal Information, the risk of harm to you posed by an unauthorized request, the likelihood that fraudulent or malicious actors would seek your Personal Information, the manner in which we interact with you, the available technology, and whether the information you have provided to verify your identity is sufficiently robust to protect against fraudulent requests. To the extent permitted by the Privacy Laws, EVA retains the right to deny any request if we cannot verify that it originated from you.
EVA retains records of all of the above requests and our responses as required by the Privacy Laws.
When you update information, we may maintain a copy of the unrevised information in our records. Please note that some information may remain in our private records after your deletion of such information from your account.
EVA may use any anonymized aggregated statistical data derived from or incorporating Personal Information after it is updated, erased, or deleted, but not in a manner that would identify you.
- Making Foregoing Requests
You may authorize an agent to take any of the acts permitted in this Section VIII on your behalf. To do so, you must provide written and signed authority to the agent, and written and signed notice to EVA that EVA may act on such requests by that agent.
Withdrawal of Consent
You may withdraw your consent for EVA to collect or process your Personal Information in any of the following manners: (1) contact us at firstname.lastname@example.org; (2) contact us at 9711 Washingtonian Blvd, Gaithersburg, MD 20878; or (3) contact us at 703-579-1496. Please be aware that such withdrawal does not affect the lawfulness of EVA’s collection or processing of your Personal Information before such withdrawal. We reserve the right to terminate or limit your access to the applications and services in the event that you withdraw your consent.
“Do Not Sell My Personal Information”
Other than providing Personal Information to Customer Employers as described in Section V.B above, EVA does not “sell” Personal Information, as that term is defined by the CCPA and CPRA. You may opt out of EVA’s disclosure of your Personal Information to Customers in any of the following manners: (1) contact us at email@example.com; (2) contact us at 9711 Washingtonian Blvd, Gaithersburg, MD 20878; or (3) contact us at 703-579-1496; or completing the form as the following link:
We will act upon any request to opt out of the selling of your Personal Information within 15 days of receiving your request. We will notify all third parties to whom we have disclosed your Personal Information of your request consistent with the requirements of the Privacy Laws. If you exercise your right to opt out of the disclosure of your Personal Information to third parties, EVA will cease disclosing your Personal Information to Customers as of the date EVA receives notice in a manner provided above. EVA will not contact you about opting in to disclosing your Personal Information for at least 12 months following the date that it receives your notice.
Object or Challenge
You may object to, or otherwise challenge, EVA’s collection and processing of your Personal Information in any of the following manners: (1) contact us at firstname.lastname@example.org; (2) contact us at 9711 Washingtonian Blvd, Gaithersburg, MD 20878
; or (3) contact us at 703-579-1496. EVA will respond consistent with the Privacy Laws.
Filing a Complaint
Regulatory authorities that oversee the Privacy Laws typically advise individuals to file an objection or challenge with the company before lodging a formal complaint with a regulatory authority. If an individual is dissatisfied with EVA’s response to an objection or challenge filed under Section VII.F, or wishes to file a complaint with a regulatory authority first, the individual may do so, including as follows:
- PIPEDA: Office of the Privacy Commissioner of Canada
- GDPR: Supervisory authority in the relevant European Union member state
- CCPA and CPRA: California Attorney General
- PII Laws: Relevant state Attorney General
Prohibit Automated Processing
EVA does not use any automated decision making or profiling at this time. If and to the extent we do so in the future, at your request, EVA will terminate any automated decision making, including profiling, that is the sole source of decisions that produce a legal effect concerning or similarly significantly affecting you.
Accessibility for Users with Disabilities
EVA will not discriminate against you because you have exercised any of the rights above or any other rights you retain pursuant to Privacy Laws, including, but not limited to by:
- Not denying goods or services to you;
- Not charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Not providing a different level or quality of goods or services to you; and
- Not suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Consistent with Privacy Laws, EVA: (a) retains the right to charge you a different price or rate, or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to EVA by your Personal Information; (b) may offer financial incentives, including payments to you as compensation, for the collection, disclosure, or deletion of your Personal Information; (c) may enter you into a financial incentive program only if EVA clearly describes the material terms of the financial incentive program, so long as you give EVA prior opt-in consent, which you may revoke at any time; and (d) shall not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.
What Are EVAREG LLC Service Differences?
EVAREG LLC does not offer any financial incentives for providing your Personal Information.
Is Personal Information About Me Secure?
We employ appropriate administrative, organizational, technical, and physical measures designed to protect the confidentiality, integrity, and availability of your Personal Information, which we regularly review and update as necessary.
We do not knowingly collect or solicit, and expressly instruct you not to provide, any Personal Information from anyone under the age of 16. If and to the extent we learn that we have collected Personal Information from a child under age 16 without verified parental consent, we will delete that information, except as provided below. If you believe that we might have any information from or about a child under age 16 without verified parental consent, please contact us immediately us at email@example.com, 9711 Washingtonian Blvd, Gaithersburg, MD 20878, or 703-579-1496.
Contractual or Statutory Requirement
Failure to Provide Personal Information
You can always opt not to disclose information to us. Please keep in mind, some information may be needed to register with us or to take advantage of some or most of our features.
Automated Decision Making
EVA does not currently rely on automated decision making, including profiling, and will not subject you to decisions based solely on automated processing which will produce legal effects concerning you or similarly significantly affecting you.
Questions or Concerns; Contact Information
Effective Date: 22 September, 2021