Privacy Policy

Last updated April 24, 2023

This Privacy Policy tells you how we collect, use and share information we collect (a) through the provision of our Services, and (b) on the Eva website at https://evafamily.app (the “Site”). By using the Services and/or the Site and submitting information you agree to the terms of this Privacy Policy. This Privacy Policy should be read in conjunction with, and is incorporated into, the Eva websiteTerms and Conditions of Use and the Eva Terms of Service applicable to the Eva Services you are using, which are available as follows (each, referred to herein as the “Terms of Service”):

This Privacy Policy is governed by the laws of the state specified in the Terms of Service apply to your Services. Capitalized, but undefined terms used in this Privacy Policy have the meaning assigned to those terms in the Terms of Service applicable to the Eva Services you are using.

1. The Services

Parental Beacon LLC (“Eva” or “we” or “us”), is a US-based Limited. Our Services assist you in monitoring the use of computer devices and applications under your control by minor children or disabled adult(s) placed under your protection as the legal guardian, by a court or appropriate government authority (your “Dependent(s)”), family member(s) or another person(s) whose devices are monitored and/or managed through your use of the Services. The Services allow you to determine the devices and applications to be monitored for each of your Covered Account(s) (as such term is defined in the applicable Terms of Service). The Eva Services automatically deploy the configuration and the instructions given by you and you are solely responsible for the configuration of the Services for your Covered Account(s).

2. Data Collection by Eva

The Account Data and personal data about you or your Covered Accounts (hereinafter the "Data") that can be collected by us through the use of the Services or the Site are as follows:

2.1 Browsing

We automatically collect information when you visit the Site including your device's IP address, browser and operating system, and statistics about how you use the Site. If you connect to our Site using a mobile device we may also collect information about your device including the operating system and browser used and a unique device identification number. We may collect information from the online interactions of subscribers through other websites, such as social media sites, email accounts or other interactive sites when you identify those sites to us.

2.2 Cookies

We use cookies and similar technology to collect aggregate (non-personal) information about Site usage by all of our visitors and to help us remember you and your preferences when you revisit the Site. These cookies may stay on your browser into the future until they expire or you delete them. We also use technology to remember your purchase selections in your shopping cart. These cookies usually are erased when you close your browser window. Further general information about cookies and how they work is available at www.allaboutcookies.org.

2.3 Third Party cookies

We allow selected third parties to place cookies through the Site to provide us with better insights into the use of the Site or user demographics or to provide relevant advertising to you. For instance, we allow Google Analytics to place cookies through our Site to collect aggregated information about use of our Site and Site visitors to assist us in our analysis to provide better services to you. These third parties may collect information about a consumer's online activities over time and across different websites when he or she uses our website. We may also permit third party service providers to place cookies through our Site to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third party cookies or the resulting information and we are not responsible for any actions or policies of such third parties.

2.4 Do-Not-Track

We do not use technology that recognizes a “do-not-track” signal from your web browser.

2.5 Web-forms

If you submit any webform to us, we collect the data indicated in the forms indicated in and submitted through these forms by you, including name and email address. Required data in order to send the webform is indicated. This data is used for processing your request and contacting you for further communication.

2.6 Registration Data

On registering for Eva Services, we will collect the following personal data: name, company/institution (if applicable to Services chosen), email address, payment information (if applicable) and at least one user name and password (“Registration Data”). This data is obligatory and if it is not provided, an account cannot be created.

2.7 Covered Account Data

On your behalf, as a principal function of the Service, we collect and process personal data relating to your Covered Accounts. Our system uses proprietary algorithms to review Covered Account(s)' online interactions through their registered devices and applications including interactions of Covered Accounts with websites, social media sites, email accounts or other interactive sites including posts, blogs and other communications.

3. Use of Data Collected by Eva

3.1 Registration Data

We are responsible for processing your Registration Data, which is used for communications with you and for the provision and management of your use of our Services. It is also used to measure and improve the Services and functionality and to provide customer service, send email notifications and (unless no longer in the distribution list) newsletters, or communications, in general, about the Services, products and novelties, and offers or promotions offered by us. We will use the Registration Data for these purposes and to comply with the Terms of Service applicable to your Services and other legal notices.

3.2 Covered Account Data

You and, if applicable, your registered Administrators and Users (collectively, your “Authorized Users''), will be sent notification and other reports concerning certain Covered Account Data monitored by the Services. Your Authorized Users will have access to all Covered Account Data in our possession for review and, if necessary, correction. Your Authorized Users may request access to such Covered Account Data by e-mailing our customer support at [email protected].

3.3 Sharing your Information

We treat your Data with strict confidentiality in accordance with applicable law. However, we may reveal your Data or other information about you to unaffiliated third parties: (1) if you request or authorize it; (2) if the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas (provided that we will notify you of any such communication of your Data to the extent legally permissible), to enforce our Terms of Service or other agreements, or to protect our rights, property or safety or the rights, property or safety of our users or others; (3) if the disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Data may be one of the transferred assets); (4) if the information is provided to our agents, outside vendors or service providers to perform functions on our behalf (e.g., analyzing data, providing customer service, processing orders, etc.); or (5) as otherwise described in this Privacy Policy. We will only share your Data with a third-party as described in items 3 through 5 of the preceding sentence if such third-party is obligated to protect your Data to the same extent we protect it under the terms of this Privacy Policy. We will never sell or rent your Data to third parties or augment, extend or combine your Data with data received from third party sources. Your Data will never be publicly displayed in any way by Eva or any person or entity acting on Eva’s behalf.

3.4 Commercial Communications

By filling in and sending your Registration Data to us, you expressly consent to receive electronic commercial communications regarding the subject matter of the Services, and other services including alerts and notices about your Covered Account(s), and, if you selected the “opt-in” mechanism, you may also receive newsletters, offers and promotions. If you do not wish to receive such information from us, you can expressly opt out by sending a notification to [email protected].

4. Children's Privacy

The Site and Services are designed to be a tool for parents and others to use to facilitate safe online interactions for Dependents. Only those over the age of 18, or those with the valid consent of his/her parent or legal guardian who is over the age of 18, may subscribe to our Services. This Site is not designed nor intended to be attractive to children under the age of 13. While our Services include analysis of online interactions by children, we do not knowingly collect data from children under the age of 13 without first receiving verified consent. If you are under 13 please do not submit any information to us.

5. Data Processing on Your Behalf: Eva as Data Processor.

5.1. User Data

Upon your registration for, and deployment of, the Eva Services, we start collecting Data from the devices and applications associated with the Covered Account(s), which may include personal data relating to you, to your Covered Accounts or to third parties, including information about your devices used by Covered Accounts, websites and applications that your Covered Accounts use, and contacts, connections, payments, messages and other communications, posted and received by your Covered Accounts (collectively, “User Data”). In accordance with applicable privacy law, to the extent that it applies to the Services, you and your Dependents are the respective Data Controllers (or the Responsible Party/ies) of this User Data and you appoint us as a Data Processor of such User Data for the purpose of providing our Services. User Data is not our property or under our control and is only monitored by us for purposes of providing the Services. Any User Data that combines personally identifiable information with non-personally identifiable information will be treated as personally identifiable information. We will take reasonably appropriate steps to maintain the accuracy of any User Data we collect.

5.2. Your use of User Data

As Data Controller, you warrant that you have the appropriate authority to collect and process the User Data and you agree to (i) process and use the User Data in accordance with this Privacy Policy, the applicable Terms of Service and applicable law (including any laws in the country where you reside or make beneficial use of the Service). You will not submit to the Services any personal data relating to any individual that has not authorized such processing. You will protect the confidentiality of any accessible User Data and prevent access by or disclosure to any unauthorized third person. You will inform us within 24 hours about any problem arising in relation with management of your Eva account and/or User Data. You and your Users will be responsible for any illegal use of other person’s data (personal or not) through the Services, including any use contrary to applicable data protection laws and/or in violation this Privacy Policy (including the Federal Family Educational Rights and Privacy Act of 1974 (“FERPA”) and/or in violation this Privacy Policy. The parties acknowledge that (a) User Data may include personally identifiable information from education records that are subject to FERPA ("FERPA Records"); and (b) to the extent that User Data in our possession, custody or control includes FERPA Records, we will be considered a "School Official" (as that term is used in FERPA and its implementing regulations) and will comply with FERPA. We will not disclose FERPA Records as “Directory Information” under FERPA.

5.3. Service Configuration

The Services provide device and application monitoring services for Covered Accounts as described in this Privacy Policy and the applicable Terms of Service. As part of the same, significant amounts of User Data may be collected and transmitted by the Services to Eva. You are responsible for setting the configuration of the Services that (i) controls the supervision and monitoring of activities, and (ii) determines the personal data to be monitored and collected. The setting of those configurations constitutes instructions by you for us to process User Data on your behalf as necessary to provide you the Services. The level and degree of such surveillance and monitoring is entirely under your control and we will not be liable for any such configuration and control carried out by you. All such User Data will be under your responsibility, with Eva as data processor in accordance with this Privacy Policy.

5.4. Data Processor Obligations

To the extent that we are a Data Processor on your behalf, we shall (a) implement appropriate technical and organizational measures to safeguard any User Data against any unauthorized or unlawful access, loss, destruction, theft, use or disclosure; (b) limit access to User Data only to those employees who need to know it to enable us to perform the Services; (c) only process the User Data as specified by this Privacy Policy and in accordance with your instructions, and (d) will not use the User Data for any purposes other than those related to the performance of the Services or pursuant to your written instructions. Upon the expiry or termination of this Agreement by way of de-registration, or upon your request, we will cease any and all use of the User Data and will destroy it. Other than as described in this Privacy Policy or the applicable Terms of Service, we will not disclose User Data to any third party without your prior written consent or pursuant to court or administrative order.

5.5. Subcontracting

As a Data Processor we may provide access to or otherwise process User Data through subcontractors, including our affiliates. We are responsible for our subcontractors’ compliance with our obligations under this Privacy Policy.

5.6. Cooperation

We will reasonably assist you with the necessary cooperation to allow you to verify our compliance with the obligations under this Privacy Policy. Upon written request, we will provide you with written evidence of the technical and organizational measures that have been taken to protect User Data, such as audit reports, privacy policies, certifications, or compliance with internationally recognized standards.

6. Security

We have put in place physical, electronic and managerial procedures to safeguard and help prevent unauthorized access, maintain data security and correctly use your Data. These safeguards vary based on the sensitivity of the Data. Nevertheless, no safeguards or procedures can be completely secure. We cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. We cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

7. Information Choices and Changes

Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you, and, as allowed by applicable law, requests for your participation in surveys. You can also usually choose how cookies are handled in your device via your browser settings. If you choose to disable cookies on your device, some features of the Services may not function properly or may not be available to you. Your rights under applicable law may include access to the Data we hold about you, as well as the right to have such Data corrected, deleted, or ported to another data controller, as specified by applicable law. For all such requests, please contact our customer service at [email protected].

8. Changes to Privacy Policy

Any information that is collected is subject to the Privacy Policy in effect at the time such information is collected. We may, however, modify and revise our Privacy Policy from time-to-time. If we make any material changes to this policy, we will notify you of such changes by posting them on the Site or by sending you an email or other notification, and we will indicate when such changes will become effective. By continuing to access or use the Services after those changes become effective, you are agreeing to be bound by the revised Privacy Policy.

9. Questions?

Please contact us at [email protected]if you have any questions about our Privacy Policy.