This Policy was last updated in May 2018.
Evolving Systems, Inc. and its subsidiaries are committed to protecting and respecting your privacy.
This Policy explains when and why we collect personal information about people who visit our website, how we use it, the conditions under which we may disclose it to others and how we keep it secure. We also collect additional data from prospective employees who visit our website and submit their personal details there. Additional guidelines on how we protect this information may be found in our Prospective Employee and Employee Information Privacy Overview here.
We may change this Policy from time to time so please check this page occasionally to ensure that our latest version is still acceptable to you. By using our website, you’re agreeing to be bound by this Policy.
Any questions regarding this Policy and our privacy practices should be sent by email to: firstname.lastname@example.org
The rules on processing of personal data of residents of the European Union are set out in the EU General Data Protection Regulation (the “GDPR”).
Who are we?
We are Evolving Systems, Inc. (“EVOL”), a provider of mobile eSIM/SIM activation, provisioning, number management and digital engagement enterprise software and services to telecom operators worldwide. Under European data protection regulations EVOL is classified as a data controller for services available on this website. That means we decide how your personal data we receive is processed and for what purposes. For all data privacy matters contact us at: email@example.com.
How do we collect information from you?
We obtain information about you when you use our website, for example: we collect your information when you complete our online forms and complete our surveys. We may also buy information about you from 3rd party marketing companies that have your permission to share this information with us. We collect data that we obtain using forms filled out by users and from cookies on our website, which help us track user behavior separately from a user’s personal information (see below for additional information on cookies). We also collect your contact information in direct sales and/or support engagement activities.
What type of information is collected from you?
How is your information used?
We may use your information to:
- Send you communications which you have requested and that may be of interest to you. These may include newsletters, product updates, activities & promotions of our group companies' goods and services;
- Seek your views or comments on the services we provide;
- Notify you of changes to our services;
- Post and/or email copies of news of interest to investors (including press releases) to your address;
- Process a job application to join us; and
- Better our understanding of web and downloadable material for visit path, influencing pages, content, keywords searched and other similar details that help us optimize our website and content for our visitors’ interests and EVOL’s sales and marketing goals.
How long do we keep your personal data?
We keep your personal information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws. Where there are technical limitations that prevent deletion or anonymization, we safeguard personal data and limit active use of it. Currently for marketing we retain your information for up to 2 years unless business reasons dictate that we retain the information for a longer period of time, such as if we require the information in order to continue to provide services to you (in line with contractual obligations, for example).
What is our legal basis for processing your personal data?
- Use information to create and manage an account, we need it in order to provide relevant services.
- Gather and record data associated with use of a digital signature, it is to comply with regulations.
- Use names and email addresses for email marketing purposes, we do so with your consent (which you can revoke at any time).
- Gather usage data and analyze it to improve our services, we do so based on our legitimate interest in safeguarding and improving our services.
Consent of the data subject — We will directly ask for your consent to process data:
Who has access to your information?
Our Affiliated Entities: EVOL may disclose personal information to companies under common control with EVOL for the purposes of operating our business, delivering, improving, and customizing our products or services, sending marketing and communications related to our business, payment processing, and for other legitimate purposes permitted by applicable law or otherwise with your consent.
Third Party Service Providers working on our behalf: We may pass your information to our third-party service providers, agents, subcontractors and other associated organizations for the purposes of completing tasks and providing services to you on our behalf (for example, mass email processing). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service. We require these vendors to keep your information secure and to not use it for their own marketing purposes without your explicit written consent or unless we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
Business Transactions: We may share your information during a corporate transaction like a merger, or sale of our assets. If a corporate transaction occurs, we will provide notification of any changes to control of your information, as well as choices you may have.
Consent: We may share your information in other ways if you have asked us to do so or have given consent. For example, with your consent, we post user testimonials that may identify you.
You have a choice about whether or not you wish to receive marketing information from us. If you do not want to receive direct communications from us, then you can select your choices by ticking the relevant boxes situated on the form on which we collect your information.
We will not contact you for marketing purposes by email, post, phone or text message unless you have given your prior consent. You can change your marketing preferences at any time by contacting us by email: firstname.lastname@example.org.
Where you have contacted or interacted with our sales, support or services teams and exchanged contact information, and there is a business relationship or contract with EVOL, or you have expressed to EVOL an interest to be contacted in the future for product or partnership activities, then EVOL will contact you as necessary for the performance of these activities. You can change your preferences by contacting us by email at email@example.com.
What security precautions do we take to protect the loss, misuse or alteration of your information?
When you give us personal information via the EVOL website, we take steps to ensure that it’s treated securely. Your personal information submitted via the EVOL website is encrypted and protected with software that uses 256 bit keys for TLS version 1.2.
Once we receive your information, we take steps to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We may analyze your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and reduce fraud risk.
Use of 'cookies'
It is possible to switch off cookies by setting your browser preferences. Turning cookies off may result in a loss of functionality when using our website.
Links to other websites
In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.
Your rights and your personal data
You have the following rights with respect to your personal data.
When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.
- The right to access personal data we hold on you
The accuracy of your information is important to us. We’re working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change email address, or if any of the other information we hold is inaccurate or out of date, please email us at: firstname.lastname@example.org. Once we have received your request we will respond promptly and in accordance with applicable regulations.
There are no fees or charges for the first request.
- The right to correct and update the personal data we hold on you
If the data we hold on you is out of date, incomplete or incorrect, you may inform us, and your data will be updated subject to our verification.
- The right to have your personal data erased
You may request that we erase the personal data we hold. When we receive your request, we will delete your personal data or inform you of the reason why it cannot be deleted (for example because we need it to comply with a legal obligation).
- The right to object to processing of your personal data or to restrict it to certain purposes only
You have the right to request that we stop processing your personal data or ask us to restrict processing. Upon receiving the request, we will contact you and let you know if we are able to comply or if we have a legal obligation to continue to process your data.
- The right to data portability
You have the right to request that we transfer some of your data to another controller. We will comply with your request, where it is feasible to do so, promptly and in accordance with applicable regulations.
- The right to withdraw your consent to the processing at any time for any processing of data to which consent was obtained
You can request to withdraw your consent by contacting us by email at: email@example.com.
- The right to lodge a complaint.
To exercise all relevant rights, queries or complaints please, in the first instance, contact EVOL via email at: firstname.lastname@example.org. If this does not resolve your complaint to your satisfaction, you may contact the applicable authority (for instance for the UK – Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF).
California Residents’ Privacy
If you are a California resident, you may ask for a list of third‑parties that have received your information for direct marketing purposes during the previous calendar year. This list also contains the types of information shared. We provide this list at no cost. We do not share your information with third parties for their own marketing purposes. If you are in Switzerland or the European Economic Area (EEA), you may have additional rights under data protection law. Transfers to the U.S. and Third Countries. If you reside in Switzerland or the European Economic Area ("EEA"), you understand and acknowledge that EVOL may transfer your personal data outside of Switzerland and the EEA for processing. By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA. Upon your explicit written request, EVOL may execute Standard Contractual Clauses approved by the European Commission for the benefit of the customer ("Customer SCCs") in order to ensure adequate protection for the Personal Data in accordance with the requirements of the EU General Data Protection Regulation. Our affiliated entities have entered into the Standard Contractual Clauses with respect to any personal data that is transferred outside the EEA; you may request a copy of these clauses from email@example.com.
If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.
If we wish to use your personal data for a new purpose, not covered by this Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
Review of this Policy
Email us at firstname.lastname@example.org