Update: August 22, 2023
1.Parties and Purpose
The website
Evoluno, hosted at the following address www.evoluno.com and app.evoluno.com (hereinafter the "Site")
And the iOS/Android mobile application (hereinafter the "Application")
Evoluno
And access services to therapists and coaches
(hereinafter jointly the "Platform")
are an initiative of :
Evoluno srl
Avenue Arnaud Fraiteur 15/23
1050 Ixelles
Company no. (ECB/VAT): BE0758.358.272
E-mail: hello@evoluno.com
(hereinafter "Evoluno" or the "Data Controller")
Evoluno establishes this Privacy Policy to inform Platform Users in a transparent manner of how personal data is collected and processed by Evoluno.
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 personal data is processed in accordance with the Law of July 30, 2018, on the protection of individuals with regard to the processing of personal data (hereinafter, "the Law") and the European Regulation of April 26, 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 individual or legal entity that processes users' personal data at its request and on its behalf (hereinafter the "Subcontractor"). Where applicable, Evoluno undertakes to select a Subcontractor offering sufficient guarantees as to the technical and organizational security measures for the processing of personal data, with regard to 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 comply with the Law and the Regulation.
Personal data will be processed by Evoluno, in accordance with the purposes cited below, via:
Individual analysis by the company Aggregate analysis (anonymous, with samples of at least 5 people)
3. Purpose of processing personal data
1. Primary Data Processing Purpose:
Provision of Treatment and Therapy: The platform may collect and process personal data to provide mental health treatment and therapy services to individuals. This includes analyzing user input, monitoring progress and providing personalized recommendations and interventions based on information provided by the user. The platform also enables users to find a therapist matching their needs and preferences.
2. Secondary Data Processing Purposes:
User Account Management: The platform may collect and process personal data to manage user accounts, including user registration, authentication and profile management. This data processing purpose is necessary to enable individuals to access and use the mental health platform's features and services, including finding a therapist.
Statistical Analysis and Research: The platform may process anonymized or pseudonymized data for statistical analysis and research purposes. This can help improve the effectiveness of the platform's services, understand user behavior and preferences, and contribute to the advancement of mental health research. It is essential to ensure that all data used for research purposes is properly anonymized and that individuals cannot be identified from the results.
4. Personal data likely to be processed
The User consents, when visiting and using the Site, to Evoluno collecting and processing, in accordance with the terms and principles described in this Privacy Policy, the following personal data:
1. Information on psychological well-being
2. Physical health information
3. Personal details
5. Consent
By accessing and using the Platform, the User declares that he/she is aware of and gives his/her free, specific, informed and unambiguous consent to the processing of his/her personal data. This agreement relates to the content of the present Privacy Policy.
Consent is given by the positive act whereby the User has ticked the box offering the Privacy Policy as a hyperlink. This consent is an indispensable condition for carrying out certain operations on the Site or for allowing the User to enter into a contractual relationship with Evoluno. Any contract between Evoluno and a User relating to the services and goods offered on the Platform is subject to the User's acceptance of the Privacy Policy.
The User consents to the Processing Manager processing and collecting, in accordance with the terms and principles included in this Privacy Policy, his/her personal data that he/she communicates on the Platform or on the occasion of the services offered by Evoluno, for the purposes indicated above.
The User has the right to withdraw his/her consent at any time. Withdrawal of consent does not compromise the lawfulness of processing based on consent previously given.
6.Retention period for Users' personal data
In accordance with Article 13 §2 of the Regulation and the Law, the Data Controller only retains personal data for as long as is reasonably necessary to enable the purposes for which it is processed to be fulfilled.
This period is, in all cases, less than: 3 years
7.Recipients of data and disclosure to third parties
Personal data may be transmitted to Evoluno's employees, collaborators, subcontractors or suppliers who offer adequate data security guarantees, and who collaborate with Evoluno in the marketing of products or the provision of services. They act under the direct authority of Evoluno, and are in particular responsible for collecting, processing or subcontracting such data.
In all cases, data recipients and those to whom such data has been disclosed comply with the contents of this Privacy Policy. Evoluno assures that they will process such data solely for the intended purposes, in a discreet and secure manner.
In the event that data is disclosed to third parties for direct marketing or prospecting purposes, the User will be informed in advance so that he/she may express his/her consent to the use of his/her personal data.
8.Data Protection Officer (DPO)
The following person is appointed Délégué à la Protection des Données or Data Protection Officer (hereinafter "DPO"): Alexandre Vandermeersch
The role of the DPO is to ensure the proper implementation of national and supranational provisions regarding the collection and processing of personal data.
The DPO can be contacted as follows: alexandre.vandermeersch@evoluno.com
9.Users' rights
At any time, Users may exercise their rights by sending a message by e-mail to the following address: hello@evoluno.com, or a letter by post addressed, enclosing a copy of their identity card to the following address: Avenue Tedesco 5, 1160 Brussels
a. Right of access
In accordance with Article 15 of the Regulation, Evoluno guarantees the User the 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 processing;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular recipients who are established in third countries or international organizations;
where possible, the intended retention period of the personal data or, where this is not possible, the criteria used to determine this 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, useful information concerning the underlying logic, as well as the significance and anticipated consequences of such 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 makes such a request electronically (via the e-mail address, for example), the information will be provided in a commonly used electronic form, unless the User requests otherwise.
The copy of his or her 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 the right to rectify and delete personal data.
In accordance with Article 16 of the Regulation, incorrect, inaccurate or irrelevant data may be corrected or deleted at any time. The User shall first make the necessary changes himself from his user/other account, unless they cannot be made autonomously, in which case the request may be made to Evoluno.
In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom personal data has been communicated of any rectification of personal data, unless such communication proves impossible or requires disproportionate efforts. The Data Controller shall provide the data subject with information about such recipients if he or she so requests.
c. Right to erasure
The User has the right to obtain the erasure of his/her personal data as soon as possible in the cases listed in Article 17 of the Regulation.
Where the Data Controller has made the personal data public and is required to erase it pursuant to the preceding paragraph, the Data Controller shall, taking into account available technologies and implementation costs, take reasonable steps, including technical steps, to inform other Data Controllers processing such personal data that the Data Subject has requested the erasure by such Data Controllers of any link to such personal data, or any copy or reproduction thereof.
The two preceding paragraphs shall not apply insofar as such processing is necessary:
for the exercise of the right to freedom of expression and information;
to comply with a legal obligation which requires processing and which is laid down by Union law or by the law of the Member State to which the controller is subject, or in order to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;
for the establishment, exercise or defence of legal claims.
In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom personal data has been communicated of any erasure of personal data or restriction of processing carried out, unless such communication proves impossible or would require disproportionate efforts. The data controller shall provide the data subject with information on such recipients upon request.
d. Right to limit 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 Regulation.
In accordance with Article 19 of the Regulation, the Controller shall notify each recipient to whom the personal data has been communicated of any limitation of the processing carried out, unless such communication proves impossible or requires disproportionate efforts. The Controller shall provide the data subject with information about such recipients if the data subject so requests.
e. Right to data portability
In accordance with Article 20 of the Regulation, Users have the right to receive from Evoluno personal data concerning them in a structured, commonly used and machine-readable format. Users have the right to transmit this data to another data controller without Evoluno hindering this in the cases provided for by the Regulation.
When the User exercises her right to data portability pursuant to the previous paragraph, she has the right to obtain that personal data be transmitted directly from one data controller to another, where technically possible.
The exercise of the right to data portability is without prejudice to the right to erasure. This right does 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 to data portability does not infringe 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/her personal data due to his/her particular situation, including the automation of data carried out by Evoluno. In accordance with Article 21 of the Regulation, Evoluno will no longer process personal data unless there are compelling legitimate grounds for the processing which override the interests and rights and freedoms of the User, or for the establishment, exercise or defence of legal claims.
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 or her for such canvassing purposes, including profiling insofar as it is linked to such canvassing.
Where the data subject objects to the processing for canvassing purposes, the personal data is no longer processed for such purposes.
g. Right of complaint
The User has the right to lodge a complaint concerning the processing of his/her personal data by Evoluno with the Data Protection Authority, competent for Belgian territory. Further information can be found on the website: https://www.autoriteprotectiondonnees.be.
Complaints can be lodged at the following addresses:
Data Protection Authority Rue de la Presse 35, 1000 Brussels Tel. + 32 2 274 48 00 Fax. + 32 2 274 48 35 E-mail: contact@apd-gba.be
The User may also lodge a complaint with the court of first instance of his place of residence.
10. Cookies
The Site uses cookies to distinguish between Users of the Site. This makes it possible to provide Users with a better browsing experience and to improve the Site and its content. The purposes and terms of cookies are contained in this article.
a. General principles
A "Cookie" is a file deposited temporarily or permanently on the User's hard disk when consulting the Website, with a view to subsequent connection. Thanks to cookies, the server recognizes 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 Website, while others enable the User's experience to be improved.
The User can personalize or deactivate cookies by setting their browser parameters.
By using the Website, the User expressly agrees to the management of cookies as described in this article.
b. Type of cookies and purposes
Various types of cookies are used by Evoluno on the Site:
Technical cookies: these are necessary for the operation of the Website, enable the communication of data entered and are intended to facilitate the User's browsing;
Statistics and audience measurement cookies: these cookies enable the User to be recognized and are used to count the number of Users of the Website over a certain period. Since they also indicate browsing behavior, they are an effective means of improving the User's browsing experience, by displaying proposals and offers likely to be of interest. They also enable Evoluno to identify possible bugs on the Website and correct them.
Functional cookies: these cookies facilitate use of the Website by retaining certain choices entered (for example, user name or language);
Tracking cookies: Evoluno uses tracking cookies via Google Analytics, to measure Users' interaction with the content of the Website and produce anonymous statistics. These statistics enable 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. Cookie retention period
Cookies are retained for the time necessary to achieve the intended purpose. The cookies likely to be stored on the User's hard disk and their retention period are as follows:
________
d. Cookie management
If the User does not want the Website to place cookies on his/her hard disk, he/she can easily manage or delete them by modifying his/her browser settings. Browser programming also enables the User to receive a notice or notification as soon as a Website uses cookies, and thus decide whether to accept or reject them.
If the User deactivates certain cookies, he accepts that the Website may not function optimally. Certain parts of the Website may not be usable, or may only be partially usable.
If the User wishes to manage and/or delete certain cookies, he/she may do so by using the following link(s):
For Users with the following browser:
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
Chrome: https://support.google.com/accounts/answer/61416?hl=fr
Firefox: https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences
Safari: https://support.apple.com/kb/ph21411?locale=fr_CA
If the User refuses to accept Google Analytics cookies, he/she is invited to configure his/her browser accordingly at the following website: http://tools.google.com/dlpage/gaoptout.
11. Limitation of the data controller's liability
The website may contain links to other websites owned by third parties unrelated to Evoluno. Evoluno is not responsible for the content of these sites and their compliance with the Law and Regulations.
The holder of parental authority must give his/her express consent for a minor under the age of 16 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 cannot be held responsible for collecting and processing information and personal data from minors under the age of 16 whose consent is not effectively covered by that of their legal parents, or for incorrect data - in particular concerning age - entered by minors. Under no circumstances will personal data be processed by the Data Controller if the User specifies that he or 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.
12. Security
The Data Controller implements organizational and technical measures to guarantee a level of security appropriate to the processing and collection of data. These security measures depend on the costs of implementation with regard to the nature, context and purposes of the personal data processing.
The Data Controller uses standard encryption technologies within the IT sector when transferring or collecting data on the Site.
13. Modification of the Privacy Policy
Evoluno reserves the right to modify the present Privacy Policy in order to comply with legal obligations. The user is therefore invited to consult the Privacy Policy on a regular basis in order to take note of any modifications and adaptations. Any such modification will be posted on the Site or sent by e-mail for enforceability purposes.
14. Applicable law and jurisdiction
This Privacy Policy is governed exclusively by Belgian law. Any disputes will be brought before the courts of the judicial district of Evoluno's registered office.
15. Contact
For any questions or complaints relating to this Privacy Policy, the User may contact the Data Controller at the following address: hello@evoluno.com
