This Notice explains how Evardo as a data controller uses Personal Information about you in a business context if you are:

• a Supplier or if you represent an organization that is a Supplier;
• a Customer or if you represent an organization that is a Customer; or
• Web Users.

We refer to this as “Business Information.”

“Evardo” means Evardo, Incorporated in the Dubai and its subsidiaries and affiliates worldwide.  Supplier” means a current or prospective vendor, supplier, subcontractor or partner of Evardo. “Customer” means a customer, prospective customer or target customer of Evardo. “Web User” means a user of a Evardo internet website. “Third Party Service Provider” means a third party vendor or supplier outside Evardo who may have access to Business Information in providing services to Evardo. “Personal Information” means information relating to an identified or identifiable natural person that is processed by or on behalf of Evardo by automatic means.

1. What Business Information does Evardo collect?

The type of Business Information that Evardo collects and uses depends on the particular business context and the purpose for which it was collected. It may include:

• contact details (such as your name, job title, gender, work address, telephone numbers, email address, fax numbers and so on);
• details of your relevant experience and/or academic and professional qualifications (for example, if you are employed by a vendor);
• details of your business and other interests and opinions (for example, where information is held in a Customer Relationship Management database);
• for Web Users, information relating to your use of the Evardo website, including the content of web forms, contributions made to any discussion forums and browsing history, IP addresses and your path through the Evardo website;
• credit card details, credit worthiness, and other financial-related information, such as your bank account number and other relevant payment-related information collected in support of a business transaction;
• CCTV images and visit information for visitors to Evardo sites.

2. What will Evardo do with your Business Information?

Generally, Evardo only uses Business Information for one or more of business-related purposes below:

• Negotiating, concluding and performing contracts with Customers (including the provision of financial services and advice);
• Managing Evardo accounts and records;
• Advertising, marketing and public relations (including direct marketing);
• Market Research and competitor analysis;
• Negotiating, concluding and performing contracts with Suppliers;
• Communicating with Individuals that are, or who represent, Customers, Suppliers or Web Users;
• Operating the Evardo website, including the use of analytics software;
• Supporting Evardo’s corporate social responsibility activities;
• Facilitating the security of Evardo sites, websites and other assets;
• Legal and regulatory compliance and internal control evaluations and audits (including where conducted by Evardo’s internal and external audit service providers);
• Debt administration; and/or
• Obtaining legal advice, including for legal proceedings and litigation and also in connection with the sale, purchase or merger of a business.

We process Business Information for the above purposes as necessary for our legitimate business interests and those of third parties that we interact with. Certain aspects of our processing are also necessary for us to comply with the law or are based on your consent, or other available legal grounds for processing.

3. Evardo data privacy principles

Evardo observes the following principles in relation to Business Information:

• We process it fairly and lawfully;
• We process it for a specific legitimate business purpose and do not process in a manner incompatible with that purpose without your knowledge and/or consent;
• We use Business Information that is adequate, relevant and not excessive for the purpose for which it is processed;
• We keep it accurate and, as necessary, up to date;
• We keep it in a form which permits identification for no longer than necessary for the purpose for which it was collected;
• We protect it against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, using appropriate technical and organizational measures;
• We process it in accordance with an Individual’s rights;

4. Who is your Business Information disclosed to?

(a) Within Evardo

Evardo restricts access to Business Information to people within the company who have a “need to know” that information. As a global company doing business across national borders and with certain shared services and resources, there are many situations where this “need to know” requires your information to be transferred to Evardo in another country, including countries that may provide no legal protection for Personal Information. However, the purpose of the Evardo Data Privacy for Business Information Policy is to ensure protection for your Business Information in every country where Evardo does business based upon it being approved by the relevant EEA data protection authorities as ‘Binding Corporate Rules’.

(b) Outside Evardo

Evardo shares Business Information with authorized Third Party Service Providers.  Where it does so, Evardo imposes appropriate contractual obligations regarding Business Information on such Third Party Service Providers.

Beyond its Third Party Service Providers Evardo will only disclose your Business Information to third parties outside Evardo:

• when required to do so by law;
• in response to a legitimate request for assistance by the police or other law enforcement agency;
• to protect an individual’s vital interests;
• to seek legal advice from Evardo’s external lawyers or in connection with litigation with a third party;
• in connection with the sale, purchase or merger of a business; or
• to engage external auditors to validate Evardo’s financial accounts.

When doing so, your Business Information may be transferred to non-EU countries which do not provide the same level of legal protection as in your own country. However, it is our practice to apply appropriate safeguards to protect your Business Information, such as relying upon the third party’s membership of the EU-US Privacy Shield. 

5. Exercising your rights

(i) Web Users, Customers and those representing Customers

If you would like a copy of any of your Business Information or if you would like to update or correct it or you would like to request Evardo to stop sending you marketing materials either generally or via a particular media, please contact Evardo. However, please note that we may continue to send you non-marketing communications (such as service related communications), and that we will keep a record of your request as well as your contact details to ensure that your request is respected.

If you have a concern about how Evardo has used your Business Information, as a first step, you should raise the concern in writing to the Evardo business with which you do business.

If your complaint is not resolved within a reasonable time of it being made to Evardo, it can be escalated to the Global Privacy Office at evardo@evardo.in. After investigating an escalated concern, the Global Privacy Office will respond to you in writing within a reasonable time setting out its conclusions together with details of any remedial action that it proposes to take.

In some circumstances, you have a right to request the erasure of your Business Information or a restriction to its use, to object to its use, to receive it in a portable format or to have it transmitted to another organization. If you wish to exercise any of these rights, please contact Evardo.

If your concern relates to Business Information subject to the laws of the European Economic Area and it has not been fully resolved by the Global Privacy Office, you are entitled to lodge your concern with your local Data Privacy Authority or before the courts in your country where you may seek compensation from Evardo for any loss or damage that you have suffered. 

(ii) Suppliers and those representing Suppliers

If you would like a copy of any of your Business Information or if you would like to update or correct it, please contact Evardo.

If you have a concern about how Evardo has used your Business Information, as a first step, you should raise the concern in writing to the Evardo business with which you do business.

If your complaint is not resolved within a reasonable time of it being made to Evardo, it can be escalated to the Global Privacy Office at evardo@evardo.in. After investigating an escalated concern, the Global Privacy Office will respond to you in writing within a reasonable time setting out its conclusions together with details of any remedial action that it proposes to take.

6. Retaining your Business Information

Depending on the purposes for which we are processing your Business Information, we may keep your Business Information for as long as is necessary for these purposes, and in particular to protect ourselves in the event of a legal claim. Limitation periods for bringing claims vary across jurisdictions; for instance, the applicable limitation period for most contractual claims in the world is six years from the alleged breach of contract.