Eve Communications Inc Inc., together with its subsidiaries (“Eve Communications Inc”, “Company”, “we”, “our” or “us”) respects the privacy of the visitors and/or users of its Site (“User(s)” or “you”) and is committed to protect the personal information that its Users share with it. 

This privacy policy (the “Site Privacy Policy”) is intended to describe our practices regarding the information we may collect from you when you use and access our Site(s) located at [​www.Eve.com] and any of their respective sub domains (the “Site”).

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Site Terms of Use available at  (the “Site Terms of Use”), which this Site Privacy Policy is incorporated thereto by reference. 

If you are a resident of California, please see our California Privacy Rights Statement for information about California Privacy Rights, and other required disclosures. 

1. Scope and Applicability 

This Site Privacy Policy applies only in connection with your use of the Site. This Site Privacy Policy does not apply to any use of the Eve device (as such term is defined in the Site Terms of Use) and other related services, which are governed solely by Eve Terms of Use and the Eve Privacy Policy (available at [www.​IamEve.ai/pages/privacy-policy]) (collectively, the “Eve Terms”). 

2. Your Consent (PLEASE READ CAREFULLY!) 

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS SITE PRIVACY POLICY, INCLUDING THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ACCESS AND/OR USE THE SITE IN ANY MANNER WHATSOEVER. 

To the extent that your use or access to the Site are on behalf of another person, such access and use must be conducted in strict compliance with the Site Terms of Use and at your sole responsibility, and you hereby represent that you received the required consent, authority, permission and approval of such person to provide Personal Information and to allow Eve Communications Inc to collect, store, and use such Personal Information in accordance with this Site Privacy Policy. 

PLEASE NOTE: YOU ARE NOT OBLIGATED TO PROVIDE US WITH ANY PERSONAL INFORMATION. YOU HEREBY ACKNOWLEDGE AND AGREE THAT YOU ARE PROVIDING US WITH SUCH PERSONAL INFORMATION VOLUNTARILY, FOR THE PURPOSES DESCRIBED UNDER THIS SITE PRIVACY POLICY, AND THAT WE MAY USE, PROCESS AND RETAIN SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS SITE PRIVACY POLICY AND SUBJECT TO ANY APPLICABLE LAWS AND REGULATIONS. 

3. Which information we may collect on our Users? 

We may collect three types of data and information from our Site Users: 

1. The first type of information is non-identifiable and anonymous information (“Non-personal Information”). Non-Personal Information is collected without particular reference to the identity of the applicable User from or about whom such information was collected and is available to us while such User is entering and/or using the Site. Non-personal Information which is being collected consists of technical, behavioral and aggregated information, and may contain, amongst other, the activity of the User on our Site, type of operating system, User’s ‘click-stream’ on the Site, type of browser and keyboards features, User demographics, traffic patterns, etc. 

2. The second type of information is information that identifies an individual, or may with reasonable effort, identify an individual, either alone or in combination with other information (“Personal Information”). Personal Information may be of private or sensitive nature of a User or identify an individual. Users may be asked to provide certain Personal Information including, without limitation, first and last name, date of birth, phone number, country of residence, email address, Candidate Information or other contact information, information concerning residency (i.e., whether the intended Eve user live alone), information concerning the language the intended Eve user is speaking, to the extent that you provide us information when contacting us we may also receive any types of information provided under such communication you provide to us in your own volition. 

3. The third type of information is any health information you provide to us as part of your usage of our Site, including without limitation, information concerning the intended Eve user cognitive, vision, or hearing impairment or any other health related information you provide to us (“Health Information”). To the extent that you provide us such Health Information over the course of your use of the Site, such Health Information provided to us shall be governed by our Eve Privacy Policy available at [www.​IamEve.ai/pages/privacy-policy] Health Information may be categorized as either Personal Information or Non-Personal Information in accordance with the definitions above, and the characteristics of each specific item of Medical Information. 

4. How do we collect information about our Users? 

There are a few main methods we use: 

• Non-Personal Information is collected through your use of the Site.We may be aware of your use and/or access of the Site, and may gather, collect and record the information relating to such usage, either independently or through third-party services as detailed below. We may also collect Non-personal Information through the analysis, aggregation and anonymization of Personal Information provided by you. 
• Personal Information you provide us voluntarily. For example, we collect Personal Information when you contact us and/or when you register to our services including when you order the Eve Device and/or subscribe to Eve services. 
• Personal Information which is being collected by us automatically when you use or access the Site. This is information which we automatically receive upon you access or interact with our Site. This information may include: 

• IP address, UDID (Unique Device Identifier) or other persistent user and/or mobile device token (as applicable), geolocation, advertising ID, device type, operating system, browser type and version, screen redevice, browser and keyboard language, the User’s ‘click-stream’ and activities on the Site, the period of time the User visited the Site and related timestamps. 

We will not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance of the Site Terms of Use and Site Privacy Policy. 

5. The Purposes and Legal Basis of the Collection, Processing and Use of Information 

Legal Basis for Use 

We collect, process, and use your Personal Information for the purposes described in this Site Privacy Policy, based at least on one of the following legal grounds: 

• In Performing an agreement with you:We collect and process your Personal Information in order to provide you with the Site, following your acceptance of this Site Privacy Policy and pursuant to the Site Terms of Use; to maintain and improve our services to you; to develop new services and features for our Users; and to personalize the use of the Site in order for you to get a better user experience. 
• With your consent:We ask for your agreement to collect and process your information for specific purposes and you have the right to withdraw your consent at any time. 
• Legitimate interest:We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our services, protecting against harm to the rights, property or safety of our properties, or our users, or the public as required or permitted by law; Enforcing legal claims, including investigation of potential violations of this Site Privacy Policy; in order to comply and/or fulfill our obligation under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request, as well as our Site Terms of Use. 

Purpose of Use 

We may use the Personal Information that we collect about you for the following purposes: 

• To provide operate and improve the Site for our Users and to manage our business. 
• To send you updates, notices, notifications, and announcement related to the Site as well as newsletters, coupons, commercial offers and additional communications regarding the Eve device and our services. 
• To enable us to provide you with customer support services and to further develop, customize and improve the service based on Users’ common preferences, uses, attributes and anonymized or de-identified data. 

• To create cumulative statistical data and other cumulative information and/or other conclusive information that is non-personal, to enable us to provide our Users with a better user experience with more relevant and accurate information, services, third party services, features and functionalities, statistical and research purposes, etc. and improve our Site. 
• To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities. 
• To initiate and facilitate transactions you wish to make through the Site, including the purchase and delivery of the Eve Device, insofar as you purchase the Eve Device such purchase shall be governed by the Eve Terms. 
• To comply with any applicable rule or regulation, to protect our legal interests and/or respond to or defend against (actual or potential) legal proceedings against us or our affiliates. 

6. Sharing Information with Third Parties 

Eve Communications Inc will not share or otherwise allow access to any Personal Information it collects, or that you provide through the Site to any third party, except in the following cases: 

• Law enforcement, legal proceedings, and as authorized by law: We may disclose Personal Information to satisfy any applicable law, regulation, legal process, subpoena or governmental request. 
• Protecting Rights and Safety:We may share Personal Information to enforce this Site Privacy Policy and/or the Site Terms of Use, including investigation of potential violations thereof; to detect, prevent, or otherwise address fraud, security or technical issues; to respond to claims that any content available on the Site violates the rights of third-parties; to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; and to protect the rights, property, or personal safety of Eve Communications Inc, any of its Users, or the general public. 
• Our Affiliated Companies: We may share Personal Information internally with our family of companies for the purposes described in this Site Privacy Policy. In addition, when Eve Communications Inc or any of our affiliated companies is undergoing any change in control, including by means of merger, acquisition, or purchase of all or substantially all of its assets, we may share Personal Information with the parties involved in such event. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Site. 
• Third Party Services: We partner with certain third parties to provide selected services that are used to facilitate and enhance the Site and your use thereof (“Service Providers”). Such third party Service Providers may have access to, or process on our behalf Personal Information which we collect, hold, use, analyze, process and/or manage. These Service Providers include hosting, database and server co-location services, data analytics services (e.g. Google Analytics), remote access services, data and cyber security services, fraud detection and prevention services (e.g. Amazon Web Services), e-mail and text message distribution and monitoring services, payment processors, customer support, and our business, legal and financial advisors (collectively, “Third Party Service Providers”). We remain responsible for any Personal Information processing done by Third Party Service Provider on our behalf, except for events outside of our and/or their reasonable control, and except with respect to Third Party Service Providers with which you are contractually engaged, either through a prior separate contractual engagement and/or through acceptance of their privacy policy and terms of use if such are referenced herein. 

For avoidance of doubt, Eve Communications Inc may transfer and disclose to third parties or otherwise use Non-personal Information (which includes Health Information which is Non-Personal including by being anonymized) at its own discretion. 

7. Storage, Transfer and Retention of your Information 

Information regarding the Users will be maintained, processed and stored by us and our authorized affiliates and service providers in the United States and abroad. 

While the data protection laws in the above jurisdictions may be different than the laws of your residence or location, please know that we, our affiliates and our service providers that store or process your Personal Information on our behalf are each committed to keep it protected and secured, pursuant to this Site Privacy Policy and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction. 

Specifically, each of our Third Party Service Providers which store or process your Personal Information either: (i) assured us that they provide adequate safeguards to protect your rights to privacy; (ii) where applicable, hold and process such information on our behalf in a jurisdiction which has been determined to ensure an adequate level protection by the EU Commission; (iii) perform such processing pursuant to your consent and acceptance of their privacy policy as further detailed above. 

By providing your information, you expressly consent to the place of storage and transfer, including transfers outside of the jurisdiction in which the information was provided. 

We retain the Personal Information we collect only for as long as needed in order to provide you with use of our Site in accordance with the terms of this Site Privacy Policy and to comply with applicable laws and regulations or otherwise as required for us to protect against claims by Users for the relevant statutory of limitations period. We then either delete from our systems or anonymize it without further notice to you. 

8. Candidates 

We welcome qualified candidates (“Candidate(s)” to apply to any of the open positions posted on our properties by sending us your contact details and CV or resume (“Candidate Information”). Since privacy and discreteness are very important to our Candidates, we are committed to keep Candidate Information private and will use it solely for our internal recruitment purposes. 

Please note that we may retain Candidate Information submitted to us even after the applied position has been filled or closed. This is done so we could re-consider Candidates for other suitable positions and opportunities at Eve Communications Inc; so we could use the Candidate Information as a reference for future applications; and in case the Candidate is hired, for additional employment and business purposes related to their employment with us. 

If you previously submitted your Candidate Information to us, and now wish to access it, update it or have it deleted from our systems, please contact us at help@IamEve.ai. 

9. Updating, obtaining a copy of, or deleting of Personal Information 

If for any reason you wish to exercise any rights to which you are entitled, under the law applicable to you, such as correction, deletion, access to and notification of the types of your Personal Information processed by us or on our behalf, you may do so by contacting Eve Communications Inc support at [help@IamEve.ai]. When handling these requests, we may ask for additional information to confirm your identity and your request. 

Subject to limitations pursuant to applicable law and if entitled to the same there under, if you wish to exercise your right to access your Personal Information, you may be able to obtain the Personal Information you directly provided us (excluding data we obtained from other sources) in a structured, commonly used, and machine-readable format and may have the right to transmit such data to another party. We may provide such access through the Site or otherwise. 

Please note, upon request to delete your Personal Information, we will delete any such Personal Information pursuant to any applicable privacy laws or otherwise de-identify any such Personal Information and thereby transform it to become Non-Personal Information. We may retain such data in whole or in part to comply with any applicable rule or regulation and/or to respond or defend against legal proceedings versus us or our affiliates. 

To find out whether these rights apply to you and on any other privacy related matter, you can contact your local data protection authority if you have concerns regarding your rights under local law. 

10. Minors 

To accept the terms of this Site Privacy Policy, you must be over the age of eighteen (18). If you are between 16 and 18 years of age, then you must review this Site Privacy Policy with your parent or guardian before visiting or using our Site, to make sure that you and your parent or guardian understand these terms and agree to them. Without relieving you of your responsibility to comply with the Site Terms of Use and the terms hereof we reserve the right (without obligation) to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using our Site. 

In the event that it comes to our knowledge that a person under the age of eighteen (18) is using our Site, not in accordance with the above-mentioned terms, we will use our best efforts to prohibit and block such User from accessing our Site and will use our best efforts to promptly delete any Personal Information. 

11. Local Storage and Third Party Software/Service, Cookies and other Tracking Technology 

Local Storage. When you access or use the Site, we may use industry-wide technologies which temporarily store certain information on your end device (such as your smartphone, your computer or other browsing device) (“Local Storage“), and which will allow us to enable proper use of the Site, automatic activation of certain features, make your browsing experience much more convenient and effortless and to provide our customers and potential customers with more relevant advertisements of the Eve device and our related services. The Local Storage is created per session and may be deleted by you or otherwise configured by you to not accept any such local storage. 

We also use certain monitoring and tracking technologies, including ones offered by Third Party Service Providers in order to collect and process Personal Information we specified above. For example, these technologies enable us to: (i) keep track of and apply our customer’s and potential customers’ Site preferences and authenticated sessions; (ii) better secure our Site by detecting abnormal behaviors; (iii) identify technical issues and improve the overall performance of our Site; and (iv) create and monitor analytics relating to use of our Site. 

Cookies and Other Tracking Technologies: A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. A pixel tag (also known as a web beacon) is a piece of code embedded on the site that collects information about users’ engagement on that web page. Cookies and similar technologies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies. To learn more about tracking technologies please refer to www.allaboutcookies.org. Tracking technologies may include Pixel tags (also commonly known as web beacons), transparent images, iFrames, or Java Script placed on our Site or our advertisements and emails, that is used to understand how you interact with the Site, such advertisements and emails. 

To learn more about our use of Cookies and other tracking technologies, please see our Cookie Policy, as defined in our Terms of Use. Some of these tracking technologies are provided to us by our Third-Party Services Providers who collect and process Personal Information on our behalf. These Third Party Services Providers may have direct contractual relationships with you (such as Google and Facebook), as detailed above. 

Additionally, the services provided to us by such Third Party Services Providers may entail collection and processing of Personal Information by such Third Party Services Providers, in a scope which is broader than the scope of Personal Information we are eventually provided with by such Third Party Services Providers. This means that sometimes these Third Party Services Providers have access to more of your Personal Information than we do. To the extent you have direct contractual relationship with any of our Third Party Services Providers, as further detailed above, any rights you may have with respect to your information, collected by such Third Party Services Providers, shall be governed by such contractual relationship. Otherwise, the terms of this Site Privacy Policy shall fully apply. 

In this context you should note that we may use certain third parties’ services, such as Google Analytics, Facebook, Twitter, LinkedIn and/or YouTube, using functionality of remarketing through their tracking cookies and pixel-based retargeting services. This means that if you provided your consent to Google, Facebook Twitter, Linkedin and/or YouTube (the “Social Ad Platforms“) to be provided with personalized commercial offers, you may be served with ads (including advertisements of third parties) based on your access to the Site, outside of the Site and across the internet. Please visit the Social Ad Platforms Privacy policy to find out how they use such information. If you wish to opt-out of such re-targeting and tracking functionality of the Social Ad Platforms, you may do so by accessing the settings of the applicable platform. 

PLEASE NOTE – such tracking and targeting by Social Ad Platforms, is provided pursuant to your engagement with such Social Ad Platforms and the actual nature and scope of Personal Information collection and processing performed by such Social Ad Platforms is not transparent to us. If you would like to learn more or make further inquiries with respect to such nature or scope, please refer to each of such Social Ad Platforms directly. 

Learn more about your choices and how to opt-out of tracking technologies: In order to delete or block any tracking technologies, please refer to the “Help” area on your internet browser for further instructions or learn more by visiting our Cookie Policy. You may also opt out of third party tracking technologies by following the relevant instructions provided by each such third party in its privacy policy or by visiting www.youronlinechoices.eu, http://optout.networkadvertising.org/?c=1 or http://www.aboutads.info/choices/.  

Please note however that deleting any of our tracking technologies or disabling future tracking technologies may prevent you from accessing certain areas or features of our Site or may otherwise adversely affect your user experience. 

Please also note that we may not respond to the ‘Do Not Track’ setting on your browser as the protocol and form for such setting has not yet been generally accepted. 

12. Direct Marketing 

If you provide us with your contact details through the Site or for the purpose of receiving from Eve Communications Inc different offers with respect to the Eve device or services, you hereby agree that we may use such contact details, in order to contact you, inform you regarding our products and services which may interest you, and send you other marketing material, including news and updates by transmission to the e-mail address or phone number you have provided. 

You may withdraw your consent by sending us a written notice via email to the following address: help@IamEve.ai. 

13. Security 

We have implemented appropriate technical, organizational and security measures, designed to reduce the risk of accidental destruction or loss, or unauthorized disclosure or access to the Site. Eve Communications Inc, however, does not and cannot guarantee that unauthorized access will never occur. We urge you to make sure to take appropriate measures to protect your browsing device and employ reasonable physical security means to protect unauthorized access. 

Our Users Personal Information, or parts thereof, are hosted in the US and abroad with advanced security features. However, please note that we cannot guarantee that the Personal Information you provide to us when accessing and/or using the Site, will not be exposed as a result of unauthorized penetration to the servers. Nevertheless, we employ industry standard procedures and policies to ensure the safety of its Users’ Personal Information and prevent unauthorized use of any such information. 

14. Third Party Websites 

While using the Site you may encounter links to third party websites and/or services. Please be advised that such third party websites and/or services are independent from Eve Communications Inc, and may use cookies and other web-tracking technologies, not specified or otherwise handled in our Cookie Policy, to collect Non-Personal and/or Personal Information about you. We assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third party websites and/or services. We encourage you to carefully read the privacy policies and the terms of use of such third party websites and/or services, as their terms, not ours, will apply to any of your interactions with such third parties. Eve Communications Inc has no control over the use of any information you provide to these third party services. 

15. Changes to the Website Privacy Policy 

Eve Communications Inc reserves the right to change this Site Privacy Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Site Privacy Policy on the Site and/or if provided by you, we may choose to send you an e-mail regarding such substantial changes. Such substantial changes will take effect seven (7) days after such notice was provided on any of the above-mentioned methods. Otherwise, all other changes to this Site Privacy Policy are effective as of the stated “Last Revised” date, and your continued use of the Site after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. 

16. General Information 

This Site Privacy Policy and the relationship between you and Eve Communications Inc shall be governed by and construed in accordance with the laws of the State of New York, without regard to its principles of conflict of laws. You agree to submit to the personal and exclusive jurisdiction of the courts located in the City of New York and waive any jurisdictional, venue or inconvenient forum objections to such courts, provided that Eve Communications Inc may seek injunctive relief in any court of competent jurisdiction. 

This Site Privacy Policy was written in English and may be translated in the future into other languages. If a translated (non-English) version of this Site Privacy Policy conflicts in any way with the English version, the provisions of the English version shall prevail. 

17. Have any Questions? 

If you have any questions or comments concerning this Site Privacy Policy, you are welcome to send us an email at help@IamEve.ai and we will make an effort to reply within a reasonable time frame. 

By contacting us, you represent that you are free to do so and that you will not knowingly provide Eve Communications Inc with information that infringes upon third parties’ rights, including any privacy right. You further acknowledge that notwithstanding anything herein to the contrary, Eve Communications Inc may use or refrain from using any such information at its sole discretion.