EVALAN Privacy Policy

EVALAN Privacy Policy

Effective Date: January 01, 2023

This Privacy Notice describes the ways in
which EVALAN and its affiliates and subsidiaries (collectively, “BACE,” “we,”
“our,” and “us”) collect, receive, process, or store information,
including Personal Information, in connection with our business operations
(“Business Operations”), including the services we provide that
reference this Privacy Notice (collectively, the “Services”). We use the
term “Personal Information” to mean any information that identifies you as an
individual, is about you as an individual, or is otherwise defined as personal
information, personal data, or similar under applicable law.

1. Products & Services

We offer a range of hardware products and
cloud-based services, each of which provides a foundation for, and assists in
the development and deployment of, IoT solutions (collectively, “BACE Products”
and “BACE System”). BACE Products include BACE Hardware, BACE Cloud, the BACE
API, ARMOR and any other service that makes reference to this Privacy Notice.

2. Scope

This Privacy Notice applies to anyone that
interacts with our Business Operations or that uses the Services (collectively,
“you”). If you are interacting with our Business Operations or using the
Services on behalf of a company or other legal entity (“Your Organization”),
then (i) you represent and warrant that you have authority to act on behalf of,
and to bind Your Organization, and (ii) for all purposes in this Privacy Notice,
the term “you” means Your Organization on whose behalf you are acting.

3. Controller

The controller, i.e., the entity that is
responsible for the processing of your Personal Information, and which is
referred to by the term “EVALAN”, “BACE”, “we”, “us” or “our” in this Privacy Notice, is Evalan
B.V., an Amsterdam based company. BACE is a product developed by Evalan, and
this Privacy Notice specifically applies to Products or Services of Evalan that
are marketed under the name BACE (see also Section 1).
If the controller is one of our affiliates or subsidiaries (collectively, our
“Affiliates”), this will be explicitly stated at the point where the data
is collected or, respectively, where you have been referred to this Privacy
Notice, and the full address of the respective controller will be given at the
same location.

4. Collection of Information

This section describes the types of
information that BACE collects. The following types of information are
collected about you:

4.1 Information that You Provide.

We collect information that you provide to
us, when you set up an account with us, interact with us through Website, email,
social media or newsletter or otherwise use our Services. Information that you
may provide includes your name, email address and company name. BACE also
stores information that is generated by you, for example labels you give to
devices or services in our system, which is subject to this Privacy Notice as

4.2 Information Automatically Collected by BACE

The information that is automatically
collected by BACE can vary depending on the Services you are accessing or
using. We apply the principle of data minimisation, meaning that we will limit
data collection to what is directly relevant and necessary to accomplish the
purposes specified in Section 5.
If you are accessing or using the BACE Products, then the following will apply.
The information automatically collected and/or generated and exchanged between
a BACE Device and the BACE Cloud falls into three categories: Metadata, Measurement
Data and Geolocation information.

4.2.1 Metadata

The term “Metadata” means information
concerning the BACE Device, independent of the Assets with which it is
associated, such as the BACE Device’s ID, state or configuration. Metadata is
automatically collected with each interaction between BACE Cloud and the

4.2.2 Measurement Data

The term “Measurement Data” means all data
(other than Metadata) collected or generated by, or transmitted to, a BACE
Device, including data generated or collected by the Device’s internal or
external sensors or assets, and data transmitted from your applications to your
sensors or assets.

4.2.3 Geolocation Information

BACE Devices may determine their location
(your “Geolocation Information”) using your device features and/or through
the information provided by a third party, such as Google. We will always ask
for your consent before we access Geolocation Information on your device or
browser. You may revoke consent for accessing your Geolocation Information at
any time, in which case GPS localization and other applicable features in your
device will be disabled. Geolocation is always treated at Personal Information,
regardless of whether or not it is combined with any Personal Information
collected in the BACE System.

4.3 Information Automatically Collected by the

The following applies if you access or use
the website. BACE may gather certain information automatically from the
website, such as your IP address, browser type and version, operating system
name and version, viewed pages on the website, pages viewed before and after
accessing the website, and search terms used on the website. This information
helps BACE to recognize and personalize your experience if you return to the
website with the same device, and improve the website overall.

4.4 Cookies

We may gather information through the use
of cookies. Prior to placing cookies on your device, we will always request
your consent, with the exception of cookies that are essential for providing
website features requested by you. For more information, refer to the Cookie
Privacy Policy outlined in Section 7.

4.5 Anonymous Information

We may also collect, process, and use
information that does not identify you or your devices, and which is neither
stored on your device nor already present on your device, including information
that has been made anonymous by:

i. removing identifying fields and aggregating the
information with other information so that individuals cannot be re-identified,

ii. anonymizing the information with techniques that
remove or modify the identifying data so as to prevent re-identification of the
anonymized information (collectively, “Anonymous Information”).
Information that meets these criteria might include, for example, demographic
information, statistical information (e.g., hit counts), and general tracking

5. Use of Information

The information we collected about you is
used for the following purposes:

5.1 Provide the Business Operations and Services

We use your Personal Information for
Business Operations. This includes, providing you with the Services you request
or access, such as accessing or using the Services, creating and managing your
user accounts, and communicating with you about our Services

5.2 Analysis and Improvement

We may use your Personal Information and
Anonymous Information to perform internal administration, auditing, operation,
and troubleshooting in connection with Business Operations, including to
evaluate and improve our Services, and to develop and test Services. For example,
we may use Metadata for improving, measuring use of, analysing performance of,
fixing errors in, providing support for, and developing BACE Hardware, BACE
Cloud, BACE Website and other BACE Products through various methods, including:

i. combining or aggregating the information
collected through the device or elsewhere for generating and analysing
statistics about use of the device, user demographics, traffic patterns, and
other metrics, and;

ii. using anonymized data that may or may not be
derived from Personal Information but does not personally identify you.

5.3 Information and Notices

If you submit your Personal Information to us, we may
provide you with information about Business Operations and the Services or
required notices.

BACE does not sell or share your Personal Information with
other companies for any purpose.

6. Storage

6.1 Security

We have implemented reasonable measures to
protect your information from unauthorized access, use or disclosure. BACE
maintains administrative, technical and physical safeguards designed to protect
the collected information that are appropriate to the nature, size, and
complexity of our Business Operations. For example:

i. BACE incorporates on-device security features,
data-in-transit and data-in-rest security protections set out in the BACE
datasheets, and these are designed to prevent unauthorized access to, or use of
the device and the data exchanged with other applications; and

ii. communications between the BACE Cloud and BACE
Devices are end-to-end encrypted and authorized via certificates. In addition,
you are responsible for implementing commercially reasonable security safeguards
consistent with customary industry practices to prevent unauthorized access to,
or use of the BACE Device. BACE is not responsible for the security of
information that you transmit over networks that BACE does not control,
including the Internet and wireless networks.

iii. The complete BACE System is regularly
penetration tested by an independent and specialized firm. Recommendations
following from the results of this tests are implemented.

6.2 Retention

BACE retains information (including
associated Personal Information) in for as long as necessary to fulfil the
purposes for which we collected it, in particular:

i. Device Meta, Measurement and Geolocation data that
is collected automatically is kept for 90 days, unless specifically requested
otherwise by you.

ii. Personal Information that is provide by you to
us will generally be kept during the term of the contract and the subsequent
statute of limitation period for claims arising out of the contract.

6.3 Reviewing, Deleting, or Correcting Information

In addition to any additional legal rights,
you may have that are described in Section 7, if you wish to review, correct, or
request that we delete information about you (including incorrect Personal
Information), you may send a written request to BACE using the contact
information provided in Section 10. Please understand that we may not be
able to change or delete your information if the information is necessary for
our Business Operations or necessary for compliance with applicable law.

7 Cookie Policy

We only use cookies for your convenience. 

A cookie is a small text file that is placed on your computer or mobile device
when you visit a website, which can be used to identify your device. When you
visit our website, you are asked to give permission for placing the cookies.
And you will be informed about the types of cookies that are placed. You can
refuse the use of cookies yourself by setting this in your browser.

evalan.com uses cookies for the following functionalities:




We use Hubspot as our CRM and marketing email
& automation platform. Cookies are stored only if marketing consent has
been given. Here you can view Hubspot’s Privacy Policy:


We use Leadfeeder as our lead generation optimization tool.
Cookies are stored only if marketing consent has been given. 

Here you can view Leadfeeder’s Privacy Policy: https://help.leadfeeder.com/en/articles/3561400-gdpr-privacy-and-security-summary.

Google Analytics

We use Google Analytics, a web analysis
service provided by Google Inc. In it, the IP address of our web users is
anonymized for privacy. You can read more about how Google uses your Personal
Information here: 

You can also opt-out of Google Analytics

Google Ads
Bing Ads
Linkedin Ads
Facebook Ads

We use Google ads, Bing ads, LinkedIn ads and Facebook ads as paid
traffic sources to grow our audience and to provide you with targeted
advertisements or marketing communications that we believe may be of interest
to you. Retargeting is also possible if marketing consent has been given.

For more information about how targeted advertising works, you can
visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

    FACEBOOK – https://www.facebook.com/settings/?tab=ads

    GOOGLE – https://www.google.com/settings/ads/anonymous

    BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

    LINKEDIN – https://www.linkedin.com/psettings/guest-controls

Additionally, you can opt out of some of these services by
visiting the Digital Advertising Alliance’s opt-out portal at:  http://optout.aboutads.info//

Please note that we do not alter our Site’s data collection and
use practices when we see a Do Not Track signal from your browser


We use CookieYes as our cookies consent &
management system

8 Your Choices and Rights Regarding Your Personal

8.1 Legal Framework

In the field of privacy and protection of your
Personal Information, BACE deals with the following legal framework and rules:

i. Dutch Personal Data Protection Act (Wbp). This
Act lays down the most important rules for handling personal data in the
Netherlands. The Dutch Data Protection Authority supervises the enforcement of
this Act. Since 1 January 2016, there is also an obligation to report data

ii. General Data Protection Regulation EU 2016/679
(“EU GDPR”). This is the EU regulation that replaces the Wbp as of
May 2018.

8.1.1 Legal Basis for Processing

For purposes stated in Section 5, the legal basis (GDPR) for the processing
of your Personal Information is as follows:

– Where we use your Personal Information for
Business Operations, the processing is generally necessary for the performance
of a contract to which you are a party or in order to take steps at your
request prior to entering into a contract (Article 6(1)(b) of the GDPR).

– Where we seek your consent for other purposes, the
legal basis is consent (Article 6(1)(a) of the GDPR).

– In relation to a legitimate interest, BACE may,
for example, us your contact details to invite you for an event.

– Based on an agreement or for the conclusion of
an agreement.

8.1.2 Your GDPR Rights

Under the GDPR, you have the following
rights in relation to your Personal Information each subject to the legal
requirements set out in the respective provisions of the GDPR:

– The right to request access to information
regarding our processing of your Personal Information (Article 15 of the GDPR);

– The right to obtain rectification of your
Personal Information that is inaccurate (Article 16 of the GDPR);

– The right to obtain the deletion of your
Personal Information (Article 17 of the GDPR), or the restriction the processing
of your Personal Information (Article 18 of the GDPR);

– The right to receive a copy of your Personal
Information in a structured, commonly used and machine-readable format (data
portability) (Article 20 of the GDPR);

– Where processing of your Personal Information is
based on your consent, the right to withdraw consent at any time, without
affecting the lawfulness of processing based on such consent before such

If you wish to exercise any of your rights
above, please contact us using the contact information provided in Section 10. You also have the right to lodge a
complaint with your local competent supervisory authority or any authority that
applies to BACE.

9. Third-Party Websites and Platforms

Communications from BACE may contain links
to websites and platforms operated by third parties. You acknowledge and agree
that BACE is not responsible for the collection and use of your information by
such websites or platforms that are not under our control. We encourage you to
review the privacy notices of each website and platform you visit or access, so
you understand such website operator’s privacy practices.

10. Changes to this Privacy Notice

From time to time, we may change this Privacy
Notice for our business purposes and to comply with changes in applicable law.
If we make any substantive or material changes, then we will communicate these
changes to you by posting the updated Privacy Notice on the Website, and/or
notifying you of the change via the Services, email, or other methods. Where
permitted under applicable law, your continued use of the Services following
such notice constitutes your agreement to follow and be bound by the updated Privacy

11. Contact Information

If you have any questions about this Privacy
Notice or the collection or use of information about you, please contact Evalan
using either of the following contact information:

Email:                    info@evalan.com

Telephone:         +3120 779 0344