Privacy Policy

1. Data Controller

The data controller for personal data collected through the EVOLVE platform is Humman Finance Marketplace OÜ, with registered address at Harju maakond, Tallinn, Kesklinna linnaosa, Kentmanni tn 4, 10116, Estonia, and contact address admin@evolve.market. Personal data is processed in accordance with Regulation (EU) 2016/679 (GDPR) and the Estonian Personal Data Protection Act (IKS).

2. Data We Collect

EVOLVE collects only personal data that is adequate, relevant and limited to what is necessary for the purposes indicated. Data processed may include:

• •Identification data: full name, email address, phone number.
• •Browsing and usage data: IP address, device type, pages visited, session duration.
• •Data provided through contact or technical support forms.
• •Platform preference and configuration data.
• •Data required for identity verification where required by applicable law.

3. Purposes of Processing

Personal data is processed for the following purposes:

• •Managing User registration and account on the platform.
• •Providing technological services for financial information visualisation and organisation.
• •Handling technical support and customer service requests.
• •Complying with applicable legal and regulatory obligations.
• •Improving platform functionality, security and user experience.
• •Sending service communications, technical notices and updates.

4. Legal Basis for Processing

Processing of personal data is based on the following legal grounds under Article 6 of the GDPR:

• •Contract performance: processing necessary to provide the requested service.
• •Legal obligation: processing required by applicable law.
• •Legitimate interest: improving security, preventing fraud and statistical analysis.
• •User consent: where expressly requested for specific purposes.

5. Sharing Data with Third Parties

EVOLVE does not sell or transfer personal data to third parties for commercial purposes. Data may be accessed, to the extent strictly necessary, by:

• •Technology and hosting service providers acting as data processors under contract.
• •Public authorities and regulatory bodies where required by law.
• •Third-party service providers whose integration has been expressly authorised by the User.

6. International Data Transfers

Where data is transferred outside the European Economic Area (EEA), EVOLVE ensures such transfers are made subject to appropriate safeguards under Chapter V of the GDPR, including standard contractual clauses approved by the European Commission or other recognised transfer mechanisms.

7. Data Security

EVOLVE implements appropriate technical and organisational measures in accordance with Article 32 of the GDPR to ensure an adequate level of security, including:

• •Encryption of data in transit using TLS 1.3 and at rest using AES-256.
• •Role-based access controls and principle of least privilege.
• •Continuous infrastructure monitoring and incident detection.
• •Regular vulnerability assessments and security audits.

8. Data Retention

Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected and applicable legal obligations. Once this period expires, data will be securely deleted or anonymised.

9. Users' Rights

Users may exercise the following rights at any time with the data controller:

• •Right of access: obtain confirmation of whether their data is being processed and access it.
• •Right of rectification: request correction of inaccurate or incomplete data.
• •Right of erasure: request deletion of their data where applicable.
• •Right to object: object to processing of their data in certain circumstances.
• •Right to restriction: request restriction of processing in the cases provided for.
• •Right to portability: receive their data in a structured and commonly used format.
• •To exercise these rights, contact admin@evolve.market.

10. Minors

The EVOLVE platform is not directed at persons under 18 years of age. EVOLVE does not knowingly collect data from minors. If data from a minor is detected, it will be immediately deleted.

11. Cookies

EVOLVE uses first-party and third-party cookies for the proper functioning of the platform, usage analysis and personalisation of the User experience. Detailed information on cookies used can be found in the Cookie Policy available on the platform.

12. Policy Amendments

EVOLVE reserves the right to amend this Privacy Policy at any time. Changes will be published on the platform with the update date indicated. Where changes are material, Users will be notified appropriately.

13. Supervisory Authority

Users have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), Tatari 39, 10134 Tallinn, Estonia, or the supervisory authority competent in their country of habitual residence.