Everledger’s Privacy Policy

Last modified: 31th May 2021

Everledger Privacy Notice 

Introduction 

To keep this Notice simple, we have not provided a Definition Section. Any capitalized word in this Notice that is not defined in the text itself shall have the terms defined by the General Data Protection Regulation (“GDPR”) in its version as of the date this Notice was last modified on. 

Your privacy is important to Foreverhold Limited (71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ) and its employees and subsidiaries which is the holding company of the Everledger group of companies (“Everledger Group”). “Everledger” “Everledger“, “us“, “our“) and we are committed to protecting your Personal Data. This Privacy Notice (“Notice“) relates to our use of your Personal Data when you interact with us through our Everledger website(s) (“Everledger Sites”), social media or adverts and content on third party websites (collectively “Everledger Content“) or otherwise engage with us, for example by contacting Customer Services, attending an event, tradeshow or other Everledger event. 

This Notice explains who we are; what information we collect about you; how we use it (including who we share that information with); our use of cookies; and your rights and choices regarding your Personal Data.

We are accountable for the Personal Data you provided to us; however, as we may share your Personal Data within our group, other Everledger entities may also use your information in accordance with this Notice.  

If you have any questions or concerns about our use of your Personal Data, then please contact us using the contact details provided in the section “How do I contact Everledger?” of this Notice. 

Quick links 

We encourage you to take the time to review this Notice in full to make sure you are informed. However, if you only want to access a particular section of this Notice, then you can jump directly to that section:  

Who is Everledger?  

• What information does Everledger collect about me? 
• How does Everledger use my information? 
• Does Everledger use cookies and other similar technologies? 
• Does Everledger share my Personal Data with anyone? 
• What are my data protection rights?  
• How can I exercise my rights? 
• How do I stop receiving email alerts? 
• For how long does Everledger keep my information? 
• Does Everledger transfer my information to other countries? 
• Is my information secure? 
• What if I access a website through a Everledger Site? 
• How old do I have to be to use the Everledger Sites or other Everledger digital offerings? 
• Does this Notice ever change? 
• How do I contact Everledger? 

 

1. Who is Everledger?  

Everledger is an independent digital transparency company helping businesses surface and converge asset information, using a symphony of technologies including blockchain, artificial intelligence, intelligent labelling and Internet of Things. 

• What information does Everledger collect about me? 

The Personal Data that we may collect about you broadly falls into the following categories:

A. Information that you provide directly 

When you engage with Everledger, either online or in person, we may ask you to provide us with Personal Data about you. For example, we may ask you to provide us with your contact details to register an account with us, to sign up to receive our newsletters or information about our products or events, receive job offers or financial communications and/or to submit enquiries to us.  

You may also provide us with your Personal Data in other ways, such as if you contact us in relation to employment opportunities; purchase products or communicate with us through social media or our customer services teams;, participate in our promotions,, or interact with us at trade shows or our other events. The Personal Data that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point when we ask you to provide it.   

We may collect: 

• Identification information, for example, your first name, last name, email address, postal address, date of birth, phone number, gender, country of residence, lifestyle/interests, appearance, login name, answers to security questions; 
• Transaction information, for example, details regarding your transactions with us, including information about the purchases you made and the date and time that you made the purchase insofar as this information does constitute a Personal Data; 
• Your opinions or other information, for example, if you review the products you have purchased from us, provide information about products, and Everledger and products you use insofar as this would constitute a Personal Data.

B. Information that we collect automatically

When you visit the Everledger Sites, engage with Everledger Content, or with us digitally, we may collect certain information automatically from your computer, tablet or mobile phone (a “Device“). In some countries, including countries in the European Economic Area, Japan, or New Zealand, this information may be considered Personal Data under applicable data protection laws and/or GDPR. 

Specifically, the information we collect from you automatically may include information like your IP address, Device type (i.e., make and model), unique device identification numbers, browser-type, time zone settings, broad geographic location (e.g. country or city-level location) and other technical information. With your consent, some of the Everledger Sites may also collect your precise location information from your Device to provide location-based services. You may change your preferences at any time by adjusting the settings on your Device. 

We may also collect information about how your Device has interacted with us, including the pages accessed and links clicked, how you navigate to and from the Everledger Sites and Everledger Content (such as how you scroll over the Everledger Sites and Everledger Content, which parts you click and how long you spend on each page), your preferences, the products and/or services that you have viewed or searched for, crashes and download errors and response times. 

Some of this information may be collected using cookies and similar tracking technology, during your online shopping, as further explained in the section “Does Everledger use cookies and other similar technologies?” below. 

C. Information that we obtain from third party sources 

From time to time, we may receive information about you from third party sources, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your Personal Data to us. 

Our third-party sources, and the types of information we collect from them, include 

• Our retailers, distributors and third party Everledger partners, for example, may pass information to us including your first name, last name, email address, postal address, phone number, gender, browsing patterns, limited geo-location and device identifiers, click through and other cookie data, demographic information including information about your appearance and information in relation to products purchased in stores and services requested using their websites and/or applications if you have authorized them to do so. 
• Our technology partners and market research organizations, for example where permitted by applicable data protection law, our preferred technology partners may share information with us, including your browsing patterns, limited geo-location and device identifiers. 

3. How does Everledger use my information? 

A. We will use your Personal Data for the following purposes: 

We will use the personal data provided above in combination with your purchase history and other personal data that you share voluntarily with our sales assistants or otherwise (e.g., via social media, cookies, etc.) (hereinafter your “Personal Data”) for the following purposes:  

• Data analytics, market research purposes (surveys, customer satisfaction, etc.) and data enrichment, on the basis of our legitimate interests in analyzing and learning how customers use and interact with Everledger in order to improve products, services and our business in general. This includes second party data matching (i.e., the activity of matching and sharing trusted partner data where two individual brands contract together to match their own data through clients unique identifiers and reidentification, i.e., enriching our database with additional client insight gathered through activities on our digital media). 
• Global or local marketing purposes (to communicate with you on Everledger updates about our products and services, invitations and other marketing communications that may be of interest to you by one or several of the following channels: SMS, MMS, e-mail, paper mail, internet, social media or telephone; and for customizing your experience with us to your interests and shopping habits (e.g., tailored communications) and improving our services, notably via profiling, including conducting lookalike targeting campaigns by the selection of your advertising impressions across our websites, on the basis of your consent. To provide you with email alerts that you might be interested in (and with your consent where required), for example, we may use your information to keep you up to date with our latest products, services, surveys, announcements, and other upcoming events, sweepstakes, contests promotions and competitions via our newsletters, emails, or other communications.  
• To provide you with the products and services that you have requested, to administer our relationship with you and to carry out our obligations arising from the relationship between you and us, including internal accounting and administration purposes, to process payment for purchases or other services and to create and manage your account. 
• To verify your identity, for example we may use your date of birth to determine that you are old enough to use our services, or your email address to determine if you already have an account with the relevant Everledger Site. 
• To provide a personalized service, for example we use your information to provide you with personalized recommendations for our products that we think you might like, tailor Everledger Content to better suit your interests or, at your request and where available, to offer personalized and customized products. We will also use your Personal Data across the Everledger Sites to provide a seamless user experience. 
• These advertisements are either: (i) “contextual” (meaning they are presented due to the webpage that you are viewing); or (ii) “behavioral advertising” or “interest-based advertising” (i.e. where advertisements are shown to you based upon your interests which we have inferred from your information including demographic, geographic and interest-based data). We may use tailored advertising to specifically include or exclude individuals who have registered for our products and services to ensure that you are provided with information about those products or services that are most relevant to you. To do this, we may track your browsing activity across different websites, different Devices and/or different applications. We may match your browsing activity on one Device, such as your mobile phone, with your browsing activity on another device, such as your tablet, to ensure our advertising is tailored to you. If you longer wish to see tailored advertising, you may be able to amend your cookie preferences (see: section: “Does Everledger use cookies and other similar technologies?”). In addition, some third-party sites allow you to stop seeing advertisements from specific advertisers on that site, so you should also check your preferences on those websites. 
• For non-marketing communications, for example we may use your Personal Data to communicate with you, important information in relation to your account, the service you have requested or other non-marketing communications. This includes: (i) emailing you to verify your identity when you sign-up; (ii) emailing you where you have requested a password and/or username reset; (iii) notifying you that a particular service has been suspended for maintenance or terminated; (iv) letting you know that we have updated this Notice or our Terms of Use; or (v) letting you know about any products or services that you have requested or purchased. We will never contact you to ask for your password. Please be careful if you receive any communications from people requesting this information. 
• To provide the best service to our customers and clients, for example, we may use your Personal Data to process and respond to your questions and/or inquiries. 
• For site optimization and management, for example we may use your Personal Data to: 
• administer the Everledger Sites, Everledger Content and our other digital offerings, including the services and products offered through those Everledger Sites; 
• ensure the security of our networks and of your information; 
• customize your future visits to the Everledger Sites and our other digital offerings based on your interests to ensure the most user-friendly online navigation experience; 
• improve the Everledger Sites and our other digital offerings (including to fix operational problems such as pages crashing and software bugs); and 
• provide services to our partners such as tools, analyses, data and insights to see how their website or mobile applications are used. 
• For product development and business development purposes, for example, we will use information we collect from you to improve our products and develop new products. 
• For fraud prevention and detection purposes and to protect and defend the rights and property of Everledger, our employees and our business partners in compliance with applicable laws, regulations and international conventions. 
• For employment application purposes, for example, if you contact us in relation to your employment prospects we will use your Personal Data to consider you for current and future employment opportunities and to contact you with respect to employment opportunities at Everledger that you have expressed interest in. Depending on how you contact us, a separate notice may apply to the processing of your employment prospects information (our candidacy notice).   

D. On what basis can Everledger use my information in this way? 

We are required to satisfy one or more of the reasons set out by applicable data privacy law before we can collect and use your Personal Data.

Generally, our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally rely on one or more the following legal bases to collect and use your Personal Data: 

Legal basis	How we use Personal Data
Taking steps to or Performance of a contract	Using your information may be necessary for us to perform our obligations under a contract with you or with a view to entering into such a contract. For example, where you have: (i) requested services and/or products from us, we will need to use your information to provide those services and/or products that you have requested; or (ii) approached us in relation to employment opportunities, the collection and use of your Personal Data is necessary to enable us to assess your application
Compliance with our legal obligations	The collection and use of your Personal Data may be necessary to enable us to meet our legal obligations. For example, if you are a business customer we need to process your information to verify your identity and undertake necessary due diligence checks
Pursuing our legitimate interests	Where such processing is not overridden by your rights, we are permitted to use your Personal Data to pursue our legitimate interests, for example to operate the Everledger Sites and our other digital offerings, to improve our products, the Everledger Sites and our other digital offerings, to undertake marketing, or otherwise to help us achieve our purpose to empower imagination. We may have other legitimate interests and if appropriate we will make this clear to you at the relevant time.
Consent	In some limited circumstances, we rely on your consent to collect and use your Personal Data. For example, we rely on consent: (i) where you have approached us in relation to employment opportunities and have provided us with sensitive Personal Data, such as information in relation to your racial and ethnic origin, sexual orientation, religion, physical and mental health, disabilities or trade union membership; or (ii) in relation to creating a profile about you to send personalized e-marketing or communication from Everledger. If we rely on consent, this will be made clear to you at the time we request your information. You can withdraw your consent at any point by using the mechanism provided at the time, or by contacting us using the contact details provided in the section “How do I contact Everledger?” of this Notice.

You may not always be required to provide the Personal Data that we have requested. However, if you choose not to provide certain information, you may not be able to take advantage of some of our services. Any information that is so required is clearly marked as mandatory. If you would prefer that we not collect certain Personal Data from you, please do not provide us with any such information, or opt out of providing this information where applicable. 

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data). 

If we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), these interests will normally be as set out in this Notice; however, if this changes we will make clear to you at the relevant time what those legitimate interests are. 

If you have any questions or need further information concerning the legal basis on which we collect and use your Personal Data, please contact our Data Protection Team. Details for how to contact our Data Protection Team can be found in the section “How do I contact Everledger?” 

4. Does Everledger use cookies and other similar technologies? 

When you access the Everledger Sites, view or interact with Everledger Content or otherwise communicate with us digitally, Everledger and our partners may place small data files on your Device, known as “cookies”, to collect and use Personal Data about you, including to serve interest-based advertising. Learn more about cookies and other similar technologies, including how to amend your cookie settings by referring to our Cookie Policy.  

5. Does Everledger share my Personal Data with anyone? 

We may disclose your Personal Data to the following categories of recipients: 

• Within Everledger’s group of companies: We may make your Personal Data available to other entities within the Everledger group, including those entities listed on our website, to allow us to provide our services to you, for the purposes described in this Notice, or as notified to you when we collect your Personal Data. 
• With third parties for marketing purposes: Certain promotions and events sponsored by Everledger, or certain portions of the Everledger Sites, may offer you the opportunity to consent to receive marketing communications from Everledger’s business partners such as Everledger’s licensors or promotion co-sponsors. If you have given your consent, your information may be used by such third party for such purposes; 
• With our service providers: Everledger engages third party service providers to perform functions on Everledger’s behalf (for example, to support the delivery of our products, or the Everledger Sites). This includes but is not limited to sharing information with the following types of service providers: 
• providers of marketing and customer relationship management databases and data management platforms – that enable Everledger to manage your information in a safe and efficient manner; 
• providers of blockchain technology – that enable Everledger to record the lifecycle of its products;
• data analysis firms – that provide insights and help us to analyze trends using the data that we and they hold;  
• customer support specialists – that provide customer support services on our behalf for Everledger’s products and services; 
• fulfillment companies – this include companies that coordinate email campaigns, sweepstakes, contests or promotions on our behalf;  
• application development and web-hosting companies – to enable the Everledger Sites to be hosted on the internet; 
• information technology and related infrastructure providers; 
• email and paper mail delivery providers; and 
• audit and similar corporate professional service providers. 
• As part of a business transfers: Everledger may disclose your Personal Data to an actual or potential buyer (and its agents and advisers) in relation to any actual or proposed divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding in compliance with applicable laws and regulations; 
• To comply with laws: Everledger may disclose your Personal Data to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your interests or those of any other person; and 
• To any other person with your consent to the disclosure and for a Legitimate Interest: contractual agreement, overriding legitimate interest, legal or compliance obligation. 

6. What are my data protection rights? 

Subject to applicable data protection law (including limitations provided by that law), you may also have the following rights: 

• The right to request access to Personal Data, which enables you to receive confirmation as to whether or not we are processing your Personal Data and information about that processing, and to access your Personal Data 
• The right to update and/or correct inaccurate Personal Data 
• The right to request that we erase (delete) your Personal Data in certain circumstances 
• The right to restrict (block) the processing your Personal Data 
• The right to object to our processing of your Personal Data (including any processing for direct marketing purposes) for reason, when the processing is based on our legitimate interests 
• The right to object to our processing of your Personal Data for direct marketing purposes. More information on how to stop receiving direct marketing can be found in the section marked, “How do I stop receiving email alerts?” 
• The right to request portability, which means providing you, or a third party that you designate, a machine-readable copy of your Personal Data  
• The right to withdraw your consent, if applicable. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent 
• You have the right to lodge any complaints with a relevant supervisory authority 
• In some countries, you have the right to define general or specific directives regarding the fate of your Personal Data after your death. 

7. How can I exercise my rights? 

You can exercise these rights by contacting us using the information provided in the section “How do I contact Everledger?” of this Notice. We respond to all requests we receive from data subjects wishing to exercise their data protection rights in accordance with applicable data protection laws and/or the GDPR and we may require reasonable documentation to verify your identity prior to granting your request. 

If you have any questions or concerns about how we use your Personal Data, please do not hesitate to let us know.  

You can exercise your data rights using this online form https://everledger.gdprform.io/en

8. How do I stop receiving email alerts? 

Everledger will consider your consents for marketing and profiling as a YES if you opted in, until you either contact Everledger to ask us to remove or change such consent or, after 5 years without any Contact Initiated by You. 

We will only send you email alerts if you have agreed to this, or if we are otherwise permitted by law. If at any time you decide that you no longer wish to receive email alerts from us, you may opt out by clicking on the relevant ‘unsubscribe’ link in the email you receive, by sending us an email, or by contacting us using the contact details in section “How do I contact Everledger?” of this Notice.  

Please note that while we will honor your request to stop receiving email alerts, we will continue to send you service-related communications such as emails confirming purchases or surveying the quality of our services through the Everledger Sites and keep your information for record keeping purposes. 

9. For how long does Everledger keep my information? 

We will retain your information where we have an obligation or ongoing legitimate business need to do so (for example, to provide you with access to the Everledger Sites or other digital offerings you have requested, to provide you with a product you have purchased or is under warranty, or to comply with applicable legal, tax, or accounting requirements). 

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

10. Does Everledger transfer my information to other countries? 

As an international entity, for the purposes described in this Notice we may need to transfer, and process internationally certain types of your Personal Data as listed above (including in countries outside the European Economic Area (the “EEA“), Switzerland and the UK), notably throughout the Everledger Group and to the jurisdictions in which those entities are based, as listed on our website. This means that when we process your Personal Data we may process it in any of these countries. 

As a result, your information may be transferred to and/or processed in countries that are not considered by the European Data Protection Authority to provide adequate protection to Personal Data or may not guarantee the same level of protection for Personal Data as the country in which you reside. However, we have taken appropriate safeguards to ensure that your Personal Data will remain protected in accordance with this Notice. This includes implementing the European Commission’s Standard Contractual Clauses for transfers of your Personal Data between our group companies, and with our third-party service providers, partners and other suppliers, which require all group companies to protect Personal Data that they process from the EEA in accordance with European Union data protection law. 

11. Is my information secure? 

We understand that you care how your Personal Data is used and/or shared with others, and we value your trust and seek to safeguard your Personal Data. 

We implement appropriate technical and organizational security measures, including physical, administrative and technical safeguards with the objective of protecting your Personal Data from unauthorized access, use and disclosure. To ensure the security of your Personal Data, we communicate our privacy and security guidelines to all Everledger employees and enforce privacy safeguards within the Everledger Group. 

The measures we use to protect your Personal Data are designed to provide a level of security appropriate to the risk of processing your Personal Data. However, please be aware that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures that we have in place to safeguard Personal Data will never be defeated or fail, or that those measures will always be sufficient or effective. 

In case any incident should happen to your data, a response plan is in force and will be deployed. If your Personal Data is impacted, we will of course follow appropriate legal processes which may include contacting you to inform you. 

12. What if I access a website through a Everledger Site? 

As described above, the Everledger Sites may contain links to and from other third-party websites and services (collectively, “Third Party Sites“) that are not controlled and operated by us. 

Please be aware that we have no control over the content, policies or actions of these Third-Party Sites. Your use of these Third-Party Sites is at your own risk and we do not accept any responsibility or liability for the privacy practices of these Third-Party Sites. We encourage you to read the privacy policies and terms of use of each Third-Party Site to which you link from the Everledger Sites. 

13. How old do I have to be to use the Everledger Sites or other Everledger digital offerings? 

You must be aged 16 or over to use the Everledger Sites and our other digital offerings. 

We take your privacy very seriously and we understand the importance of taking extra precautions to protect the privacy and safety of children who use Everledger’s products and services. We do not solicit or knowingly collect Personal Data from children aged 16 and under.  

If we are made aware that we have received such information, or any information in violation of our policy, we will locate and remove that information from our records. 

14. Does this Notice ever change? 

We may update or modify this Notice from time to time in response to changing legal, technical or business developments. We will obtain your consent to any material Notice changes if and where this is required by applicable data protection laws. The date of the most recent version of this Notice will appear at the top of the page. 

When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. For example, we will notify you of any changes to this Notice by posting a new Notice and updating the “last modified” date at the top of this page or by sending the new Notice to you via email, where appropriate. 

15. How do I contact Everledger? 

If you have any questions regarding our practices or how we handle your information, please contact our Data Protection Officer by sending an email to complianceteam@everledger.io or by post to Foreverhold Ltd, 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ. 

Thank you for taking the time to read this Notice. 

© Foreverhold Ltd 2021