PRIVACY POLICY
Last updated January 26, 2020
1. Your Privacy
Evergreen Capital Advisors LLC (“Evergreen Capital”, “we”, “our” or “us”) is committed to protecting and respecting your privacy.
Evergreen Capital provides education, training, and consulting services (together, the “Services”) via its website evergreencapitaladvisors.com (our “Website”). Your access to and use of our Website is subject to the Terms of Use and this privacy policy (this “Policy”).
The purpose of this Policy is to explain to you how we collect, store, process, transfer, share and use (together, “Process”) information that identifies or is associated with you (“Personal Information”) and information regarding our use of cookies and similar technologies. It also explains what choices you have with respect to your Personal Information.
We process personal information about individuals who are: (a) our direct users or customers; (b) individuals for whom a purchase or booking has been made by a third party; (c) individuals who have been named in a purchase or booking by a customer; (d) individuals who have been named in interactions with us; and (d) where our customer is a business or similar entity, individuals that are our customer’s employees, agents and other representatives. The individuals about whom we collect Personal Information are referred to as "you" throughout this Policy.
This Policy applies to our Website, the Services and your interactions with us.
Before accessing our Website, using the Services or interacting with us, please ensure that you have read and understood how we Process your Personal Information as described in this Policy. By accessing our Website, using the Services or interacting with us, to the extent permitted by applicable law, you are consenting to us Processing your Personal Information in accordance with this Policy, although your consent may not be required for all of the elements described in this Policy. Please ensure that you have received the consent of any individual before naming them in a purchase, booking or in any interactions with us.
2. Personal Information We May Collect
We collect Personal Information about you when you provide this information directly to us (or someone gives us information about you) when you access our Website, use the Services or interact with us. This can include information you provide to us when you purchase an item, make a booking, fill in a form, correspond with us via our Website (including comments or material posted, uploaded or stored on our Website), telephone, text, email or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, engage in competitions or promotions, respond to surveys or use some other feature of our Website or the Services as available from time to time.
If you choose not to provide Personal Information, we may not be able to provide the Services to you or interact with you or the Services or our interactions may be limited.
We also automatically collect some Personal Information about you when you access our Website. This includes information about how you access and use our Website and the Services and information about the device you use to access our Website and the Services.
We may also record and share information that you post publicly on social media platforms such as Facebook, Instagram, LinkedIn, Twitter, and others. For example, if you tag an Instagram post with the hashtag #EvergreenCapital or #EvergreenLLC, we may share your image and caption with our own followers.
The schedule (at the end of this Policy) sets out the categories of Personal Information we collect about you and how we use that information. The schedule also lists the legal basis that we rely on to Process the Personal Information.
Evergreen Capital does not rent, swap or sell your Personal Information to other organizations for them to use in their own commercial activities.
3. Cookies and Other Tracking Technology
When you use our Website, some information is collected about you automatically. This information is typically collected through a variety of tracking technologies, including cookies, and may include web beacons, embedded scripts, flash objects and similar technology.
Cookies are used as part of a normal business procedure to track patterns of behavior of visitors to our Website by saving your information (such as your internet protocol (IP) address and other preferences (including the kind of content viewed or clicked on and the frequency and duration of your activities)). Cookies help us to improve our Website and to deliver a better and more personalized service to you. A cookie is an element of data that our Website sends to your browser, which is then stored on your system. The cookies we use are designed to help you get the most from our Website but if you do not wish to receive cookies, most browsers allow you to set your browser to prevent this happening. If you select this setting, however, you may be unable to access certain parts of our Website. These settings will typically be found in the "options" or "preferences" menu of your browser.
We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for our Website and to understand more about the demographics of our users. You can learn more about Google’s practices at https://policies.google.com/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.
4. Marketing and advertising
From time to time, with your consent, we may contact you with relevant information about the Services. Most of these messages will be sent by email. For some messages, we may use Personal Information we collect about you to help us determine the most relevant information to share with you.
If you no longer wish to receive such messages from us, you may opt-out by clicking on the unsubscribe link at the bottom of our emails at any time.
5. Disclosure of Personal Information
We may disclose your Personal Information to the following, as relevant:
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our employees, officers and contractors (who are under a duty of confidentiality to us);
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third party vendors and other service providers that perform services for us or on our behalf, which may include (but is not limited to) providing e-commerce and booking platforms, sales fulfillment services, mailing or email services, messaging platforms, tax and accounting services, payments processing, data enhancement services, cloud based storage platforms, fraud prevention, web hosting, or providing analytic services. Your Personal Information is never transferred to any third-party for the purposes of re-marketing to you;
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third parties in connection with a business transaction or potential business transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a part of our business;
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third parties as required by law or if we reasonably believe that such action is necessary (a) to comply with the law or the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Website or the Services; (c) to prevent any illegal activity (including for the purposes of fraud protection and credit risk reduction); and (d) in connection with any legal proceedings or prospective legal proceedings;
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any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personal Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal Information; and
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in order to establish, exercise, protect or defend the rights, property, or personal safety of Evergreen Capital, our customers, users or others.
Except as provided in this Policy, we will not provide your Personal Information to third parties. Moreover, we do not rent, swap or sell Personal Information with any third party for their own commercial activities.
6. Retention of Personal Information
Evergreen Capital Advisors will retain your Personal Information for as long as is necessary to perform our contract with you, meet our legitimate interests or our legal obligations or in accordance with your consent, as relevant.
7. Safekeeping of Personal Information
We implement appropriate technical and organizational measures to protect your Personal Information against accidental or unlawful destruction, loss, change or damage.
All Personal Information you provide to us is stored on secure servers.
Any online payment transactions will be encrypted using SSL technology.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will use reasonable endeavors to protect your Personal Information, we cannot guarantee the security of data transmitted to our Website, so any transmission is at your own risk.
8. International Transfer Of Personal Information
The Personal Information that we collect from you may be transferred to, and stored at, a destination outside the country you are in where we and or third party service providers have operations. If you are located in the European Union (the “EU”), your Personal Information may be Processed outside of the EU. Where it takes place, the international Processing of Personal Information is necessary for the provision of our Website and the Services (including, without limitation, for the processing and fulfillment of your purchase or booking, the processing of your payment details, fraud and security checks and the provision of support services).
By submitting your Personal Information, you agree to this transfer and Processing of your Personal Information. We will take reasonable organizational and technical precautions to ensure that your Personal Information is treated securely and in accordance with this Policy when such a transfer and Processing takes place.
9. Your Controls And Rights Over Personal Information
If you are located in the EU you have the following rights in respect of your Personal Information that we hold:
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right to rectification: you have a right to request the rectification of your Personal Information by us where the Personal Information is inaccurate or incomplete. You can also review or edit the Personal Information you have supplied to us in respect of a booking by accessing your online account with us;
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right to object: where we Process your Personal Information based on our legitimate interests, you have a right to object to such Processing, in whole or part;
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right to withdraw consent: where we Process your Personal Information based on your consent, you have a right to withdraw your consent in whole or part. If you withdraw your consent to the Processing of your Personal Information, we might not be able to provide you with all (or any) of the Services. In certain cases, we may continue to process your Personal Information after you have withdrawn consent if we have a legal basis to do so, or if your withdrawal of consent was limited to certain Processing activities. For example, we may keep Personal Information if we need to do so to comply with a legal obligation or to resolve disputes;
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right to deletion: you can request that we delete your Personal Information, unless the Processing is being done pursuant to a legal obligation;
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right of access: you have the right to get confirmation of whether we are Processing your Personal Information and to obtain a copy of your Personal Information in an easily accessible format;
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right to transfer: where we Process your Personal Information based on your consent or contract, you have a right to request that we transfer some of your Personal Information to third parties; and
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right to restriction of Processing: you have the right to request us to restrict the Processing of your Personal Information under certain circumstances, such as where you think that the Personal Information we Process about you is incorrect or unlawful or where we no longer need the Personal Information but you need us to keep it in order to establish, exercise or defend a legal claim.
Evergreen Capital will help you exercise these important rights and will carry out your request unless certain exceptional reasons arise permitting Evergreen Capital to keep certain Personal Information about you. Please contact us (see contact details below) for assistance in exercising any of these rights.
10. Protecting children’s privacy
You must be at least 18 years of age to use our Website or, if you are under 18 years of age, have the permission of your parent or guardian to use our Website. We do not knowingly collect, use or share information that could reasonably be used to identify children under the age of 16 without prior parental or guardian consent or consistent with applicable law. If you learn that someone younger than 16 has provided us with Personal Information, please contact us and we will takes steps to delete such Personal Information.
11. Third Party Links
Our Website may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to those websites.
12. Changes to our Privacy Policy
We may update this Policy periodically. Any changes we may make to this Policy in the future will be posted on this page, so you should occasionally check back and review it.
Contact
Questions, comments and requests regarding this Policy are welcomed and should be addressed to info @ evergreen.llc
Schedule
Categories of Personal Information And How We Use the Personal Information
1. Personal Information Provided By You
(a) Contact information and basic personal details (such as your full name, postal address, email address and telephone number).
We use this Personal Information to communicate with you for a variety of reasons (for example, in relation to a purchase or booking (such as sending purchase or booking receipts, confirmations, statements, invoices, payment reminders and purchase status updates), sending you news, alerts, newsletters, marketing communications and general (non-marketing) commercial communications and following-up on abandoned carts or failed bookings); to supply you with purchased goods or provide booked courses or expeditions; to collect payments from you for purchases or bookings; to address questions from you; to carry out or support promotions; to deal with complaints made by or about you relating to the Services; for authentication purposes; to create customer accounts and operate, maintain and provide to you the features and functionality of our Website and the Services.
(b) Payment details (such as your credit card information, account information, billing address and related information). Please note that we do not retain your credit card details after completion of your payment.
We use this Personal Information to facilitate and collect payment for purchases or bookings and to detect and prevent fraud.
(c) When you contact us directly, such as by email, telephone, text, mail, when you post on message boards, blogs, or social media or complete an online form or provide quality survey input, feedback or testimonials, we will record your comments and opinions.
We use this Personal Information to communicate with you for a variety of reasons (for example, for purposes such as those noted in (a) above); to address your comments, questions, issues and concerns and improve the Services; to determine, provide, improve and develop features, products, content and services that may be of interest to you; and to send you news, alerts and marketing communications in accordance with your marketing preferences. We may also post customer testimonials on our Website or re-post social media material that is related or relevant to us, our Website or the Services.
2. Information Collected Automatically
Information from your devices (computers, mobile phones, tablets, etc.) and about your visits to and use of this website. The IP address used to access our Website will be logged along with the dates and times of access. Please note that any recorded IP addresses are not linked to personally identifiable information.
We use this information to analyze trends, administer our Website, track users movement and gather broad demographic information for internal use; to enable our Website and the Services to be properly presented to you on your device; to determine products and services that may be of interest to you for marketing purposes; and to operate, maintain and provide to you the features and functionality of our Website and the Services.
Legal basis Relied upon to Process Personal Information
To the extent that Evergreen Capital’s Processing of your Personal Information is subject to the General Data Protection Regulation 2016, the legal basis we rely on to Process your Personal Information in any particular case will depend upon the circumstances for which it is being Processed but will fall into one of the following categories:
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where you have given your consent for us to Process your Personal Information in such manner;
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where the Processing is necessary for the performance of our contract with you or to take steps prior to entering into a contract (e.g. to provide a quote or further information to you);
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where the Processing is necessary for our legitimate interests, namely in running a commercial enterprise. In pursuance of our legitimate interests, we only Process Personal Information in ways a customer or user would reasonably expect, unless we have a good reason to do otherwise; or
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where the processing is necessary for us to comply with the law.