Update: 6 April 2022
1. Parties and Purpose
Evoluno, hosted at www.evoluno.com (hereinafter the "Site")
And the iOS/Android mobile application (hereafter "Application")
And access services to therapists and coaches
(hereinafter jointly the "Platform")
are an initiative of :
Avenue Arnaud Fraiteur 15/23
1050 Ixelles, Belgium
Company N° (ECB/VAT) : BE0758.358.272
(hereinafter "Evoluno" or the "Data Controller")
The term "User" refers to any user, i.e. any natural or legal person, who visits or interacts in any way with the Platform.
As such, Evoluno determines all the technical, legal and organizational means and purposes of processing Users' personal data. To this end, Evoluno undertakes to take all necessary measures to ensure that the processing of personal data complies with the Law of 30 July 2018, on the protection of individuals with regard to the processing of personal data (hereinafter, "the Law") and the European Regulation of 26 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter, "the Regulation").
Evoluno is free to choose any natural or legal person who processes users' personal data at its request and on its behalf (hereinafter the "Processor"). Where applicable, Evoluno undertakes to select a Processor offering sufficient guarantees as to the technical and organisational security measures for the processing of personal data, in accordance with the Law and the Regulation.
2. Processing of personal data
The use of the Site by Users may result in the communication of personal data. The processing of such data by Evoluno, in its capacity as Data Controller, or by service providers acting in the name and on behalf of Evoluno, will be in accordance with the Law and the Regulations.
Personal data will be processed by Evoluno, in accordance with the purposes mentioned below, via :
Individual analysis by the company
Aggregate analysis (anonymous, with samples of at least 5 people)
3. Purpose of the processing of personal data
In accordance with article 13 of the Regulations, the purposes of the processing of personal data are communicated to the User and are as follows:
1. Find the best therapist based on questionnaires
2. Identify user needs and trends
3. Contribute to the development of diagnostic tools and content recommendations
4. Personal data that may be processed
1. Information on psychological well-being
2. Physical health information
3. Personal details
The User has the right to withdraw consent at any time. Withdrawal of consent shall not compromise the lawfulness of the processing based on the consent previously given.
6. Storage period of Users' personal data
In accordance with Article 13 §2 of the Regulation and the Law, the Data Controller shall only keep personal data for the time reasonably necessary to allow the fulfilment of the purposes for which they are processed.
This duration is in any case less than : 2 years.
7. Recipients of data and disclosure to third parties
Personal data may be transferred to Evoluno's agents, employees, subcontractors or suppliers who offer adequate data security guarantees and who collaborate with Evoluno in marketing products or providing services. They act under the direct authority of Evoluno, and are responsible for collecting, processing or subcontracting such data.
In the event that the data is disclosed to third parties for direct marketing or prospecting purposes, the User will be informed beforehand so that he can express his consent to the use of his personal data.
8. Data Protection Officer (DPO)
The following person is appointed Data Protection Officer (hereinafter "DPO"): Alexandre Vandermeersch
The role of the DPO is to ensure the proper implementation of national and supranational provisions on the collection and processing of personal data.
The DPO can be contacted as follows: firstname.lastname@example.org.
9. Users' Rights
At any time, the User may exercise his rights by sending a message by e-mail to the following address: email@example.com, or a letter by post, enclosing a copy of his identity card to the following address: Avenue Tedesco 5, 1160 Brussels
a. Right of access
In accordance with Article 15 of the Regulations, Evoluno guarantees the User's right of access to his/her personal data. The User has the right to obtain access to said personal data as well as the following information:
the purposes of the treatment ;
the categories of personal data concerned ;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations ;
where possible, the intended period of storage of personal data or, where that is not possible, the criteria used to determine that period ;
the existence of automated decision making, including profiling, as referred to in Article 22(1) and (4) of the Regulation, and, at least in such cases, relevant information concerning the underlying logic and the importance and intended consequences of the processing for the data subject
The Data Controller may require payment of a reasonable fee based on administrative costs for any additional copies requested by the User.
Where the User submits this request electronically (e.g. via e-mail address), the information is provided in a commonly used electronic form, unless the User requests otherwise.
A copy of the User's data will be communicated to the User no later than one month after receipt of the request.
b. Right of rectification
Evoluno guarantees the user's right to correct and delete personal data.
In accordance with Article 16 of the Regulation, incorrect, inaccurate or irrelevant data may be corrected or erased at any time. The User first makes the necessary changes himself/herself from his/her user/other account, unless these changes cannot be made independently, in which case a request can be made to Evoluno.
In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom the personal data have been communicated of any rectification of the personal data, unless such communication proves impossible or involves a disproportionate effort. The Controller shall provide the data subject with information about these recipients if the data subject so requests.
c. Right to erasure
The User has the right to obtain the deletion of his/her personal data as soon as possible in the cases listed in article 17 of the Regulations.
Where the Controller has made the personal data public and is under an obligation to erase them pursuant to the previous paragraph, the Controller shall, taking into account the available technologies and the costs of implementation, take reasonable measures, including technical measures, to inform the other controllers processing such personal data that the data subject has requested the erasure by those controllers of any link to, or any copy or reproduction of, such personal data.
The two preceding paragraphs shall not apply to the extent that such processing is necessary:
to the exercise of the right to freedom of expression and information;
to comply with a legal obligation which requires the processing to be carried out in accordance with Union law or the law of the Member State to which the controller is subject, or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;
the establishment, exercise or defence of legal rights.
In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom the personal data have been communicated of any erasure of personal data or any restriction on the processing carried out, unless such communication proves impossible or involves a disproportionate effort. The controller shall provide the data subject with information about such recipients if the data subject so requests.
d. Right to restrict processing
The User has the right to obtain the limitation of the processing of his/her personal data in the cases listed in article 19 of the Regulations.
In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom the personal data have been communicated of any restrictions on the processing carried out, unless such communication proves impossible or involves a disproportionate effort. The Controller shall provide the data subject with information about such recipients if the latter so requests.
e. Right to data portability
In accordance with Article 20 of the Rules, Users have the right to receive from Evoluno their personal data in a structured, commonly used, machine-readable format. Users have the right to pass on such data to another data controller without Evoluno's interference in the cases provided for in the Rules.
Where the User exercises his right to data portability pursuant to the previous paragraph, he has the right to obtain that personal data be transmitted directly from one controller to another, where technically possible.
The exercise of the right of data portability shall be without prejudice to the right to erasure. This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
The right of data portability does not affect the rights and freedoms of third parties.
f. Right to object and automated individual decision making
The User has the right at any time to object to the processing of his or her personal data due to his or her particular situation, including the automation of the data by Evoluno. In accordance with Article 21 of the Regulations, Evoluno will no longer process personal data, unless there are legitimate and compelling reasons for the processing that prevail over the interests and rights and freedoms of the User, or for the ascertainment, exercise or defence of legal rights.
Where personal data is processed for canvassing purposes, the User has the right to object at any time to the processing of personal data concerning him/her for such canvassing purposes, including profiling insofar as it is related to such canvassing.
Where the data subject objects to the processing for the purposes of canvassing, the personal data shall no longer be processed for those purposes.
g. Right of complaint
The User has the right to lodge a complaint concerning the processing of his personal data by Evoluno with the Data Protection Authority, which is competent for the Belgian territory. Further information can be found on the website: https://www.autoriteprotectiondonnees.be.
Complaints can be submitted to the following addresses:
Data Protection Authority
Rue de la Presse 35, 1000 Brussels
Phone + 32 2 274 48 00
Fax: + 32 2 274 48 35
The User may also file a complaint with the Court of First Instance of his domicile.
a. General principles
A "Cookie" is a file that is temporarily or permanently deposited on the User's hard disk when consulting the Website, with a view to later connection. Thanks to cookies, the server recognises the User's computer.
Cookies may also be installed by third parties with whom Evoluno collaborates.
Some of the cookies used by Evoluno are necessary for the proper functioning of the Site, while others are used to improve the User's experience.
The User can personalise or deactivate cookies by setting their browser.
By using the Website, the User expressly agrees to the management of cookies as described in this article.
b. Type of cookies and purpose
Different types of cookies are used by Evoluno on the Site:
Technical cookies: these are necessary for the operation of the Website, allow the communication of the data entered and are intended to facilitate the User's navigation;
Cookies for statistical and audience measurement: these cookies allow the recognition of the User and are used to count the number of Users of the Website over a certain period of time. Since they also indicate browsing behaviour, they are an effective means of improving the User's browsing by displaying proposals and offers that may be of interest to him/her. They also allow Evoluno to identify and correct possible bugs on the Website.
Functional cookies: these cookies facilitate the use of the Website by retaining certain choices introduced (for example, user name or language);
Tracking Cookies: Evoluno uses tracking cookies via Google Analytics to measure Users' interaction with Site content and produce anonymous statistics. These statistics allow Evoluno to improve the Website. Google supports the explanation of these cookies at the following address: http://www.google.nl/intl/en_uk/policies/privacy/.
c. Retention period for cookies
Cookies are kept for the time necessary to achieve the intended purpose. The cookies that may be stored on the User's hard drive and their retention period are as follows:
d. Cookie management
If the User deactivates certain cookies, he/she accepts that the Website may not function optimally. Certain parts of the Website may therefore not be usable, or may only be partially usable.
If the User wishes to manage and/or delete certain cookies in this way, he can do so by using the following link(s):
For Users with a :
Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
Microsoft Edge: http://windows.microsoft.com/en-gb/windows-10/edge-privacy-faq
11. Limitation of liability of the Data Controller
The Website may contain links to other websites owned by third parties not related to Evoluno. Evoluno is not responsible for the content of these sites or their compliance with the Law and Regulations.
The holder of parental authority must give his/her express consent for a minor under 16 years of age to disclose personal information or data on the website. Evoluno strongly advises persons exercising parental authority over minors to promote responsible and secure use of the Internet. The Data Controller may not be held liable for collecting and processing information and personal data from minors under 16 years of age whose consent is not effectively covered by that of their legal parents or for incorrect data - particularly concerning age - entered by minors. Under no circumstances will personal data be processed by the Data Controller if the User specifies that he/she is under 16 years of age.
Evoluno is not responsible for the loss, corruption or theft of personal data caused in particular by the presence of viruses or as a result of computer attacks.
The Data Controller implements organisational and technical measures to guarantee an appropriate level of security for the processing and collection of data. These security measures depend on the costs of implementation in relation to the nature, context and purposes of the processing of personal data.
The Data Controller uses standard encryption technologies within the IT sector when transferring or collecting data on the Site.
14. Applicable law and jurisdiction