Privacy Policy
Who we are
EvoRep LLC provides software and related services designed to support organisations with Carbon Border Adjustment Mechanism, or CBAM, compliance processes.
For the purposes of applicable data protection law, the data controller responsible for the personal data described in this Privacy Policy is:
EvoRep LLC
Registered agent: Northwest Registered Agent, Inc.
1209 Mountain Road PL NE, Ste N
Albuquerque, New Mexico 87110
United States
Email: info@evorep.eu
This Privacy Policy applies to the EvoRep website at evorep.eu, including its contact forms, pilot-booking pages and related communications.
It does not cover personal data processed through the EvoRep software platform on behalf of customers under a separate customer agreement or data-processing agreement.
Personal data we collect
We may collect personal data directly from you when you contact us, book an EvoRep pilot or otherwise communicate with us.
Contact and enquiry forms
When you submit an enquiry through our website, we may collect:
- Your full name
- Your email address
- Your company
- Your company type
- Information you include in your message
- The date and time of your submission
Pilot bookings
When you book an EvoRep pilot through Google Calendar, we may collect:
- Your first and last name
- Your email address
- Your company
- Information you choose to include about the subjects you want to discuss
- Your selected appointment date and time
- Booking, confirmation and cancellation information
The booked appointment may also include a Google Meet link and information associated with the meeting invitation.
Communications
When you communicate with us by email, during a meeting or through another business channel, we may retain your correspondence and relevant notes about your enquiry or potential use of EvoRep.
Technical and security information
When you visit the website, our hosting, security and anti-spam systems may process technical information such as:
- Your IP address
- Browser and device type
- Operating system
- Requested pages and URLs
- Date and time of access
- Referring website
- Security events and attempted malicious activity
- Cookie and consent preferences
- Information generated through Google reCAPTCHA
We do not ask you to provide sensitive personal data through our website forms. Please do not submit health information, identification numbers, financial-account information or other sensitive information unless we specifically request it through an appropriate secure process.
How we use personal data
We use personal data for the following purposes:
Responding to enquiries
We use contact details and messages to understand your enquiry, communicate with you and provide information about EvoRep.
Arranging and conducting pilot calls
We use booking information to schedule the meeting, send confirmations and reminders, generate a Google Meet link and conduct the pilot call.
Understanding potential customer requirements
We may use the information you provide to understand how your organisation manages CBAM, whether EvoRep may be relevant to your workflow and which product features should be demonstrated.
Operating and protecting the website
We process technical and security information to:
- Operate and maintain the website
- Prevent spam, fraud and abuse
- Detect malicious activity
- Troubleshoot technical problems
- Protect the website, accounts and systems
- Maintain records of cookie choices
Managing business relationships
Where an enquiry develops into a commercial relationship, we may process personal data to prepare proposals, negotiate agreements, provide services and manage the customer relationship.
Complying with legal obligations
We may process or retain personal data where required to comply with applicable law, respond to lawful requests, establish or defend legal claims or protect our rights and those of others.
Legal bases for processing
Where the EU General Data Protection Regulation, UK GDPR or similar legislation applies, we rely on one or more of the following legal bases:
Steps requested before entering into a contract: We may process your information when you ask us to provide information, arrange a pilot, prepare a proposal or take other steps before a potential agreement.
Performance of a contract: Where you or your organisation becomes a customer, we may process information needed to provide and manage the agreed services.
Legitimate interests: We have legitimate interests in responding to business enquiries, developing customer relationships, operating our website, preventing spam and fraud and protecting our systems. We consider whether these interests are overridden by your rights before relying on this basis.
Legal obligations: We may process information where required by applicable laws, regulations, court orders or lawful regulatory requests.
Consent: We rely on consent where it is required, particularly for non-essential cookies or similar technologies. You may withdraw consent through the cookie settings or by contacting us.
EU guidance recognises contractual steps, legal obligations, legitimate interests and consent as potential lawful bases, depending on the circumstances. Legitimate interests must be balanced against the individual’s rights and freedoms.
Marketing communications
We do not currently add people to newsletters or promotional mailing lists merely because they submit an enquiry or book a pilot.
We may respond to your request and communicate with you about the specific enquiry, booking or potential business relationship.
If we introduce optional marketing communications in the future, we will provide an appropriate choice and obtain consent where required.
Cookies and similar technologies
The website may use cookies and similar technologies that are necessary for website operation, security, form functionality and remembering privacy choices.
Where required, non-essential cookies and third-party technologies will not be activated until you have made the relevant choice through our cookie banner.
You can accept, reject or manage applicable cookie categories through the cookie banner and revisit your choices using the Cookie Settings link on the website.
Further details will be provided in our separate Cookie Policy.
Google reCAPTCHA
We use Google reCAPTCHA to help protect website forms against spam, automated submissions and abuse.
When reCAPTCHA is used, Google may process technical and interaction information associated with your device and use of the website. Google processes this information under its own privacy terms.
The legal basis for our use of reCAPTCHA is our legitimate interest in protecting the website and preventing fraudulent or abusive submissions.
Google Calendar, Google Meet and Google Workspace
We use Google Workspace services, including Gmail, Google Calendar and Google Meet, to:
- Receive and respond to enquiries
- Provide the public appointment-booking page
- Schedule pilot calls
- Send booking confirmations and reminders
- Create and host online meetings
- Store related business communications
When you make a booking, the information submitted through the Google booking form is added to the relevant Google Calendar event and may be made available to authorised EvoRep hosts or co-hosts.
Google states that appointment schedules create public booking pages, collect the required attendee name and email fields and add confirmed appointments to the organiser’s calendar.
Google processes customer data under its applicable service terms and data-processing arrangements. Google’s data-processing addendum describes Google as a processor of Google Workspace customer data and addresses security, subprocessors and restricted transfers.
Contact forms and email delivery
Our website uses WPForms to provide the enquiry form.
WPForms Lite remote entry backups are disabled. Form submissions are transmitted to EvoRep through our configured website email system rather than being intentionally retained as remotely backed-up WPForms entries.
We use Easy WP SMTP with Google Workspace’s Gmail SMTP service to help deliver form notifications securely and reliably.
Hosting and security providers
Our website is hosted by Hostinger in its Frankfurt, Germany data-centre region.
Hostinger may process website content, server logs, IP addresses and other technical data as necessary to provide hosting, network, security and support services.
Hostinger’s data-processing addendum describes Hostinger as a processor of customer data and incorporates transfer safeguards including the EU Standard Contractual Clauses where applicable.
We also use Wordfence to protect the website against malicious traffic, unauthorised access, malware and other security threats. Wordfence may process IP addresses, access attempts and related technical security data. Wordfence states that it provides contractual safeguards, including Standard Contractual Clauses, for customers subject to GDPR requirements.
Who may access or receive personal data
Access to enquiries, bookings and related communications is limited to authorised EvoRep founders and employees who need the information for their work.
We may also disclose or make personal data available to:
- Website hosting and infrastructure providers
- Email and business-productivity providers
- Calendar, booking and video-meeting providers
- Website security and anti-spam providers
- Cookie-consent and compliance-service providers
- Professional advisers, such as lawyers or accountants, where necessary
- Regulators, courts, law-enforcement bodies or other authorities where legally required
- A purchaser, investor or successor in connection with a merger, financing, restructuring or sale of all or part of the business, subject to appropriate safeguards
We do not sell personal data.
International data transfers
EvoRep LLC is established in the United States, while the website is hosted in Germany.
Personal data may therefore be accessed or processed in the United States, Germany and other countries in which our service providers or their subprocessors operate.
Where applicable data-protection law requires safeguards for an international transfer, we rely on appropriate mechanisms such as:
- An adequacy decision
- The EU Standard Contractual Clauses
- The UK International Data Transfer Addendum
- A valid data-privacy framework certification
- Other legally recognised safeguards
You may contact us at info@evorep.eu for further information about the safeguards applicable to a particular transfer.
How long we retain personal data
We retain personal data only for as long as reasonably necessary for the purposes described in this policy.
Our general retention approach is:
Unsuccessful enquiries and pilot bookings: Up to 24 months after the most recent meaningful interaction.
Active customer and commercial records: For the duration of the business relationship and for any additional period required for contractual, accounting, tax, compliance or legal-claim purposes.
Email communications: For as long as reasonably necessary to manage the enquiry, business relationship or related legal obligations.
Security and technical logs: For as long as necessary to investigate security events, protect the website, troubleshoot technical issues and comply with applicable obligations.
Cookie-consent records: For as long as reasonably necessary to record and demonstrate the privacy choices made.
We may delete information earlier where it is no longer needed. We may retain limited information for longer where required by law or necessary to establish, exercise or defend legal claims.
Data security
We use reasonable technical and organisational measures intended to protect personal data against accidental loss, unauthorised access, misuse, alteration or disclosure.
These measures include access controls, account security, encrypted connections, security monitoring, anti-spam controls, backups and restrictions on who can access enquiry and booking information.
No website, transmission method or storage system can be guaranteed to be completely secure.
Your privacy rights
Depending on your location and applicable law, you may have the right to:
- Request access to your personal data
- Request correction of inaccurate or incomplete data
- Request deletion of your personal data
- Request restriction of processing
- Object to processing based on legitimate interests
- Receive certain data in a portable format
- Withdraw consent where processing is based on consent
- Lodge a complaint with a competent data-protection authority
These rights are not absolute and may be subject to legal conditions and exceptions.
To exercise a privacy right, email info@evorep.eu. We may need to request reasonable information to confirm your identity and understand your request.
Individuals in the EEA may lodge a complaint with the data-protection authority in the country where they live, work or believe an infringement occurred.
Automated decision-making
We do not currently use website enquiry or pilot-booking data to make decisions based solely on automated processing that produce legal or similarly significant effects.
Children’s privacy
The EvoRep website and services are intended for organisations and business professionals. They are not directed at children.
We do not knowingly collect personal data from children through the website. If you believe that a child has provided personal data to us, contact us so that we can review and, where appropriate, delete it.
Third-party websites and services
Our website may contain links to third-party websites or use embedded third-party services.
Those third parties may process personal data under their own privacy policies. We are not responsible for the privacy practices of independently operated third-party websites.
Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes to our website, services, providers or legal obligations.
The updated version will be published on this page, and the “Last updated” date will be revised.
Where a change materially affects how we process personal data, we will provide additional notice where reasonably appropriate or legally required.
Contact us
For privacy questions, requests or concerns, contact:
EvoRep LLC
Email: info@evorep.eu
Registered agent: Northwest Registered Agent, Inc.
1209 Mountain Road PL NE, Ste N
Albuquerque, New Mexico 87110
United States