Privacy Policy
Introduction
We at EVOUS develop our artificial intelligence platform with the objective of supporting companies in their corporate learning processes, offering knowledge base upload and management resources, training personalization, content generation (videos, texts and materials), integration with third-party LMS systems and providing insights for new learning journeys. EVOUS helps teams and organizations improve their employees' training, making training processes more efficient and effective.
We are committed to safeguarding the privacy and protection of Personal Data of individuals who interact with our actions and with the execution of our services, as well as those who contract our services. Thus, "you", data subject, have the right and duty to read this document completely at any time to understand how we act.
In this Policy you will find clear information about what personal data we collect, for what purposes, with whom we can share it, how long we keep it stored and what are the rights of the subjects, under the terms of applicable legislation.
This Policy will be periodically reviewed to reflect improvements and new features of the Platform. Any relevant changes will take effect 15 days after their publication on the official EVOUS website, except for contrary legal provision.
If you do not agree with this Policy, please do not continue providing your data and stop using our websites and services.
What Personal Data does EVOUS process?
The personal data processed by EVOUS varies according to your interaction with our websites, applications and services, and according to the category of subject to which you belong. This data may be:
- Registration data: name, email, phone, position and company.
- Navigation and device data: IP address, access dates and times, device identifiers, navigation history, content interactions, cookies.
- Sensitive data: only if and when strictly necessary and with adequate legal basis, including situations where the User himself inserts such data in content uploaded to the Platform. EVOUS does not recommend uploading personal sensitive data, with the use of these resources being the responsibility of the contracting company.
- User Content: information, texts, images, videos, data and other materials sent, uploaded or shared by the User.
- AI-generated content: materials produced by the Platform from parameters provided by the User.
- Usage and integration data: Platform usage records, interactions with training and materials, in addition to data from integrations with third-party LMS systems.
- Inferred or analytical data: information generated by data analysis and intelligence models, such as learning profiles, usage reports and personalized recommendations.
Sources: data may be provided directly by you, collected automatically on our websites and applications, obtained from service providers that support our operations or passed on by the contracting company responsible for enabling the use of the Platform.
Who are the subjects of Personal Data processed by EVOUS?
We process personal data from different categories of subjects, which may overlap depending on how you interact with EVOUS:
- Visitors and interested parties: people who access EVOUS websites or pages, interact with our content, materials or campaigns, or who agree to receive our communications.
- Contracting company administrators: representatives of the legal entity that contracts the Platform and manages user access.
- End users of the Platform: employees or professionals authorized by the contracting company to use the Platform in the context of training and knowledge management.
What are the legal bases for processing?
EVOUS carries out personal data processing always supported by a legal basis provided for in applicable legislation. The main hypotheses are:
- Contract execution: when processing is necessary to provide access and resources to the Platform contracted by the company.
- Compliance with legal or regulatory obligation: to meet fiscal, accounting or information security obligations.
- Regular exercise of rights: when necessary for defense in judicial, administrative or arbitration proceedings.
- Legitimate interest: when EVOUS carries out processing aimed at legitimate purposes, such as Platform security, fraud prevention, usage report generation and improvement of learning resources, always after analyzing necessity, subject expectation and proportionality.
- Consent: for processing that depends on express authorization from the subject, such as optional cookie use, eventual processing of sensitive data inserted by the User himself or sending marketing communications, when required by law.
What are the legal purposes of data processing by EVOUS?
1) Visitor data
When accessing and browsing EVOUS websites, we may collect and process some personal data for the purpose of enabling your access to our websites and improving our institutional strategies, so that our communication through websites and contact with you is always developing.
| Finalidade | Dados Pessoais | Base Legal |
|---|---|---|
| Website access | Access information; Navigation and device information; | Legitimate Interest |
| Analysis to develop improvements in institutional communication strategies | Access information; Navigation and device information; | Legitimate Interest |
2) Interested party data
To facilitate, objectively, your visualization of how and for what purpose we can process your data, you can consult the exemplary table below:
| Finalidade | Exemplo | Dados Pessoais | Base Legal |
|---|---|---|---|
| EVOUS services disclosure | When you fill out a form stating that you want access to materials such as ebooks or that you want to receive our content by email, or when we promote marketing campaigns about our services. | Registration information, such as name and email address; Professional information such as position and company where the EVOUS Lead works; Access information; Navigation and device information. | Legitimate Interest |
| Sending communications | When you agree that we send materials, content and news that we think will be useful to you. | Registration information, such as name and email address. | Legitimate Interest |
| Public service | When you contact us through social networks or our contact email. | Registration information, such as full name, email address and phone | Legitimate Interest |
3) Contracting Company Administrator Data
| Finalidade | Exemplo | Dados Pessoais | Base Legal |
|---|---|---|---|
| Service contracting | When the company contracts the Platform and it is necessary to sign a contract. | Name, email, position, company; access credentials. | Contract execution |
| Corporate account management | Administration, billing and support activities. | Name, email, phone; banking data, if applicable. | Contract execution |
| Communication and support | When EVOUS contacts about the contract or technical support. | Name, email, phone. | Contract execution |
4) Platform End User Data
| Finalidade | Exemplo | Dados Pessoais | Base Legal |
|---|---|---|---|
| Platform access and use | Enable User login and authentication. | Name, email, position, company; access credentials. | Contract execution |
| Content upload and management | When the User uploads materials, bases or data to the Platform. | User Content (texts, videos, data, images, materials). | Contract execution |
| AI content generation | Content created from prompts and parameters provided by the User. | Inserted and processed data; results generated by AI. | Contract execution |
| LMS and third-party integrations | Make data available for integration operation. | Access, usage and interaction data. | Legal obligation. Legitimate interest |
| Insights and analysis | Usage reports and learning recommendations. | Usage data and inferred/analytical data. | Legitimate interest |
| User support | Answer questions or support requests. | Name, email, phone. | Contract execution |
5) Minor data
EVOUS services are not intended for minors under 18 years of age. We do not intentionally collect personal data from minors. If we identify that data was collected inadvertently, it will be immediately deleted, except if there is authorization from parents or legal guardians or specific legal basis.
Roles in data processing
EVOUS may act as controller or processor of personal data, depending on the context:
- Controller: when defining the purposes and means of processing, as occurs with visitor data, interested parties, contracting company administrators and usage data collected directly by the Platform.
- Processor: when processing personal data on behalf of the contracting company, including content uploaded by users (knowledge bases, materials, learning interactions) and information inserted or generated within the scope of the contract, following contractual instructions and in accordance with applicable legislation.
In addition, reports, analyzes and recommendations produced by the Platform may be processed by EVOUS as data under its control, but always in an anonymized or aggregated manner when used for service improvement, security or artificial intelligence model development purposes.
Cookies and similar technologies
6.1 What are cookies?
Cookies are small text files stored in the user's browser or device, which allow basic navigation, security and personalization functionalities. The term "cookies" includes similar technologies, such as pixel tags, SDKs, mobile device identifiers and local storage.
6.2 Types of cookies we use
| Tipo de Cookie | Finalidade |
|---|---|
| Strictly necessary | These cookies are essential for the website tools to work and for **EVOUS** to be able to offer the requested services. |
| Performance/analysis | We use these cookies to check how the EVOUS website is accessed, used and how it is working, we analyze the data to maintain, operate or improve our services. |
| Functional | We use these cookies so that your experience becomes even better, so that your preferences have relevance on the website, for example, remembering the visitor of the articles he has already consumed or the content he has already heard. |
6.3 Additional use for data intelligence
Some technical identifiers (such as analytics cookies) may be used to train and improve internal data analysis and artificial intelligence models, in an anonymized or aggregated manner.
EVOUS may use anonymized and aggregated data from Users' interactions with the Platform — such as clicks, searches, views and quiz responses — to improve its recommendation algorithms, content generation and learning analysis.
Under no circumstances will the data used for this purpose allow direct or indirect identification of individuals, being processed exclusively to improve the accuracy and relevance of Platform resources, in compliance with LGPD principles.
6.4 Geolocation
Location data collection is not performed by cookies, but may occur in the application or device when you authorize (opt-in). This setting is independent and can be disabled at any time, aware that this may limit resources that depend on location.
6.5 How to manage your preferences
You can manage cookie usage directly in your browser settings or, when available, through our consent banner. Disabling certain cookies may harm the experience or limit website and application functionality.
Who does EVOUS share your data with?
Personal Data Sharing. To enable the execution of processing activities, EVOUS may share some of the Personal Data collected with third parties. To understand such relationships, you can view in the table below the recipients of the sharing and the reasons why this happens.
| Destinatários | Razões de Compartilhamento |
|---|---|
| Service Providers | Suppliers that support us in activities such as cloud hosting, analytics, marketing, invoice issuance, payment processing, technical support and security. We always limit access to the minimum necessary and require contractual obligations of confidentiality and data protection. |
| Integration partners | Third-party systems, including LMS platforms, with which the Platform connects to enable contracted functionality. The use of these services is subject to the respective terms and privacy policies of third parties. |
| Personal Data Protection Authorities and Judicial Actions | If we are required by Data Protection Authorities or in the case of Judicial Action, we may share your data by legal requirement, under the terms of applicable legislation, or for regular exercise of rights purposes. |
International transfers: if any service provider is located outside Brazil, we will adopt adequate mechanisms to guarantee the same level of protection provided for in the LGPD, such as specific contractual clauses or recognized certifications.
What are your rights as a data subject?
8.1. Know your rights
Personal Data Subject Rights. Know, according to the table below, what your rights are, based on the fundamentals of personal data protection legislation that applies to you.
| Direitos Fundamentais | Aplicabilidade Prática |
|---|---|
| Access | You will have facilitated access to information (both electronic and printed) about the processing of your data, mainly to facilitate the use of this information at your discretion. |
| Rectification | You can ask us to rectify/correct your data that is for some reason incomplete, inaccurate or outdated. |
| Deletion | We will delete your personal data when there is no longer any type of use for the purposes described in this Privacy Policy, but you can also request this cancellation through a request. |
| Consent withdrawal | When processing depends on your consent (e.g.: optional cookies), you can revoke it at any time. |
| Opposition | You can object to personal data processing carried out based on legitimate interest, if you understand that there is a violation of fundamental rights. |
| Explanation | We can associate this right with the transparency we will have in relation to the information we provide to you through response to your request. They will be clear and objective to do justice to your right. |
| Automated Decision Review | You can request review of automated decisions, including profiling, as well as explanations about the criteria used, respecting trade secrets. |
| Portability | You can request a copy of your personal data in digital format and can, at your discretion, use it on another platform, that is, for services provided by third parties. |
8.3. Requests
If you have any questions about the data processing we carry out or want to exercise any of your rights, in accordance with applicable legislation, it is possible to make a request. The subject can, for example, request access, rectification or deletion of their personal data.
The request relating to any of these rights must be requested through this email address: contact@evous.com.br.
8.4. Opt-out
Still, as we care about your experience with EVOUS, we make available to the Data Subject the option to demonstrate that they no longer want to receive our communications. To do this, just click on one of the buttons at the end of our emails, which indicate that you no longer want to be subscribed to our email list.
How long will the data be stored?
9.1. Processing period
Navigation information. All Data collected regarding navigation and device information mentioned in this Policy are stored on the platform used for data collection, and will be stored in a secure and controlled environment for at least 6 (six) months, under the terms of Article 15 of Law 12.965/2014 ("Marco Civil da Internet").
We may (for audit, security, fraud control and rights preservation purposes) maintain the history of Data Subject records for a longer period than established by law or regulatory standard.
Platform usage data: maintained while the User account is active and for the period necessary to fulfill the contract with the contracting company.
User Content and AI-generated content: stored while the contractual relationship with the contracting company is in effect or until deleted by the User or authorized administrator, except for legal or regulatory obligation that determines a different period.
Data backups and security: To guarantee the continuity and integrity of services, EVOUS performs encrypted backups of stored data, which remain available exclusively for recovery purposes in case of technical failures or security incidents. These backups follow protection and access control standards compatible with market best practices, being automatically deleted after the period necessary for recovery or environment restoration.
Contractual and billing data: maintained during the contract term and subsequently for the period necessary to comply with legal, regulatory, fiscal and accounting obligations.
Personal data. The other Personal Data indicated in this Policy will be processed by Us, in accordance with the law, until one of these hypotheses occurs:
- The processing purpose is achieved;
- The data is no longer necessary or relevant to the scope of the proposed purpose;
- The Contract with the Contracting Company is terminated or reaches its end;
- The right to delete Personal Data from the Data Subject is exercised;
- Any eventual penalty applied by the body responsible for supervising applicable legislation occurs;
Retention
Still, in specific situations, EVOUS and its Service Providers may retain personal data even after the processing termination hypotheses, due to compliance with legal or regulatory obligation or exercise of the right of defense. In these cases, personal data will be stored for the time necessary to comply with the legal or regulatory obligation and in compliance with internal data retention and deletion policies, always in a secure location and with segmented access.
9.3 Security measures
EVOUS adopts adequate technical and administrative measures to protect personal data against unauthorized access, leaks, loss, alteration or any form of inadequate or illicit processing.
All data is stored in controlled and monitored environments, with security protocols compatible with market best practices.
Despite all efforts, no system is totally immune to incidents. Therefore, EVOUS commits to adopting reasonable measures to identify, mitigate and communicate any security incidents that may affect data subjects. When applicable, EVOUS will notify the National Data Protection Authority (ANPD) and the subjects themselves, in accordance with current legislation.
Changes and adaptations to this Policy
Updates to this Privacy Policy. We are constantly developing, so some changes or adaptations may be made to this Policy.
For this reason, it is important that you check it regularly when using our website. If we have your contact email, you don't need to worry, as we will send all these updates to you.
How to contact EVOUS?
Get in touch. We comply with all Brazilian legislation applicable to data protection and privacy. Questions or requests about any item in this policy can be sent to the email contact@evous.com.br.
GLOSSARY
- Anonymization: use of reasonable technical means to make it impossible to associate data with a natural person.
- Contracting company administrator: representative of the legal entity that contracts the Platform and manages access and users.
- Consent: free, informed and unambiguous manifestation by which the subject agrees with the processing of their personal data for a specific purpose.
- Controller: legal entity to whom decisions regarding personal data processing belong.
- Cookies: small text files stored in the browser or device, used for basic functionality, personalization and analysis.
- User Content: information, texts, images, videos, data and other materials sent, uploaded or shared by the User on the Platform.
- AI-generated content: materials produced by the Platform from parameters provided by the User.
- Personal data: any information related to an identified or identifiable natural person, under the terms of the LGPD.
- Sensitive data: special category of personal data defined by the LGPD (e.g.: racial or ethnic origin, religious conviction, political opinion, data relating to health or sexual life, genetic or biometric data).
- Usage and integration data: Platform usage records and data from integrations with third-party LMS systems.
- Inferred or analytical data: information generated by analysis models from collected data, such as learning profiles, reports and personalized recommendations.
- Automated decision: decision made solely based on automated processing of personal data, without human participation, which may affect the subject's interests.
- Geolocation: data that indicates the approximate or precise location of a device, collected only through express consent (opt-in).
- Legitimate interest: legal basis that allows data processing to meet legitimate purposes, considering the subject's expectations and their fundamental rights.
- Processor: legal entity that processes personal data on behalf of the controller.
- Personal data subject: natural person to whom the personal data subject to processing refers.
- Platform end users: employees or professionals authorized by the contracting company to use the Platform.
- Visitors and interested parties: people who access EVOUS websites or pages, interact with content, materials or campaigns, or agree to receive communications.
- The singular includes the plural and vice versa and each gender includes the other;
- Additives, Annexes, Schedules, Communications, Reports and any other attachments, provisions and documents are part of this Privacy Policy and have the same effect as if they were expressly included in the body of this Policy, with any mention of one including a mention of the others;
This policy is effective as of January 20, 2025