PRIVACY POLICY

 

Evoli management d.o.o. (“Evoli”, “we”, “our”, or “us”) is committed to protecting the privacy of individuals who visit our websites (»Vistiors«), subscribe to our services (»Users« and/or »Subscribers« or »Customers«), or register for our events. This Privacy Policy governs the collection, use and disclosure of personal information we receive through our Services (as defined in the Terms of Service), and covers the data you share with us through any of our websites, including but not limited to practicalmanager.com, or our online or mobile apps (“PracticalManager Services” or “Our Services”).

This Privacy Policy (the “Policy”) describes how PracticalManager collects, uses, and discloses information collected through the Service and Websites, and what choices you have with respect to such information.

By using any of our services, you consent to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. We encourage you to read this Policy before using any of our services. Your use of our services signifies that you agree with all terms of this Policy. Do not use any of our services if you disagree with any part of this Policy.

1. Who we are

PracticalManager is online SaaS product delivered by Evoli and associated companies dedicated to developing people and talent development to build General Business Excellent in business organisations.

 

2. What Type of User am I and Which Privacy Terms Are Applicable to Me?

PracticalManager has three different types of users depending on the product used. Please see the bullets below to determine which type of user you are, and then click the internal link to visit the privacy terms applicable to you. It is possible that you may use our service in different ways. If so, please review all applicable privacy terms. Also, don’t forget to review the General section, which contains privacy terms applicable to all users.

• Subscribers. We call users who use the Service as part of any tier of a paid subscription plan “Subscribers.” The Service features and functionalities available to Subscribers are determined by the specific terms agreed to between PracticalManager and the organization (e.g., your employer or another entity or person, called the “Customer”) that entered into a separate agreement that governs delivery, access, and use of the Service (for purpose of this Policy, the “Customer Agreement”). The Customer controls its instance of the Service and is the data controller of the information collected through the Service about Subscribers, and PracticalManager is a data processor of such information.
• Free Users. We call users who use a non-paid version of the Service “Free Users.” Free Users can access and use the Service and they have access to a more limited set of Service features and functionality than Subscribers. PracticalManager is the data controller of the information collected through the Service about Free Users.
• Site Visitors. We call users of the Websites “Visitors.” Visitors can be individuals who are simply browsing the Websites but who do not use the PracticalManagerService. Site Visitors can be Free Users or Subscribers who visit our websites to seek additional information about PracticalManager. PracticalManager is the data controller of the information collected through the website about Site Visitors.

 

2. What information we collect about you

The information we collect from Subscribers:

We do not require Subscribers to provide us with information. However, certain information, such as account log-in data, is required to provide you with access to the Service, and other information may be collected automatically as you use the Service.

1. The service. Through the service information is collected, used, and shared by PracticalManager in accordance with the Customer’s instructions, including any applicable terms in the Customer Agreement, or as required by applicable law. The Customer, determines its own, internal policies regarding storage, access, modification, deletion, sharing, and retention of Service content which may apply to your use of the Service. For example, a Customer may provide or remove access to the Service, enable or disable third party integrations, manage permissions, retention and export settings, transfer or assign teams, or share data.
2. Account Information. To set up your PracticalManager account, you or the Customer will provide us with basic information about you which may include your name, address, telephone number, email address, and password. You will then have the ability to provide optional profile information, such as a photograph or basic demographic data. With your permission, we may also upload calendar information stored on your mobile device to your account. If you submit payment information in connection with your use of the Service, we utilize a third party credit card payment processing company to collect payment information, including your credit card number, billing address, and phone number. In such circumstances, the third party service provider, and not Evoli, stores your payment information on our behalf.
3. Service Usage Information. As you use the Service, we collect information about how you use and interact with the Service (“Service Usage Information”). Such information includes:

• Device information – when you access the Service using a mobile device, we collect certain device information, including the type of device you are using, its operating system, and mobile network information, which may include your mobile phone number.
• Log files – when you use the Service, our or 3rd party servers automatically record information in server log files. These log files may include information such as your web request, IP address, browser type and settings, referring/exit pages and URLs, number of clicks, date and time stamp information, language preferences, data from cookies and similar technologies, and other such information.
• Location information – we collect and process general information about the location of the device from which you are accessing the Service (e.g., approximate geographic location inferred from an IP address).
• Service Use Metadata – when you interact with the Service, metadata is generated that provides high-level (non-content) information about the way you use the Service.

1. Other Information. You may provide us with information when you interact with us in other ways, such as when you submit requests or questions to us via forms or email (e.g., support forms, sales forms, user research participation forms); information you provide in connection with us, events, or research studies in which you choose to participate; beta testing; and requests for customer support and technical assistance (collectively, “Other Information”).

Information Collected from Third-Party Integrations. If you choose to use or connect to third-party integrations (e.g., Microsoft, Google, etc.) through the Service, or if you are required or permitted to do so by a Customer, such third parties may allow us to have access to and store additional information about your interaction with those services as it relates to your use of the Service. If you initiate these connections, you also understand that we will share information about you that is required to enable your use of the third-party integration through the Service. If you do not wish to have this information shared, do not initiate these connections. By enabling these connections, you authorize us to connect and access the information provided through these connections, and you understand that the privacy policies of these third parties govern such connections.

We collect the following information directly from you, or through the Service.

Usage Information

As you navigate our websites, we may collect information through the use of commonly used information gathering tools such as cookies and Web beacons. With it, we collect:

• Browser information (type and language)
• IP address
• Open / Click-through tracking URL: In some of our email communications, we use a “click-through tracking URL” that, when clicked, sends you to a different web address, which logs your click, before redirecting you to your expected destination.
• The actions you take on our websites (such as the web pages viewed and the links clicked, and time spent).
• Referrer information
• Event registrations

Personal Information

When you use our website to request information about us or our Services, register to our Services, register to attend an event we may collect the following personal information. We may gather some of this information from third party sources, as described in the section below titled “Information from Other Sources.”

• First Name & Last Name
• Email Address
• Phone number

Subscription Information

When you purchase our Services we will require you to provide us with the following:

• Business Name
• Billing details such as Credit Card Number & Paypal
• Mailing Address
• Business organisation tax ID number
• Quantity of users

Support communication

If we communicate with you to offer support through any medium (Phone, Chat, Email, & Messaging apps) we will collect and store the following information.

• Chat Transcripts
• Emails
• Phone call logs
• Phone call recordings

Integrated Services

You may be given the option to access or register for the Service through the use of your user name and passwords for certain services provided by third parties (each, an “Integrated Service”), such as through the use of your Google account, or otherwise have the option to authorize an Integrated Service to provide Personal Data or other information to us. By authorizing us to connect with an Integrated Service, you authorize us to access and store your name, email address(es) and other information that the Integrated Service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on each Integrated Service to understand what information that Integrated Service makes available to us and make changes as appropriate. Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Service.

Single sign-on

You may be able to log in to our Service using sign-in services such as Google, Facebook Connect, LinkedIn, Office 365, etc. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address.

Information from other sources

We may obtain information, including Personal Data, from third parties and sources other than the Service. These include publicly available sources of information like LinkedIn, Facebook, and Twitter. They also include our partners, mutual connections, advertisers, credit rating agencies, and Integrated Services. This information may be collected to facilitate our understanding of who you are and your needs, as well as to help us improve our products and services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy.

4. How we use the information that we collect

We will never disclose, share or sell your data without your consent unless required to do so by law. We use your information for the following purposes:

To provide you with information about our products and services

We use the information – other than Client Data – to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process Client Data solely in accordance with the directions provided by the applicable Client or User.

To improve the usefulness of our messaging to you

We use your click-through tracking data for various purposes, including to help us determine interest in particular topics and measure the effectiveness of our customer communications. You may grant or decline consent for this tracking from your Preferences page, accessible from the “Unsubscribe” or “Manage Preferences” link in the footer of any newsletter that we send to you.

To plan our events

We also use event registration information to plan and host corporate events, host online forums and social networks in which event Attendees may participate, and to populate online profiles for Attendees on our websites.

To respond to your requests

We use your contact information and other information shared with us via email and over other channels like chat and phone to respond to your requests.

To process your payments

We use credit card and PayPal information solely to process payment for the Services and events. We pass your billing information on to PayPal, our billing partners, who store your information securely for future billing as authorized by you.

To improve our website

We use website navigational information, IP address, browser type, browser language, referring URL, files accessed, errors generated, time zone, operating system and other visitor details collected in our log files to analyse trends, administer our website, track visitors’ movements and to improve our website. We link this automatically-collected data to other information we collect about you.

To improve our products and services

Your usage details such as time, frequency, duration, pattern of use, features used and the amount of storage used might be recorded by us and used to improve the Service. We also use your information with your consent, including:

1. Fulfil any other purpose disclosed to you and with your consent.
2. We post user testimonials on our website. These testimonials may include names, and other Personal Information and we acquire permission from our users prior to posting these on our website. We obtain the consent of each customer prior to posting any information on such a list or posting testimonials.
3. Collection and Use of Non-Personal Information. When you register for the Service  we may collect non-personal information data that does not permit direct association with any specific individual, such as your country and operating system. This information is used to help us improve our products and services.

Communications

We may use a Subscriber’s, Visitor’s or User’s email address or other information – other than Client Data – to contact that Visitor or User (i) for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the Client Data or Personal Data posted on the Service or with updates on promotions and events, relating to products and services offered by us and by third parties we work with. You may unsubscribe from email notifications by clicking on the unsubscribe link that provided in all email notifications or by sending an email to [email protected]. You cannot opt out of receiving transactional emails related to your account or use of the Services. You have the ability to opt-out of receiving any promotional communications as described below under “Your Rights and Choices.”

5. How we share the information that we collect

Except as described in this Policy, we will not intentionally disclose the Personal Data or Client Data that we collect or store on the Service to third parties without the consent of the applicable Visitor, User or Client. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

Unrestricted Information

Any information that you voluntarily choose to include in a Public Area of the Service, such as a public profile page, will be available to any Visitor or User who has access to that content.

Service Providers

We work with third party service providers who provide a website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.

Non-Personally Identifiable Information

We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Clients’, Users’ and Visitors’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service.

Reselling Partners

When you sign-up for a free trial through authorized partners or referral links, your personal details will be shared between PracticalManager and the authorized partner that you have signed-up through. We encourage you to check the privacy policy of our authorized partner before you sign-up for a free trial or any services. We may share your personal information with our authorized reselling partners in your region, solely for the purpose of contacting you about products that you have downloaded or services that you have signed up for. We will give you an option to opt out of continuing to work with that partner.

Law Enforcement, Legal Process, and Compliance

Please be aware that laws in various jurisdictions in which we operate may obligate us to disclose user information and the contents of your user account to the local law enforcement authorities under a legal process or an enforceable government request. In addition, we may also disclose Personal Information and contents of your user account to law enforcement authorities if such disclosure is determined to be necessary to protect PracticalManager’s rights, or for protecting the safety of our users, employees, or the general public.

Change of Ownership

In the event that PracticalManager is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information will be transferred as part of that transaction. This Privacy Statement will continue to apply to your information after transferring to the new entity. Client Data may be physically or electronically transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing the operation of the Service, and only if the recipient of the Client Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.

Legal bases for processing:

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have a legal basis for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:

1. We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services.
2. It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests.
3. You give us consent to do so for a specific purpose. Or
4. We need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because a third party (e.g. your employer) or we have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.

Our Representative Details For Data Subjects in the EU:

We value your data subject rights under GDPR according to Art 27 GDPR and provide you with an easy way to submit us privacy-related requests like a request to access or erase your personal data. If you want to make use of your data subject rights send you e-mail to [email protected].

Data Protection Officer

If you have any questions about this Privacy Policy or our privacy practices, please contact us by mail at [email protected]. We will never disclose, share or sell your data without your consent unless required to do so by law.

External Websites

Our Websites may provide links to other websites of third parties. We do not control and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.

6. How we handle Your Customer Data

You may electronically submit data or information to the Services for hosting and processing purposes (“Customer Data”). We will not review, share, distribute, or reference any such Customer Data except as provided in our Terms of Service, or as may be required by law. In accordance with our Terms of Service, we may access Customer Data only for the purpose of providing Services or preventing or addressing service or technical problems or as may be required by law.

7. How we store and secure the information we collect

Data Security

We maintain strict administrative, technical, and physical procedures to protect information stored on our computers/servers. We use industry-standard Secure Socket Layer (SSL) encryption technology to safeguard the account registration process and sign-up information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to building and files. We implement a variety of security measures to maintain the safety of your personal information and data you store in your account. Data stored in your account is only accessed by the our team when performing the migration, or support services. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. After a transaction, your private information (credit cards, social security numbers, financials, etc.) will not be stored on our servers. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. If you use our services or websites, responsibility for securing storage and access to the information you submit rests with you and not PracticalManager. If you have any concerns regarding the security of your data, please write to us at [email protected] with any questions.

Data Retention

We only retain the Personal Data collected from a Subscriber, User or Customer for as long as the account is active or otherwise for a limited period of time as long as we need it to fulfil the purposes for which we have initially collected it unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:

1. the contents of closed accounts are deleted within 3 months of the date of closure
2. backups are kept for 3 months
3. billing information is retained for a period of 5 years
4. information on legal transactions between Customer and PracticalManager is retained for a period of 5 years.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

8. How we transfer your personal information internationally

International transfers to third parties

Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information of customers in the EU we make use of the standard contractual clauses.

9. Your Rights and Choices

We acknowledge that you have the right to access your personal information. Depending on the country in which you reside, you may have the following data protection rights:

• To access; correct; update; port; delete; restrict; or object to our processing of your Personal Information.
• You can manage your individual account and profile settings within the dashboard provided through the Service, or you may contact us directly by emailing us at [email protected]. You can also manage information about your users through the Service.
• We take reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date.
• The right to complain to a data protection authority, about the collection and use of Personal Information, please contact your local data protection authority.
• Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing the consent will not affect the lawfulness of any processing we conducted before your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

We respond to all requests we receive from individuals wishing to exercise their data protection rights under applicable data protection laws. We may ask you to verify your identity to help us respond efficiently to your request. Please note we will retain and use your data, including server/backup copies, to comply with our legal obligations, resolve disputes, and enforce our agreements. We may decline to process change or deletion requests that require disproportionate technical effort or jeopardize the privacy of others.

10. Other Important Privacy Information

Cookies

PracticalManager and our partners use cookies or similar technologies (such as web beacons and JavaScript) to analyse trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. Please read our Cookie Policy to find out more about how we use cookies on our Websites and how to manage your cookie preferences.

Third Party Analytics

We employ the services of third-party software to collect, aggregate, and analyse data about our website content, users, and their use of it. The software we use includes Google Analytics and Google Ads. The information these applications collect is not personally identifiable and is used to improve website functionality and content. To this end, these third parties may employ the use of cookies and/or pixel tags to facilitate tracking website users. These third party cookies are not tied to your Personal Information. We do not have access to these cookies nor are we responsible for them.

Third Party Products and Services Links from our website

Our Service contains links to, or content from third-party websites and other products and services. You are advised to verify the privacy practices of such other websites. We are not responsible for the manner of use or misuse of information made available by you at such other websites. We encourage you not to provide Personal Information, without assuring yourselves of the Privacy Policy Statement of other websites.

Clear Gifs and Log Files

We and our third party partners use technologies such as web beacons in analysing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We link this automatically-collected data to other information we collect about you.

12. Our Policy Toward Children

We do not collect any information from anyone under 13 years of age. Our website, products, and services are all directed to people who are at least 13 years old or older. If you become aware that your child has provided us with personal information without your consent, please contact us at [email protected].

13. Changes to this Privacy Policy

This Privacy Policy may be updated from time to time. If we make changes, we will revise this Privacy Policy to reflect such changes and revise the effective date included at the beginning of this policy. We may provide you additional notice (such as to your e-mail address) if the changes are material. Your use of the Service following any such notice will signify and constitute your assent to and acceptance of such revised Privacy Policy.

14. Terms and Conditions

Please refer to our latest terms of service to learn about the disclaimers and limitations of liability governing the use of PractialManager.

15. Contact Us

If you have questions regarding this Privacy Policy, Terms of Service, User Agreement, or our data handling practices, please feel free to contact us directly:

By email at [email protected].

By mail at: Evoli management d.o.o., Smledniška 140, SI-4000 Kranj, Slovenia.

 

16. Definitions

“Client” and »Subscriber« means a customer of PracticalManager, a person who subscribed to our Service either on an organisation’s account or as an individual.

“Client Data“ means personal data, reports, addresses, and other files, folders or documents in electronic form that a User of the Service stores within the Service.

“Google User Data” means Your data synced from Google such as Contacts, Emails, Calendar, Documents, and Attachments.

“Personal Data” means any information relating to an identified or identifiable natural person.

“User” means an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.

“Visitor” means an individual other than a User, who uses the public area but has no access to the restricted areas of the Site or Service.