Everwise Privacy Policy

Everwise (“we,” “our,” or “us”) values the privacy of our users. This Privacy Policy covers the collection, use and disclosure of information that may be collected any time you interact with Everwise, such as when you visit our website or communicate with our employees (“Services”). Please read the following to learn more about what information we collect and how we use and share it. If you do not agree to this Privacy Policy, please do not use the Services.

Information We Collect

How we collect and store information depends on how you interact with us. You can use some of the Services without providing any information other than that automatically collected as described below (for example, if you browse the Services without registering or signing in). Several categories of information are collected from you, as described below.

INFORMATION YOU PROVIDE

We may collect information about you during your use of the Services, including your name, username, password, email address, phone number, other contact information, payment information, and other information you provide or post on our Services (such as your goals, job information and preferences) or allow us to access when you do certain things, such as:

  • Register to use the Services;
  • Request certain features (e.g., newsletters, updates, and other products);
  • Connect with the Services or otherwise allow us to access certain information about you via a social media service (e.g., LinkedIn);
  • Contact us with a question or for customer support;
  • Enter a sweepstakes or contest or register for a promotion;
  • Participate in voting or polling activities;
  • Make a purchase; or
  • Post user-generated content to or on any of our Services.

You have the right to access and modify your data through the profile you create on our Services as well as through a request to sent to the contact information provided below.

We may collect and store your user ID associated with a social media service account that you use to sign in to your account or connect or use with the Services. When you sign into your account with your social media service account information or otherwise connect to your social media service account with the Services, you authorize us to collect, store, and use in accordance with this Privacy Policy any and all information available to us through the social media interface, including without limitation any information that you have made public in connection with your social media account, information that the social media service shares with us, or information that is disclosed as being shared during the sign-in process (for example, with LinkedIn, your full LinkedIn profile including your job title, experience, education, skills, and recommendations).

Please be careful and responsible whenever you are online. Certain portions of the Services may be open to any online viewer that you decide to share information with via a link, email, “share” function, or posting that you send or we send on your behalf with your permission. Should you choose to voluntarily disclose information through the Services, such as via social media service connections or our blogs, that information can be viewed publicly and can be collected and used by third parties without our knowledge and may result in unsolicited messages from other individuals or third parties. We are not responsible for any publication or use of any personal information you choose to post in these locations or share.

AUTOMATICALLY-COLLECTED INFORMATION

Device/Usage Information.

We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services. For example, we may collect and analyze information such as (a) IP addresses, mobile device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, and the city, state and country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, error logs, and other similar information. As described further below, we may use third party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.

Cookies and other electronic technologies.

Cookies are small data files that a web site you visit may save on your hard drive that usually include an anonymous unique identifier. Cookies do not contain information that is intended to identify you personally. When you use the Services, we use persistent and session cookies and other similar tracking technologies for various purposes, including: user authentication, keeping track of your preferences, keeping track of our audience size and traffic patterns, site administration, delivering relevant advertising, and analyzing trends. You can configure your browser to accept cookies, reject cookies or notify you when a cookie is being used. However, if you configure your browser to reject cookies, you may not be able to use our products or services that require you to sign in or take advantage of all their features. To learn more, please see our Cookie Policy. We may also include tracking pixels, which are small graphic images, in our email messages and newsletters to determine whether the messages were opened and the links were actually viewed. If you do not want to receive tracking pixels, you will need to disable HTML images in your email client, but that may affect your ability to view images in other email that you receive. As we adopt additional technology, we may also gather additional information through other methods.

Information from Third Parties

We may obtain additional information about you from third parties such as marketers, partners, researchers, and others. We may combine information that we collect from or about you with information we obtain about you from such third parties or affiliates.

Anonymous or De-Identified Data

We may anonymize and/or de-identify information collected by the Services or via other means so that the information does not identify you. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.

What we do with information we collect

We use the information that we collect for the following purposes:

  • To deliver and support our products and services;
  • To process and respond to your inquiries and provide you with customer service;
  • To contact you with information that we believe will be of interest to you (such as product announcements, software updates, and special offers);
  • To analyze the accuracy, effectiveness, usability, or popularity of the Services;
  • To improve the content and features of the Services or develop new Services;
  • To allow us to personalize the content and advertising that you see on the Services;
  • To administer sweepstakes and contests;
  • To enforce the legal terms that govern your use of the Services; and
  • To administer and troubleshoot the Services.

How we share your information

We do not share, sell, rent or otherwise distribute your information to others, except as disclosed in this Privacy Policy. Everwise may share your information with others outside of Everwise under any the following circumstances:

  • We have your explicit consent to share the information.
  • We need to share your information to fulfill your product or service request, such as with a service provider who is working on our behalf.
  • We wish to contact you with information about products and services from our business partners.
  • You have explicitly requested information from our business partners, in which case it will be clear at the point of collection who is collecting the personal information and whose privacy policy will apply.
  • We have a good faith belief that sharing or otherwise permitting access, disclosure, use or preservation of such information is reasonably necessary in response to any subpoenas, court orders, or other legal process we receive, or to establish or exercise our legal rights or to defend against legal claims.
  • We believe it is necessary in order to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Use for the Services you accessed, and/or to protect our rights and property.
  • We have a relationship with an affiliate or partner that you have an online or off-line relationship with, or have visited the affiliate or partner’s web site that links to or mentions the Everwise site, and have registered for Everwise online services through the partner’s or affiliate’s program or site.
  • As we continue to develop our business, we may sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US or Swiss-US Privacy Shield Frameworks, Everwise is potentially liable.

Online analytics & tailored advertising

ONLINE ANALYTICS

We may use third-party web analytics services on our Services, such as those of Google Analytics. These service providers use the sort of technology described in the Automatically-Collected Information section above to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on by clicking here.

TAILORED ADVERTISING

Third parties whose products or services are accessible or advertised via the Services may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to help them (i) inform, optimize, and serve ads based on past visits to our websites and other sites and (ii) report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our websites. We may also allow other third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) to serve tailored ads to you on the Services, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. We neither have access to, nor does this Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of ad targeting as described below. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising (i.e., not just for the Services), you may visit the Network Advertising Initiative’s Consumer Opt-Out Link and/or the Digital Advertising Alliance’s Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Links

The Services may contain links to other sites and services. Everwise is not responsible for the privacy policy or other practices employed by sites and services linked to or from our Services nor the information or content contained therein. This Privacy Policy solely to information collected by our products and services.

How we secure your information

We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.

Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that personal information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.

Children

The Services are not intended for persons under the age of 13. We require that only persons 13 years of age or older use the Services. By using the Services, you hereby represent that you are at least 13 years old. If we become aware of a user under the age of 13, we will make reasonable efforts to promptly delete that user’s information.

California do not track policy

We are committed to providing you with meaningful choices about the information collected on our Services for third party purposes, and that is why we provide above the NAI “Consumer Opt-out” link, DAA opt-out link, and Google opt-out link. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations and solutions.

Changes to this privacy policy

We reserve the right to change this policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this policy will mean you accept those changes. If we make any material changes to this Privacy Policy, we will post the updated Privacy Policy here and notify you by email or by means of a notice on our website prior to the changes becoming effective.

EU-US and Swiss-US Privacy Shield Framework

Everwise complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively..  Everwise has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

In compliance with the Privacy Shield Principles, Everwise commits to resolve complaints about your privacy and our collection or use of your information.  European Union and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Everwise at: privacy@geteverwise.com

Everwise has further committed to refer unresolved privacy complaints under the Privacy Shield Principles through the  BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

If you are using Everwise from within the European Economic Area or other non-U.S. territories, please note that any information we collect from and about you may be transferred outside the European Economic Area or those other non-U.S. territories for use by Everwise for any of the purposes described in this Privacy Policy. In addition, because Everwise operates globally, we may make information we gather available to worldwide business units and affiliates under the terms of this Privacy Policy. By providing us with information, you hereby expressly consent to such transfers of your data to the United States or other countries, except in the case of data transfers from the European Economic Area or Switzerland, which are covered under our EU-US and Swiss-US Privacy Shield Frameworks detailed above. For users from outside the US, Switzerland or the European Economic Area, please note that laws in the US or other countries may not provide the same level of protection for your information as the laws of your country of residence.

Your communication choices

Information collected by Everwise is used for the purposes set forth in this Privacy Policy, and is subject to the choices discussed throughout this Privacy Policy. Everwise also provides opt-out information in all marketing communications via an “unsubscribe” link in communication emails, which directly unsubscribes you from any further communication from us. Please note that it may take us some time to process your requests consistent with applicable law. Note that you do not have the ability to opt-out of non-marketing communications that we send if you are a registered user of our Services or if you have engaged in transactions with us. Upon request from you to correct or delete your data, we will make reasonable efforts to promptly correct or delete such data.

Your California privacy rights

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to privacy@geteverwise.com.

Federal Trade Commission

Everwise is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

SUPPLEMENTAL EU GDPR PRIVACY NOTICE

European Union Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“EU GDPR”), requires Everwise to provide additional and different information about its data processing practices to data subjects in the European Union (“EU”).

Scope

If you are located in a member state of the EU and access our Services or otherwise provide us with your personal data, this Supplemental EU GDPR Privacy Notice applies to you.

The Data Controller

If you are using our Services as a protege, the data controller is your employer. Everwise is a Data Processor on behalf of your employer with respect to your data uploaded to an account in our Services.

If you are using our Services as an Everwise mentor, the data controller is Everwise.

Our Legal Bases for Processing Personal Data

We process your personal data on several different legal bases, as follows:

Contract Performance: Use of our Services is subject to our Terms of Use and other applicable terms and conditions. We process the personal data of users of our Services as necessary to perform our contractual obligations in respect of such users or take steps at such users’ request prior to entering into a contract, pursuant to Article 6(1)(b) of the EU GDPR.

Legitimate Interests: We process the personal data of users of our Services as necessary to pursue the following legitimate interests, pursuant to Article 6(1)(f) of the EU GDPR: To provide users with a good user experience, to maintain and secure our Services, to understand our users so that we can tailor our services to them, and to support and provide requested services and information to our users or customers. In these cases, we will ensure that your privacy and other fundamental interests do not override our legitimate interests.

Legal Obligations: If we are subject to a lawful access request, engaged in a legal proceeding or suspect a user of illegal conduct, we may need to process your personal data as necessary to comply with relevant laws, regulatory requirements and to respond to lawful requests, court orders, and legal process, pursuant to Article 6(1)(c) of the EU GDPR.

Consent: If we are required to obtain your consent to place certain cookies on your device or engage in other processing activities associated with the Services, we may perform such processing on the basis of your consent if you have provided it, pursuant to Article 6(1)(a) of the EU GDPR. In such cases, you may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. In such cases, providing your consent is voluntary, but we will not be able to provide you with a service for which we require your consent until we obtain such consent.

Vital Interests: In extenuating circumstances, we may need to process your personal data to protect the vital interests of you or another natural person, pursuant to Article 6(1)(d) of the EU GDPR.

Transferring and Protecting Personal Data

We disclose your personal data to recipients in the following jurisdiction or jurisdictions outside of the EU which do not provide adequate protection to personal data according to the European Commission: the United States of America. By entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EU and/or 2004/915/EC) as referred to in Article 46(5) of the EU GDPR or other adequate means, we have established that all such recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer (including to our Affiliates outside the EU) is subject to appropriate onward transfer requirements as required by the applicable contract or applicable law. You can ask for a copy of such appropriate data transfer agreements by contacting privacy@geteverwise.com

Your Data Subject Rights

Under the conditions set out under the EU GDPR and any other national data protection laws in the EU, you have the following rights:

  • Right of access: You have the right to obtain from us confirmation as to whether your personal data is being processed, and, where that is the case, to request access to the personal data. The access information includes, among other things, the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed. You have the right to obtain a copy of the personal data undergoing processing. Subject to applicable law, we may charge a reasonable fee for copies, based on administrative costs.
  • Right to rectification: You have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  • Right to erasure: You have the right to ask us to erase your personal data to the extent it is not required for legally required purposes.
  • Right to restriction of processing: You have the right to request restriction of processing of your personal data, in which case, it would be marked and processed by us only for certain purposes.
  • Right to data portability: You have the right to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit the personal data to another entity without hindrance from us.
  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data. If you have a right to object and you exercise this right, your personal data will no longer be processed for such purposes by us. Exercising this right will not incur any cost. Such a right to object may not exist, in particular, if the processing of your personal data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
  • Right to Submit Complaints: You have a right to lodge a complaint with a supervisory authority.

Please note that these rights may be limited under the applicable national data protection law. To exercise your rights please contact us at privacy@geteverwise.com.

Retainment of Your Personal Data

If you register for an account on our Services, we retain your personal data for as long as you have an account with us. Upon your request, we will delete or erase your personal data within one month after your personal data is no longer necessary for us to provide you with any information or services you have requested, pursue any of the legitimate interests specified herein where the legitimate interest is not overridden by your fundamental rights or privacy interests, comply with any legal obligations to which we are subject, or defend any legal claim against us or support any legal claim made by us, including any potential appeal.

Requirement to Provide Personal Data

In order to create an account with Everwise and to use our Services, you need to provide us with your name, email address, and professional development goals. In order to use our Services, you must consent to cookies that are strictly necessary.

Contact us

We welcome your feedback regarding this Privacy Policy. If you have questions, comments, or concerns about either one, please contact us by e-mail at privacy@geteverwise.com or postal mail at:

Everwise Corporation
18 W21st Street
7th Floor
New York, NY 10010