Date Last Revised: December 10, 2019
Evident offers you a secure platform to share your personal information with others (“Relying Parties”). Relying Parties will request that you share your personal information through the Services when you conduct a transaction with them (e.g., registering for access to their website or when you request to purchase their products or register for their services). To enable our Services, we collect information about you directly from you, from Relying Parties, from third parties, and automatically through your use of our Services.
To make it easy for you to navigate and understand our data practices, use these hyperlinks to find the section relevant to you.
Collection of Personal Data
Definition of “Personal Data”
How We Collect Personal Data
How We Use Personal Data and Other Information
How We Share Your Information
Links to Other Websites
Access and Your Choices
International Data Transfers and Our Privacy Shield Compliance
Children Under 13
Do Not Track Signals
California Privacy Rights
Evident ID is the operator of our Sites and the controller of data collected from you by our Sites. With respect to the use of our Services by EU data subjects, we are either a controller or processor of your data, depending upon the circumstances that give rise to our processing of your data. We are a United States corporation registered in the State of Delaware and located in Atlanta, Georgia.
Collection of Personal Data
- Postal address
- Telephone number
- Email address
- Driver License or Permit (e.g. vehicle, pilot, water sports, etc)
- Driving Record
- Background check
- Criminal history
- Insurance policy information
- Credit and Financial information in limited circumstances
- National identification such as a social security number
- Language preference
- Date and place of birth
- Professional licenses and certifications
- Geolocation information
- Social media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts
- Pictures, audio files, or videos you submit, including pictures of yourself
- Credit card and billing information (if submitted as payment for Services)
- Other data about you that is requested by a Relying Party or that you authorize us to process
How We Collect Personal Data
We collect Personal Data in a variety of ways as described below.
Directly From You
To use our Services, we require you to register by providing your name and contact information. You, may, but are not required to, provide additional information, such as the data listed in the Collection of Personal Data section above. Note that this is not an exhaustive list.
We may ask you to provide Personal Data for various reasons. For example, when you request a demo of our platform, we may ask you for contact information such as your name, email address, phone number, geographic and job information.
We may ask you for similar information at other times, such as when you apply for a job through our Sites or contact our customer service team.
You may also provide us your personal information when you sign up for a webinar, download a whitepaper directly on our Sites or from one of our partners, or complete a contact us form on our Sites.
We also collect Personal Data that employees, contractors, or agents of our Relying Parties provide to us when they register for access to the Evident platform. The information we may collect includes name, address, company name, location, email address, phone number and account password.
Information Uploaded to the Services
From Third Party Sources
Through our Sites and Services we may receive information, including, with your consent where required, from third party providers and sources that, alone or in combination with other information, could be used to identify an individual, including you. For example, a Relying Party using our Services may provide us with your name and contact information so you can join our Services or qualify to use the Relying Party’s products or services. We verify the information we receive about you so that the Relying Party can have confidence in the accuracy of the information. To do so, we may collect information about you from publicly-available information and third party sources. For example, if a Relying Party requires you to carry insurance, we may verify with your insurance provider that your coverage is in effect, or we may verify that you have a valid driver license or permit.
We also collect, with your consent where required and in accordance with applicable laws, consumer reports about you, such as credit reports or background checks, if the Relying Party requires such information.
We do not control the privacy practices of these third parties that we collect information from. In some cases, such as when a Relying Party asks us to obtain a credit report on you, it may be the Relying Party’s legal obligation to obtain your consent. In those cases, we are relying on the Relying Party’s authorization to collect this information from or about you.
We also may receive your personal information such as name, business email, company and job title, from trade shows or other similar events that we sponsor or from third parties that provide such information. We use this information to send marketing messages to you as described below.
This information can include your browser type and operating system, your IP address, the length and times of day you use our Sites or Services, the referring URL or webpage that led you to our Sites or Services.
Additionally, when you use our App, we may collect information on your mobile device, such as device name and model, mobile operating system type, name and version; language information; and activities within the Services.
With your permission, we will collect location information from your mobile device to help us verify information you may have provided to us. You may turn off this feature through the location settings on your mobile device. More information about how to do this and manage other mobile privacy settings is available from your device provider.
From Social Networking Sites
You may log into our Services through your social networking accounts, including Facebook and Google. If you do this, we obtain information from these sites as follows:
Google. If you log into our Services using your Google account, you must enter your Google email address and password. We will collect your email address, profile information and photo if you login to our Services using Google.
Facebook. If you log into our Services using Facebook, you must enter your Facebook email address or phone number, and password. We will ask that you grant us permission to access and collect your Facebook public profile information (this includes your name, profile picture, and any other information you have set to public on your Facebook account) and email address.
We securely store the information that we receive from Facebook and Google with other information that we collect from you or receive about you.
Any third-party social networking site controls the information it collects from you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies. We have no control over how any third-party social networking site uses or discloses the personal information it collects about you.
Use of Personal Data and Other Information
We use the Personal Data collected for a number of purposes as described below.
To Provide our Services
Evident uses your information, including Personal Data, for the following purposes:
- To allow you to share with Relying Parties, at your discretion, the information that we obtain about you.
- To verify that the information you provided is accurate.
- To assist Relying Parties in preventing fraud in relation to their products and services.
- To request, with your permission and in accordance with applicable laws, consumer reports.
- To perform our Services that you request or to fulfill other requests from you.
- To send you text messages, with your consent, as part of our multifactor authentication protocols.
- To verify information about you, with your permission where required, we may employ various methods, such contacting governmental authorities (such as state licensing boards), receiving information from third parties, reviewing public records, for purposes such as verifying that you hold a particular license or credential, or running a criminal background or credit check (in accordance with applicable laws). The data received from these third parties and sources is used solely to prevent fraud and verify information about you, unless you authorize additional uses.
To Communicate with You
We use the information that we collect when you visit our Sites to respond to questions, comments or requests for information from us and to send applicable and personalized marketing messages in accordance with applicable laws. These marketing messages may include emails, texts, online advertisements, or phone calls. Marketing related communications to you will contain instructions on how to unsubscribe from receiving them. See more on how to opt out in the Your Choices section below.
When you send email or other communications to us, we may keep those communications and use the Personal Data they contain in order to process your questions, respond to your requests and improve our Sites or Services. In particular, we may use your email address to communicate with you about our Services, such as to provide you with support.
Other Uses of Data
We may anonymize, de-identify and/or aggregate the information that we collect and use such anonymized, de-identified and/or aggregated data for our own business purposes, including but not limited to sharing anonymized and de-identified data with our current and prospective business partners, service providers, affiliates, agents and other third parties for commercial, statistical and market research purposes, for example to allow those parties to analyze patterns among groups of people, and conducting research on consumer demographics, interests and behavior.
We use Personal Data and other data for data analysis, security and fraud monitoring and prevention, product development and testing, improving or modifying our Sites and Services, analyzing website traffic patterns and behaviors, statistical and survey purposes, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
How We Share Your Information
Evident may share your information, including Personal Data, in the circumstances described below.
Relying Parties. We will share the information that you direct us to share with a Relying Party.
Third Party Data Sources. We share your information with third party data sources to verify the accuracy of the information you provide to us and to request information about you.
Aggregate and De-Identified Information. We may share aggregate or de-identified information about users and prospective users of our Sites and Services with third parties for marketing, advertising, research or similar purposes.
Service Providers. We share information with our third party vendors and service providers to perform certain functions on our behalf, such as hosting specific portions of the Service, maintaining databases, helping us collect job applications, delivering content, sending emails on behalf of our customers and for our own marketing communications, using text messaging services for multifactor authentication protocols, administering content, mailing information, processing payments or otherwise operating the Services or the Sites.
Business Transfers. If we are acquired by or merged with another company, if all or some portion of our assets are transferred to another company, or as part of a bankruptcy proceeding, financing due diligence, reorganization, or receivership, we may transfer the information we have collected from you to the other company or bankruptcy trustee or administrator.
In Response to Legal Process. We may disclose the information we collect from you in order to comply with the law, a judicial or regulatory proceeding, court or governmental agency order, or other legal process, such as in response to a court order or a subpoena.
Links to Other Websites
Evident is built to protect your private information and to allow you to securely share your information with Relying Parties. We have implemented commercially reasonable and appropriate precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. For example, we protect the personal information that you submit to us through encryption and access controls.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
We may use “cookies” (a small text file sent by your computer each time you visit our site) or similar digital technologies to record log data. Many browsers default to accepting cookies. You may be able to change this setting in your browser and you can also clear your cookies. If you do, you may lose some functionality of our Sites or Services. Check your browser’s help function to learn more about your cookie setting options.
We may use the following types of cookies and digital technologies:
- Analytics & Advertising cookies
- Essential cookies
- Functionality cookies
- Social Media cookies
- To help us make e-mails more useful and interesting, we often receive a confirmation when you open e-mail from us if your computer supports such capabilities. You can opt out of receiving emails or other electronic marketing communications from us, other than emails related to your use of the Services or management of your account. Please see the Your Choices section below.
- We might also use a pixel tag which is a small graphic file that allows us and third parties to monitor the use of the Sites and Services and provide us with information based on your interaction with the Sites, Services and e-mails. These tags may collect the IP address from the device which you loaded the page, your browser type, and other data. Pixel tags are also used by our third parties to collect information when you visit our Site, the links and other actions you take on our Site, and we may use this information in combination with cookies to display targeted advertisements.
- Other data technologies may be used that collect comparable information for security and fraud detection purposes.
Access and Your Choices
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to control cookies, including turn them off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
- Internet Explorer
- Microsoft Edge
- Mozilla Firefox
- Google Chrome
- Apple Safari
To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit www.allaboutcookies.org, and/or the Digital Advertising Alliance’s (DAA) online resources at youradchoices.com/control, and/or the Network Advertising Initiative’s (NAI) online resources at http://www.networkadvertising.org, and follow the opt-out instructions there, or if located in the European Union, visit the European Interactive Digital Advertising Alliance’s (EDAA) Your Online Choices opt-out tool at www.youronlinechoices.com.
Opting out from one or more companies listed on the DAA Consumer Choice Page, the NAI Consumer Opt-Out Page, or the EDAA Your Online Choices opt-out page will opt you out from the delivery of interest-based content or ads to you by the third parties participating in those opt-out services, but it does not mean you will no longer receive any personalized advertising through our Services or on our Sites or other websites. You may continue to receive advertisements, for example, non-personalized advertisements or advertisements based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA, NAI or EDAA websites, your opt out may not be effective. Additional information is available at these websites.
Third Party Analytics
Third Party Advertisers
Modifying personal information
You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Services for a period of time and in accordance with our data retention policies.
Opting out of email
We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.
EU Data Subjects
This section applies if you are an EU data subject (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland). Evident is the data controller for processing Personal Data provided to Evident in relation to the Sites. Unless you have given us your consent for our independent uses of your Personal Data or we have another lawful basis for processing your Personal Data, we act strictly as a data processor for Personal Data that we process through the Services, as described under the “Information Collected Through our Services” section above. For example, we process data on behalf of Relying Parties in relation to transactions you may be conducting or considering with them. We rely on the following legal bases for processing your Personal Data:
- Processing of your Personal Data based on your consent for such processing, which may be given either to us or the Relying Party.
- Processing of your Personal Data that you provide to us (such as your name, email address, postal address, telephone number, company name and role) when you request a demo of the Evident platform or when you otherwise send inquiries about our Services is necessary to respond to or implement your request prior to entering into a contract with us or a data controller that is using our Services.
- When you apply for employment, including through our Sites, processing of your contact details and data about your employment history and education (as needed to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment) is necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you submit.
- We use account-related data to set up accounts for users in the Services and to administer and support those accounts (such as usernames, email address and billing information), provide you with access to the Services, contact you regarding your use of the Services or to notify you of important changes to the Services. Such use is necessary for the performance of the contract between you and the Relying Parties or us.
- We may send you information by email or through other electronic communications on our new products or services or other promotions if you consent to receiving them. If you have not opted-in to these marketing emails, we do this either because we are relying on an exception to opt-in requirements or because of our legitimate interest to promote the success of our business.
- Our use of data relating to your use of the Sites and/or the Services, described above, is necessary for our legitimate interests in understanding how the Sites and the Services are being used by you, to improve your experience on it and our Service offerings.
- We also have a legitimate interest in aggregating and/or anonymizing or de-identifying the information that we collect through our Sites and/or the Services and using this information for our business purposes, as described above.
- When we process your Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Data for activities where our interests are overridden by the impact on you, unless we have your consent for our processing activities or those activities are otherwise required or permitted by law. You have the right to object to processing that is based on our legitimate interests, as further described below.
Subject to applicable law and reasonable steps that we may take to verify your identity with respect to your requests, you have the following rights in relation to your Personal Data:
- Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
- Right to rectification: If your Personal Data that we control is inaccurate or incomplete, you are entitled to have it rectified or completed. Note that we may not be able to rectify data obtained from a third party such as a governmental agency or other data that we do not control, and you will need to contact that third party directly. If we have shared your Personal Data with others, we will tell them about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
- Right to erasure: You may ask us to delete or remove your Personal Data and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion, for example if we are required by law to keep it). If we have shared your data with others, we will tell them about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
- Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of that Personal Data or object to us processing it. We will tell you before we lift any restriction on processing. If we have shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
- Right to data portability: Effective 25 May 2018, you have the right to obtain your Personal Data from us that you consented to give us or that is necessary to perform a contract with you, to the extent it is available. We will give you your Personal Data in a structured, commonly used and machine-readable format.
- Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so if we are processing your Personal Data for the Services, for direct marketing, or otherwise. However, if we are relying on a legitimate interest to process your Personal Data and we demonstrate compelling legitimate grounds for the processing we may continue; or you may exercise your rights by contacting us as indicated under “Contact Us”. Note you will be asked to verify your identity when submitting a request.
- Rights in relation to automated decision-making and profiling: You have the right to be free from decisions that we make based solely on automated processing of your Personal Data, including profiling, which produce a significant legal effect on you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us, or with your explicit consent.
Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Your withdrawal of consent will not apply to or affect prior processing of data that was processed prior to our receipt of your withdrawal of consent.
- Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we have handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
EU Data Subjects may contact us about these rights at email@example.com or at the address set out in the Contact Us section below.
International Data Transfers and Our Privacy Shield Compliance
The Personal Data we process may be transferred to, and processed in, any country in which we, our group companies, or our service providers or partners operate, which may include countries other than the country in which you are resident. These countries may have data protection laws that are different than the laws of your country.
However, we have taken appropriate safeguards to require that your Personal Data will remain protected in accordance with this Policy. In particular, Evident complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Economic Area member countries and Switzerland to the United States, respectively. Evident has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the terms of this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.
Evident US has further committed to refer unresolved privacy complaints from EEA or Swiss citizens or residents regarding transfers of their personal data under the Privacy Shield Principles to an alternative dispute resolution. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel for EU or Swiss individuals.
When Evident US transfers personal information about EU or Swiss individuals to other third parties, it will do so in accordance with the Onward Transfer principle of the EU-US and Swiss-US Privacy Shield Principles. In these cases, Evident is potentially liable if such third parties do not provide the same level of protection as the Privacy Shield Principles. More information on the Privacy Shield Frameworks is available here.
Evident will retain Personal Data for the period necessary to provide our Services or for the purposes it was collected for, as otherwise required by our contracts or by law.
When determining how long we should keep data, we consider the length of time we will have a relationship with you or the Related Parties and provide our Services, whether there is a legal obligation that would require us to keep the information for a specified period of time, the reasons why we process your data, the risk of harm from unauthorized use or disclosure of your Personal Data.
We may also anonymize or de-identify Personal Data so it would no longer be associated with you for research or analytical purposes. If data is anonymized or de-identified, we may use this data for as long as we have a legitimate business purpose for such use, without additional notice to you.
Children Under 13
Our Services and Sites are not directed at children under 13 years of age (or older where required by law), and we do not knowingly collect or receive Personal Data from them. If we learn that we have received Personal Data from a child whose age requires parental consent for processing, we will delete the data. If you believe that we have received Personal Data from a child whose age requires parental consent, you may contact us at firstname.lastname@example.org.
Do Not Track Signals
Our Sites and Services do not collect personal information about your online activities over time and across third-party websites or online services. Therefore, “do not track” signals transmitted from web browsers do not apply to our Sites or Services, and we do not alter any of our data collection and use practices upon receipt of such a signal.
California Privacy Rights
California law permits visitors 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 contact us at email@example.com.