Privacy Policy

WHAT THIS POLICY COVERS

This privacy policy covers data that Eva Live collects, uses and discloses from our owned and operated corporate websites, client-facing portals and by other means, including through your contact with us (“Websites”). It also describes the choices available to you regarding our use of your personally identifiable information (“PII”) and how you can access and update this information.

This policy does not cover data that is collected, used or disclosed through Eva Live’s advertising technology platform and systems (the “Platform”). For more information on privacy as it relates to the Platform, please see Eva Live Platform Privacy Policy. Additionally, this policy does not apply to the privacy practices of other websites that are linked to from our Websites. Eva Live is not responsible for the privacy practices of these other websites. We encourage you to read the privacy policies of those websites to understand their data privacy practices.

Eva Live is a member of the Network Advertising Initiative (NAI) and adheres to the NAI’s 2020 Code of Conduct. Eva Live also follows the industry self-regulatory guidelines of the Digital Advertising Alliance, the Digital Advertising Alliance of Canada, and the European Digital Advertising Alliance.

Eva Live also implements and adheres to the policies of the IAB EU Transparency & Consent Framework as part of our compliance with EU data protection law. See http://advertisingconsent.eu for more information.

INFORMATION WE COLLECT
PII We Collect From Our Websites

We may collect PII such as your name, email address and phone number when you interact with us in the manners described below. PII is distinguished from “pseudonymous” data we collect about your browser or device (as described below) in that PII links to, or is, data which can directly identify you as an individual, client or prospective client.

PII we collect may be voluntarily provided, for example when you request more information through a form on the Websites or apply for employment. The PII 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 we ask you to provide your PII.
Pseudonymous Data

We may automatically collect pseudonymous data, distinguished from the PII described above, that does not directly identify you personally but is linked to your computer or device. We collect this data from you in the normal course of operating our Websites. When you visit our Websites, we and/or our third-party partners automatically collect information about your computer that your browser sends, such as IP address, browser type and language, access times, pages visited, and referring website addresses.

We may also collect information about your mobile device such as the type and model, operating system, carrier name, mobile browser, applications using our Websites, and identifiers assigned to your device, such as IDFA and AAID.

We may also collect your location information, such as your zip code or the approximate geographic area derived from your IP address or location positioning information provided by the location services and GPS features of your mobile device when location services have been enabled.

Pseudonymous data may contain cookie data. To understand more about how cookies are used on our Websites, see the COOKIES ON OUR WEBSITES section below.

HOW WE USE YOUR INFORMATION

Any PII you provide to or through the Websites shall be used for the purposes for which you provided it that were disclosed at the time it was collected.

We use PII to respond to inquiries initiated by individuals, to provide services requested by such individuals, to alert you to changes in services or features and to provide you with requested information regarding our services. We may also use your email address to send you our newsletter if you are a client or have chosen to receive it.

We also use pseudonymous data to assess the use and operation of our Websites and to better understand how our Websites are used. We use this information to conduct analytics, measure trends, and streamline website usability.

HOW WE SHARE INFORMATION

We will share your information with third parties only in the ways that are described in this policy. In addition, we do not, and will not, sell your information collected through our Websites to any third party.

We may disclose your information to companies that provide data processing services to help us with our business activities, such as sending email communications on our behalf. These companies are authorized to use your information only as necessary to provide these services to us.

We will also disclose your information:

COOKIES ON OUR WEBSITES

“Cookies” are data files that are stored on your browser or device and are used to remember user preferences and behaviors over time. Cookies allow us to recognize your device and remember information, such as your preferred language and other general settings.

Cookies set by the website owner (in this case, Eva Live) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Our Websites use both first party and third-party cookies.
First Party Cookies

First party cookies on our Websites are used for a variety of reasons, including purposes which may be strictly necessary for our Websites to function properly. Because these cookies are strictly necessary to deliver our Websites, we do not seek consent for such uses.
Third Party Cookies

Our Websites may contain content, pixels or cookie syncs from third parties, as outlined below. Note also that, in jurisdictions where consent is required for the placement of cookies, the appearance of any third parties on our Websites is subject to these consents being obtained by or on behalf of these third parties through, for example, the IAB’s Transparency and Consent Framework. We do not control these third parties, and you should refer to the privacy statements of our partners and service providers listed below to find out how they use cookies on our Websites and any data derived from such cookies.

Our Websites may contain content or pixels from service providers providing certain services on behalf of Eva Live. These third parties currently include:

Google Analytics
Website analytics services
Google opt-out
LinkedIn
Facebook
Facebook analytics

Our Websites may also contain content, pixels or cookie syncs from other ad tech partners, including Eva Live and our pixels. These third parties may collect data about your web viewing behavior on our Websites and combine this data with information collected from other websites over time for purposes that include targeted advertising. Most advertising networks offer you a way to opt-out of targeted advertising. If you would like more information, please refer to the YOUR CHOICES section below.

You can remove or manage cookies by following directions provided in your browser or device’s “help” or “preferences” areas. Note: if you reject cookies, you may still use our Websites, but some functionalities and areas of our Websites may be limited. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information. You may also seek additional information here.
Other Technologies

Our third-party partners or service providers may employ other tracking technologies like clear gifs (sometimes called “web Beacons” or “tracking pixels”), that are pieces of code that can be embedded on websites and can be used to learn how you interact with that website. Clear gifs help us better manage content on our Websites by informing us what content is effective. We also use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functionality.
Social Media

Our Websites may include social media features, such as the Facebook “like” button. These features may allow the social media provider, like Facebook, to collect certain information, such as your IP address, cookies and page you are visiting. Your interactions with these features and data collection enabled by such social media features are governed by the privacy policy of the social media provider offering them. Please note that links to social media platforms or content from our Website does not mean that we endorse the linked social media platform and/or content.

YOUR CHOICES

Industry opt-out pages. The online advertising industry provides websites from which you may opt out of interest-based advertising from Eva Live and other companies that participate in self-regulatory programs. The US-based opt out pages are www.aboutads.info/choices and www.networkadvertising.org/choices. The European based page is www.youronlinechoices.com. In Canada, use youradchoices.ca/choices.

For mobile apps. You can opt out of Eva Live using information about your usage of mobile apps that are targeted to your interests by using your device settings, for most devices. We are not able to directly access the Mobile App Opt Out on devices that offer it. To learn how to use the mobile app opt out, consult your device instructions. To find information on Opting out on Mobile Devices please visit http://www.networkadvertising.org/mobile-choice.

Eva Live’s Data Control Page. You are able to opt out of having new data associated with your device and to request that we disassociate from your device data we already have. You can directly access Eva Live’s opt out, which will cease data collection and disassociate data from your device, by visiting http://www.adsrvr.org.

Cookies

For more information about opting out of cookies on our Websites or otherwise blocking or deleting cookies, please refer to COOKIES ON OUR WEBSITES.

Adherence to Do Not Track Signals (“DNT”)

DNT is a privacy preference that you may set in certain browsers or may be preset in certain instances. Please note that Eva Live does not currently honor DNT signals sent by browsers or otherwise included through third party intermediaries.

What is Eva DSP?

Eva DSP provides tools for our media buyers, to purchase digital ad space on website and mobile sites and applications. To accomplish these goals, the Eva DSP collects pseudonymous information from these websites, mobile sites and mobile applications and supplements that information with data from third parties. Advertisers and media buyers use Eva DSP to engage in a variety of advertising techniques, including interest-based advertising, real-time (programmatic) advertising, contextual, and location-based advertising.

What information does Eva DSP collect?

Eva DSP is designed to use certain types of data. It includes data generated through Eva DSP as well as data clients receive from other sources and then use on Eva DSP, or that they buy through Eva DSP. This may include pseudonymous information about Internet users’ browsers and devices, such as:

• the type of browser and its settings,
• information about the device’s operating system,
• cookie information,
• information about other identifiers assigned to the device,
• the IP address from which the device accesses a client’s website or mobile application
• information about whether an Internet user has visited a Eva client’s website, based on web beacons placed on the site by our customer
• information about the websites (i.e., the URLs) and mobile applications upon which we serve advertisements
• information about the geographic location of the device when it accesses a website or mobile application
• inferences or information about users’ interests that are created, acquired, bought, sold, or used by our clients

How does Eva DSP use the information that it collects?

We use the information we collect to serve targeted ads to individuals.

More specifically, the platform enables our users to use this information to:

• Determine what ad to show an individual, and to serve that ad (including behaviorally targeted ads) to that individual
• Customize ads to particular types of audiences;
• Customize ads to the type of web page an individual is viewing;
• Perform analysis of how effective the ads served are;
• Learn more about their own customers;
• Limit the number of times an individual sees an ad;
• Detect fraud; and
• Troubleshoot platform or campaign issues.

In order to use this information as described above, we may need to transfer that information to third party partners, and such transfer may be considered a sale of data in California.

How long is the information stored and kept?

For data collected via browsers and stored in cookies, Eva DSP stores this data for up to 60 days. For data collected via mobile application advertising and stored via mobile advertising IDs Eva DSP stores this data for up to 180 days. Our systems typically reset the retention period each time we encounter the same user.

How does Eva DSP collect this information?

Eva DSP uses cookies, beacons, mobile SDKs, tags and other technology to collect data associated with particular devices or web browsers. Customers then use this data within Eva DSP to enhance and refine digital ad campaigns.

How does Eva use the information provided by Eva DSP advertisers?

We use any information provided by Eva DSP and Basis Platform advertising customers for the following service-related purposes:

• To provide, operate, manage, maintain and enhance the platform. We internally perform statistical and other analysis on information we collect (including usage data, device data, referral data, and information from page tags) to analyze and measure user behavior and trends, to understand how people use our services, and to monitor, troubleshoot and improve our services.
• To assist the enforcement of our Terms of Service.
• To prevent potentially illegal activities.
• To screen for undesirable or abusive activity.
• To contact you about your service or account. We occasionally send you communications of a transactional nature (e.g. service-related announcements, billing-related matters, changes to our services or policies, welcome emails when you first register, etc.). You can’t opt out of these communications, since they are necessary in order for us to effectively provide our services to you.
• To contact you for marketing purposes. We will only do this if you have given us your express permission to contact you for this purpose.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• To create new services, features or content. We may use any information you provide us (e.g. via email or through our ticketing system) to create and provide new services, features or content.

Will Eva share the information collected via the Eva DSP or Basis Platform?

1. We share aggregate information collected from the Eva DSP for marketing purposes. For example, we may issue a press release announcing that users who have visited travel sites have a higher click-thru rate on finance related web pages.
2. Billing and Contact information – We work with trusted agents and service providers to assist us in billing and account maintenance for our clients. These companies are required by contract to only use the information as directed by Eva and are prohibited from selling it. For example, if you fund your platform account with a credit card, we use a credit card processing company to bill you for the services and share your address and billing details with them in order to do so. These service providers do not retain, share, store or use that information for any other purpose.

CHANGES TO THIS POLICY

We may revise this policy at any time. However, if we make material changes, we will not apply them retroactively.