EVLVE — Privacy Policy

Last updated: October 8, 2026

This Privacy Notice for EEVA EVE LLC (doing business as "EVLVE") ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including our website at evlve.app, our mobile application, and when you otherwise engage with us.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us using the details in the "How Can You Contact Us" section below.

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide when you register for the Services, when you use features of the app, or when you otherwise contact us. The personal information we collect includes:

Sensitive information

When necessary, with your consent or as otherwise permitted by applicable law, we process the following category of sensitive information:

We maintain a separate Consumer Health Data Privacy Policy at evlve.app/health-data-privacy with more detail on the health data we collect, why, who we share it with, and how to exercise your rights over it — including for consumers covered by state consumer-health-data laws such as Washington's My Health My Data Act. We apply those protections to all users, not only Washington residents.

Payment data

We may collect data necessary to process your payment if you choose to make a purchase, such as your payment instrument number and its associated security code. All payment data is handled and stored by Stripe. We do not receive or store your full card number, expiration date, or CVV. You may find Stripe’s privacy notice at https://stripe.com/privacy.

Social media login data

We provide you the option to register or log in using your Google account. If you choose to do this, we will receive certain profile information about you from Google, as described in "How Do We Handle Your Social Logins?" below.

Application data

If you use our mobile application, we may also collect the following, consistent with permissions you grant:

Information automatically collected

In Short: Some information — such as your IP address, browser, and device characteristics — is collected automatically when you use our Services.

This information does not reveal your specific identity but may include device and usage information such as your IP address, browser and device characteristics, operating system, and information about how and when you use our Services. We also collect information through cookies and similar technologies (see Section 5 below), including:

Creator referrals

If you arrive through a creator's link (evlve.app/r/...) or enter a creator's code, we store which creator referred you, whether it was a link or a code, and when. A creator link you tap is remembered on your device for up to 60 days so the referral still counts if you sign up later. For members who were referred, we also record the date and amount of each subscription payment in your first 12 paying months, so we can pay that creator a commission.

If you’re an EVLVE creator

If you apply to or join the creator program, we also collect what you give us in your application and on your creator page: your name as shown to followers, your code, your social media handles and links, your audience size and description, your country, your PayPal email, and when you accepted the creator agreement. We keep records of the commissions and payouts we calculate for you, and your monthly statements show counts and amounts only, never the names or emails of members you referred. If we ask for a tax form (W-9 or W-8BEN), you upload it to private storage that only you and EVLVE can open; we use it only for tax reporting. We share your PayPal email and payout amounts with PayPal to pay you, and tax information with tax authorities where the law requires it.

Google API

Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements (https://developers.google.com/terms/api-services-user-data-policy).

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. Some purposes below describe planned uses (marked accordingly), not just current features.

We process your personal information for the following reasons:

3. What Legal Bases Do We Rely On to Process Your Information?

In Short: We only process your personal information when we have a valid legal reason to do so under applicable law.

If you are located in the EU or UK, this section applies to you. The GDPR and UK GDPR require us to explain the legal bases we rely on:

If you are located in Canada, this section applies to you. We may process your information with your express or implied consent, which you can withdraw at any time, or in specific circumstances permitted by law (such as fraud detection and prevention, or disclosure required by a court order). We may disclose de-identified information for approved research or statistics projects, subject to confidentiality commitments.

4. When and With Whom Do We Share Your Personal Information?

In Short: We may share information with the categories of third parties below, and in specific situations described in this section.

We share data with third-party vendors and service providers who perform services for us and require access to do that work. We have contracts in place with these providers designed to safeguard your personal information; they may not use it for their own purposes or share it with anyone else.

The categories of third parties we share personal information with are:

We may also need to share your personal information in the following situations:

5. Do We Use Cookies and Other Tracking Technologies?

In Short: We use cookies and similar technologies to collect and store information, for site functionality today and for advertising once that feature is live.

We use cookies and similar tracking technologies to maintain the security of the Services and your account, save preferences, and support basic site functions. Once advertising features are live, we (or our service providers) may also use these technologies for analytics and to tailor advertising to your interests, which may appear on our Services or elsewhere.

To the extent these technologies are deemed a "sale" or "share" (including targeted advertising) under applicable US state laws, you can opt out as described in "Do United States Residents Have Specific Privacy Rights?" below.

Specific information about the cookies we use and how to control them is in our Cookie Notice at evlve.app/cookies.

6. How Do We Handle Your Social Logins?

In Short: If you register or log in using your Google account, we may have access to certain information about you.

Our Services let you register and log in using your Google account. When you do this, we receive certain profile information from Google — typically your name, email address, and profile picture. We use this information only for the purposes described in this Privacy Notice. We do not control, and are not responsible for, Google’s own use of your information; we recommend reviewing Google’s privacy notice.

7. How Long Do We Keep Your Information?

In Short: We keep your information for as long as you have an account with us, unless a longer period is required by law.

We only keep personal information for as long as necessary for the purposes in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax or accounting requirements). No purpose in this notice requires us to keep your personal information longer than the period in which you have an account with us. When you delete your account, deletion is immediate — see Section 15 below. The exception is the commission record for a payment you made after a creator referred you: we keep the amount and date for our tax and accounting records, no longer linked to you.

8. How Do We Keep Your Information Safe?

In Short: We aim to protect your information through organizational and technical security measures.

We use encrypted transmission (HTTPS/TLS), database-level access controls (row-level security), and rely on infrastructure providers with their own security programs. However, no transmission or storage method is 100% secure, and we cannot guarantee absolute security. You should only access the Services within a secure environment.

9. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18.

We do not knowingly collect, solicit, or sell personal information from anyone under 18. By using the Services, you represent that you are at least 18. If we learn that we have collected information from someone under 18, we will deactivate the account and delete the data. If you become aware of this, contact us at eeva@evlve.app.

10. What Are Your Privacy Rights?

In Short: Depending on where you live, you may have rights that give you greater access to and control over your personal information. You may review, change, or delete your account at any time.

If you are in the EEA, UK, Switzerland, or Canada, you may have the right to access, correct, or erase your personal information, restrict or object to its processing, request data portability, and not be subject to solely automated decisions with legal or similarly significant effects. You can exercise these rights by contacting us (see Section 14). If you are in the UK and unhappy with how we handled a complaint, you can also contact the Information Commissioner’s Office (ico.org.uk/make-a-complaint). If you are in the EEA, you may contact your local data protection authority; in Switzerland, the Federal Data Protection and Information Commissioner.

Withdrawing your consent

Where we rely on your consent, you can withdraw it at any time by contacting us at eeva@evlve.app. This won’t affect the lawfulness of processing before withdrawal.

Opting out of marketing communications

Once marketing emails are live, you can unsubscribe at any time via the link in those emails or by contacting us at eeva@evlve.app. We may still send you non-marketing, service-related messages necessary to administer your account.

Account information

You can review or update your training experience, equipment, and physical considerations at any time in Settings. To terminate your account, delete it from Settings — deletion is immediate. We may retain limited information as needed to prevent fraud, comply with legal requirements, or enforce our terms.

Cookies

Most browsers accept cookies by default; you can usually set your browser to remove or reject them, though this may affect some features. See our Cookie Notice at evlve.app/cookies.

11. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of a state with a comprehensive privacy law (including California, Colorado, Connecticut, Virginia, and others), you may have the right to access, correct, delete, or obtain a copy of your personal information, and to opt out of certain processing. These rights may be limited by applicable law.

Categories of personal information we collect

The table below shows the categories of personal information collected in the past twelve months. The "Examples" column illustrates what each legal category can include under applicable law — it does not mean EVLVE collects every example listed. The "Collected" column reflects what EVLVE actually collects or has concretely planned.

Category Examples Collected
A. Identifiers Real name, alias, postal address, phone number, unique identifier, IP address, email address, account name YES
B. CA Customer Records categories Name, contact information, education, employment, financial information YES (name, email, subscription/billing reference — not education or employment)
C. Protected classifications Gender, age, race, ethnicity, marital status NO
D. Commercial information Transaction information, purchase/subscription history, payment information YES
E. Biometric information Fingerprints, voiceprints NO
F. Internet or network activity Browsing history, interactions with our Services and advertisements YES
G. Geolocation data Coarse, IP-derived location YES
H. Audio, electronic, visual, or similar information Images, audio/video recordings NO
I. Professional or employment information Job title, work history NO
J. Education information Student records NO
K. Inferences Inferences drawn to create a profile of preferences or characteristics YES (training tier and progression are derived from logged performance)
L. Sensitive personal information Health data YES

Sources and use of this information

See "What Information Do We Collect?" (Section 1) for sources, and "How Do We Process Your Information?" (Section 2) for how we use it.

Will your information be shared with anyone else?

We disclose personal information to our service providers under written contracts, as described in Section 4. We do not consider this "selling" your information.

We have disclosed the following categories of personal information to service providers for a business purpose in the past twelve months: Identifiers, CA Customer Records categories, Commercial information, Internet/network activity, Geolocation data, Inferences, and Sensitive personal information (health data).

We have sold the following category of personal information in the past twelve months: none to date. We may in the future sell de-identified, aggregated information (never identifiable, individual-level data) to research and data-licensing partners.

We have shared (in the CPRA sense — cross-context behavioral advertising) the following categories, once advertising features are live: Identifiers and Internet/network activity, with Ad Networks, Retargeting Platforms, and Social Networks.

Your rights

How to exercise your rights

To exercise these rights, contact us at eeva@evlve.app. Upon receiving your request, we will need to verify your identity before acting on it. If you use an authorized agent, we may require written proof of authorization.

Appeals

If we decline to act on your request, you may appeal by emailing eeva@evlve.app. We will respond in writing with our reasoning. If your appeal is denied, you may complain to your state attorney general.

California "Shine the Light" law

California residents may request, once a year and free of charge, information about categories of personal information we disclosed to third parties for direct marketing purposes in the prior calendar year. Submit such requests to eeva@evlve.app.

12. Do Other Regions Have Specific Privacy Rights?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We process personal information under Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020 where applicable. You have the right to request access to or correction of your personal information by contacting us. If you believe we are unlawfully processing your information, you may complain to the Office of the Australian Information Commissioner or the Office of the New Zealand Privacy Commissioner.

Republic of South Africa

You have the right to request access to or correction of your personal information by contacting us. If unsatisfied with our response, you may contact the Information Regulator (South Africa) at enquiries@inforegulator.org.za.

13. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time, indicated by an updated "Last Updated" date. If we make material changes, we will notify you by prominent notice or direct communication.

14. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, email us at eeva@evlve.app.

15. How Can You Review, Update, or Delete the Data We Collect From You?

You may have the right to request access to the personal information we collect from you, details about how we've processed it, correct inaccuracies, or delete it, and to withdraw consent where applicable. To make this request, email eeva@evlve.app. We will respond in accordance with applicable law.