We will not use personal information for a materially different purpose without obtaining consent or otherwise having legal authority to do so.

 

5. CONSENT

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We obtain consent where required by law. Consent may be express or implied depending on the nature of the information, the circumstances and your reasonable expectations.

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By voluntarily providing personal information to us, you consent to its collection, use and disclosure for the purposes described in this Privacy Policy or identified when the information is collected.

 

You may withdraw consent by contacting us, subject to legal and contractual restrictions and reasonable notice. Withdrawing consent may affect our ability to respond to an enquiry or provide certain services.We may collect, use or disclose personal information without consent where permitted or required by law.

 

6. HOW WE DISCLOSE PERSONAL INFORMATION

 

We disclose personal information only as reasonably necessary for the purposes described in this Privacy Policy or as otherwise permitted or required by law.

 

Personal information may be disclosed to:

• Technology, website-hosting and cloud-service providers;

• Email, communication and collaboration providers;

• Customer relationship management and business administration providers;

• Analytics and website-performance providers;

• Payment, banking, accounting and professional-service providers;

• Contractors or specialists supporting an authorized engagement;

• Affiliates, implementation partners or referral partners where you have consented or where disclosure is necessary for a requested service;• Government, regulatory, law-enforcement or legal authorities where required; and

• A purchaser, successor or other party involved in a proposed or completed business transaction, subject to appropriate confidentiality protections.

 

We expect service providers handling personal information on our behalf to use appropriate confidentiality and security safeguards. Where appropriate, we use contractual protections governing the handling of personal information.

 

We do not rent, sell or trade personal information or customer lists.

 

7. COOKIES AND SIMILAR TECHNOLOGIES

 

Our website uses cookies and similar technologies to support website functionality, security, performance and user preferences.

 

Cookies may include:

 

• Essential cookies, which are required for the website to function;

 

• Functional cookies, which remember preferences or enhance website features;

 

• Analytics cookies, which help us understand website traffic and usage; and

 

• Marketing cookies, which may help measure communications or advertising activity.

 

Where required, non-essential cookies are used only after you provide consent through our cookie banner or preference tool.

 

You may accept, decline or manage non-essential cookies through the available cookie settings. You can also control cookies through your browser, although disabling certain cookies may affect website functionality.

 

8. MARKETING COMMUNICATIONS AND CASL

 

Evolve complies with Canada’s Anti-Spam Legislation (“CASL”) when sending commercial electronic messages.

 

Where required, we will:

• Obtain express or valid implied consent;

• Clearly identify Evolve as the sender;

• Provide accurate contact information; and

• Include a functioning unsubscribe mechanism.

 

You may unsubscribe using the link provided in a message or by contacting connect@evolvegroup.ai.

 

We may still send non-promotional communications that are necessary to respond to an enquiry, administer a business relationship, deliver contracted services or meet legal obligations.

 

9. INTERNATIONAL AND CROSS-BORDER PROCESSING

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Personal information may be stored or processed in Canada and in other jurisdictions where our service providers operate, including the United States.

 

When personal information is processed outside Canada, it may be accessible to courts, governments, law-enforcement agencies or regulatory authorities under the laws of that jurisdiction.

 

We take reasonable steps to select reputable service providers and use appropriate organizational, contractual and technical safeguards for cross-border processing.

 

10. RETENTION

 

We retain personal information only for as long as reasonably necessary to:

 

• Fulfil the purposes for which it was collected;

• Maintain an active or prospective business relationship;

• Provide services and support;

• Meet legal, tax, accounting, contractual or regulatory obligations;

• Resolve disputes; and

• Establish, exercise or defend legal claims.

 

Retention periods vary according to the nature of the information and the purpose for which it is held.

 

When personal information is no longer reasonably required, we securely delete, destroy or anonymize it. We may retain aggregated or anonymized information that no longer identifies an individual.

 

11. SECURITY

 

We maintain reasonable administrative, organizational, technical and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, loss or destruction.

 

These safeguards may include:

 

• Access controls and limited permissions;

• Authentication and account-security measures;

• Encryption in transit where supported;

• Secure cloud and technology providers;

• Confidentiality obligations;

• Backup and recovery practices; and

• Periodic review of our information-handling practices.

 

No electronic system or transmission method is completely secure. We cannot guarantee absolute security, but we take reasonable measures appropriate to the nature of the information we handle.

 

12. PRIVACY INCIDENTS AND BREACH NOTIFICATION

 

If a privacy or security incident affects personal information, we will investigate the incident and take reasonable steps to contain it, reduce potential harm and prevent recurrence.

 

We will notify affected individuals, the Office of the Information and Privacy Commissioner of Alberta and any other applicable authority when required by law.

 

13. ACCESS, CORRECTION AND DELETION REQUESTS

 

You may request access to personal information we hold about you or ask us to correct information that is inaccurate or incomplete, subject to applicable legal exceptions.

 

You may also ask us to delete personal information, subject to applicable legal, contractual, operational and record-retention requirements.

 

To make a request, email connect@evolvegroup.ai with the subject line:Privacy Request – [Your Full Name]

 

Please describe your request clearly. We may ask for information reasonably necessary to verify your identity before responding.

 

We will generally respond to an access request within 45 calendar days, subject to any extension or different timeframe permitted or required by applicable law. If a fee is legally permitted and reasonably necessary, we will notify you before processing the request.

 

14. QUESTIONS AND COMPLAINTS

 

If you have a question or concern about our handling of personal information, please contact our Privacy Officer first so that we can review and respond to the matter.

 

If you are not satisfied with our response, you may contact:

 

Office of the Information and Privacy Commissioner of Alberta

Website: https://oipc.ab.ca/

 

Depending on the matter and applicable legislation, you may also have the right to contact the  Office of the Privacy Commissioner of Canada or another relevant privacy authority.

 

15. INDIVIDUALS OUTSIDE CANADA

 

If privacy legislation outside Canada applies to our handling of your personal information, you may have additional rights under that legislation.

 

Where the European Union or United Kingdom General Data Protection Regulation applies, those rights may include:

 

• Access to personal information;

• Correction of inaccurate information;

• Deletion in certain circumstances;

• Restriction of processing;

• Objection to certain processing;

• Data portability;

• Withdrawal of consent; and

• The right to make a complaint to an applicable supervisory authority.

 

These rights are subject to the requirements and exceptions contained in the applicable legislation. To exercise a privacy right, contact connect@evolvegroup.ai.

 

16.CHILDREN’S PRIVACY

 

Our website and services are intended for businesses and professionals. They are not directed toward children under 16, and we do not knowingly collect personal information from children under that age.

 

If you believe a child has provided personal information to us, please contact our Privacy Officer.

 

17. THIRD-PARTY WEBSITES

 

Our website may include links to websites, platforms or services operated by third parties.

 

We do not control and are not responsible for the privacy, security or content practices of third parties. We encourage you to review their privacy policies before providing personal information.

 

18. CHANGES TO THIS PRIVACY POLICY

 

We may update this Privacy Policy periodically to reflect changes to our practices, technology, services or legal obligations.

 

The revised version will be posted on our website with an updated “Last updated” date. Material changes may also be communicated through another appropriate method where required.

 

19. CONTACT THE PRIVACY OFFICER

 

Evolve Strategy & Capital Inc.

Operating as Evolve Advisory Group

 

Privacy Officer

Calgary, Alberta, Canada

Email: connect@evolvegroup.ai