Privacy Policy

Controller: Global Talent Consulting LLCTrade name: EvolutivasEIN: 42-2701728Address: 1209 Mountain Road Pl NE, Ste R, Albuquerque, NM 87110, United StatesEmail: contacto@evolutivas.comWebsite: evolutivas.com

Representative for the European Economic Area

Where the General Data Protection Regulation applies, Evolutivas has appointed the following representative in the European Economic Area:

Representative: Michael SchneiderAddress: Taunusanlage 8, 60329 Frankfurt am Main, GermanyEmail: michael@evolutivas.com

Individuals located in the European Economic Area and the relevant data protection authorities may contact this representative regarding the processing of personal data subject to the General Data Protection Regulation.

General inquiries or privacy-related requests may also be sent to contacto@evolutivas.com.

This policy applies to personal data processed by Evolutivas through:

• The website and its forms.
• Communications by email, phone or video call.
• Diagnostic forms, assessments and digital tools.
• Meetings, business proposals and hiring processes.
• Professional communications carried out via LinkedIn, email or other B2B channels.
• The provision of consulting, artificial intelligence transformation, Growth & Revenue, digitalization and product services.
• The relationship with clients, prospective clients, suppliers, partners, collaborators and professional contacts.

Evolutivas provides services from the United States and may interact with individuals and organizations located in various countries.

Evolutivas' obligations and the rights available to each individual may vary depending on:

• Their country, state or region of residence.
• The place from which they access the services.
• The nature of the relationship maintained with Evolutivas.
• The law applicable to the specific processing.

This policy sets out the general principles applied by Evolutivas to the processing of personal data on a global level.

Where local law grants additional rights or safeguards, Evolutivas will apply such provisions to the extent legally required.

Individuals located in the European Economic Area

Where the General Data Protection Regulation applies, Evolutivas will process personal data based on one of the following legal bases:

• The individual's consent.
• The performance of a contract or the application of pre-contractual measures.
• Compliance with a legal obligation.
• The legitimate interest of Evolutivas or a third party, provided the individual's rights and freedoms do not override it.
• Other legal bases recognized by applicable law.

Individuals located in the European Economic Area may exercise the rights recognized by the General Data Protection Regulation and file a complaint with the competent data protection authority in their country.

Individuals located in the United Kingdom

Where United Kingdom privacy law applies, individuals may exercise the rights recognized by such law and file a complaint with the Information Commissioner's Office or another competent authority.

Individuals located in the United States

Certain U.S. states recognize specific rights related to access, knowledge, correction, deletion, portability or limitation of the use of personal data.

Evolutivas will honor such rights where the relevant state law applies to the company and the processing carried out.

Evolutivas does not sell personal data in exchange for monetary consideration.

Individuals located in other countries

Individuals located in other jurisdictions may exercise the rights recognized by the privacy laws applicable in their country.

Requests may be sent to contacto@evolutivas.com. Evolutivas will assess each request in accordance with applicable law and may request information reasonably necessary to verify the individual's identity.

Depending on your relationship with Evolutivas, we may process the following categories of data:

Identification and contact data

• First and last name.
• Email address.
• Phone number.
• Country or professional location.
• Information provided during communications.

Professional and business data

• Company or organization.
• Job title or professional role.
• Company size and industry.
• Public professional profile.
• Areas of interest.
• Needs, challenges, goals and projects of the organization.

Data related to inquiries, diagnostics and assessments

• Information included in forms or messages.
• Responses provided in questionnaires, diagnostics or assessments.
• Information about an organization's artificial intelligence processes, tools, systems or use cases.
• Information about the organization's level of maturity, digitalization, compliance or technology adoption.
• Results, scores, recommendations or action plans generated from the data provided.

We recommend not including confidential information, third-party personal data, or sensitive or special categories of data —such as medical, biometric, ideological, religious, political or trade union information— unless strictly necessary and expressly requested.

Contractual and administrative data

Where a business relationship exists, we may process:

• Contracting data.
• Information about contracted services.
• Communication history.
• Proposals, agreements and project documentation.
• Billing and payment data.
• Information necessary for administrative, accounting, tax or legal management.

Technical and browsing data

When you use the website, we may process:

• IP address.
• Device type.
• Browser and operating system.
• Date, time and duration of the visit.
• Pages viewed.
• Information about interactions with the site.
• Referral address or traffic source.
• Identifiers associated with cookies or other similar technologies.

The use of non-essential cookies will be subject to consent given through the cookie settings panel where required by applicable law.

Personal data may come from:

• The data subject themselves.
• Their company or organization.
• Website forms and tools.
• Meetings, emails and professional communications.
• Publicly available professional sources, such as corporate pages, business directories or professional profiles.
• B2B professional information platforms and providers.
• Social networks and professional platforms.
• Clients, collaborators, partners or professional contacts who make an introduction or referral.

Where the data has not been obtained directly from the individual, Evolutivas will provide the corresponding information when required by applicable law.

Handling inquiries and information requests

We may use the data to:

• Respond to inquiries.
• Understand the needs of the individual or their organization.
• Assess the suitability of our services.
• Coordinate meetings or initial conversations.
• Prepare proposals, quotes or initial recommendations.
• Follow up on a request.

Where applicable law requires identifying a legal basis, the processing may be based on the application of pre-contractual measures, consent, or Evolutivas' legitimate interest in handling professional communications.

Conducting diagnostics and assessments

We may process the responses provided to:

• Prepare indicative results.
• Identify opportunities, gaps or risks.
• Assess an organization's level of maturity.
• Generate scores, recommendations or action plans.
• Determine the suitability of Evolutivas' services.
• Follow up on results when requested.

Where identifying a legal basis is required, the processing may be based on the individual's consent, the application of pre-contractual measures, or the performance of a requested service.

Managing the business and contractual relationship

When our services are contracted, we will use the data to:

• Formalize and execute the contractual relationship.
• Manage projects, tasks and deliverables.
• Coordinate meetings and operational communications.
• Manage access to tools and collaboration spaces.
• Issue invoices and manage payments.
• Maintain business and administrative records.
• Comply with accounting, tax and legal obligations.

Where identifying a legal basis is required, the processing will be based on the performance of the contract, compliance with legal obligations, or the legitimate interest in properly managing the professional relationship.

Conducting B2B commercial communications

We may contact professionals and representatives of organizations to present services, resources or proposals that we consider relevant to their activity or professional responsibilities.

These communications may be carried out using data obtained directly from the individual, their organization, publicly available professional sources, or business information providers.

Where applicable, this processing will be based on Evolutivas' legitimate interest in developing B2B business relationships, provided the rights and interests of the contacted individual do not override it.

The individual may object at any time by replying to the message received or writing to contacto@evolutivas.com.

Where a commercial communication requires prior consent, it will only be sent after such consent has been obtained.

Sending content, news or periodic communications

Where a person has voluntarily subscribed, we may send:

• Professional content.
• Reports, guides or resources.
• Event invitations.
• Service updates.
• Commercial communications.
• Updates on artificial intelligence, Growth, digitalization or regulatory compliance.

Where applicable, this processing will be based on consent, which may be withdrawn at any time.

Analyzing and improving the website

We may use technical and browsing data to:

• Measure website usage.
• Understand aggregate visitor behavior.
• Detect technical issues.
• Improve content, navigation and performance.
• Analyze the source of visits.
• Assess the performance of campaigns and business actions.
• Improve user experience and conversion.

Where applicable law requires consent for the use of analytics, advertising or similar cookies, these technologies will only be activated after the individual has accepted them.

Ensuring security and preventing misuse

We may process technical and activity data to:

• Protect our systems.
• Prevent fraud.
• Detect unauthorized access.
• Investigate incidents.
• Prevent abusive or unlawful use.
• Ensure the security of the website, tools and information.

Where identifying a legal basis is necessary, this processing may be based on Evolutivas' legitimate interest in protecting its infrastructure, users and information.

Handling legal obligations and claims

We may retain and use information when necessary to:

• Comply with legal or regulatory obligations.
• Respond to requests from authorities.
• Bring, exercise or defend legal claims.
• Manage disputes or proceedings.
• Prevent legal liability.
• Protect the rights and interests of Evolutivas or third parties.

This processing may be based on compliance with legal obligations or Evolutivas' legitimate interest in protecting and defending its rights.

Fields marked as mandatory are necessary to process the request or provide the corresponding service.

The individual is not required to provide optional fields. However, the absence of certain information may prevent us from properly understanding the inquiry, responding to it, preparing a diagnosis, or providing the requested service.

The individual providing data declares that it is true, accurate and current, and undertakes to report any relevant changes.

Evolutivas does not sell personal data to third parties in exchange for monetary consideration.

Data may be processed by providers that render services on behalf of Evolutivas, including:

• Web hosting and technology infrastructure providers.
• Email and communications services.
• CRM and business management tools.
• Forms and diagnostics platforms.
• Automation tools.
• Meeting and video call scheduling platforms.
• Cloud storage and collaboration services.
• Digital analytics providers.
• Advertising and measurement platforms, when authorized.
• Artificial intelligence or automated processing providers.
• Billing, accounting and administrative management services.
• Payment providers.
• Legal, tax, accounting or technology advisors.
• Professionals, collaborators or partners involved in providing a service.

These providers will only have access to the information necessary to render their services and must process it in accordance with their contractual, confidentiality and data protection obligations.

Data may also be disclosed to:

• Government authorities.
• Courts and judicial authorities.
• Regulatory or data protection authorities.
• Law enforcement agencies.
• Auditors, advisors or prospective acquirers, in the context of a corporate transaction.

These disclosures will be made where there is a legal obligation, a valid request, a contractual need, or a legitimate interest permitted by applicable law.

Evolutivas operates from the United States and uses technology providers that may be located in different countries.

As a result, personal data may be processed, stored or transferred outside the country or region where the individual is located.

Destination countries may apply privacy rules different from those of the country of origin.

Where required by applicable law, Evolutivas will adopt measures intended to ensure an adequate level of protection, such as:

• Adequacy decisions issued by a competent authority.
• Providers' adherence to recognized privacy frameworks.
• Standard contractual clauses.
• Data processing agreements.
• Additional contractual, technical and organizational measures.
• The individual's consent, where valid and necessary.
• Other legally permitted mechanisms.

For transfers of data originating from the European Economic Area, the United Kingdom or Switzerland, Evolutivas will apply, where applicable, the mechanisms recognized by the laws of those jurisdictions.

You may request additional information about the applicable safeguards by writing to contacto@evolutivas.com.

Data will be retained only for as long as necessary to fulfill the purposes for which it was collected.

As a general rule:

• Inquiries that do not lead to a business relationship: up to 12 months from the last interaction.
• Professional contacts and B2B prospecting activities: up to 24 months from the last relevant interaction, unless an earlier objection is raised.
• Consent-based subscriptions and communications: until consent is withdrawn or unsubscription is requested.
• Clients and suppliers: for the duration of the contractual relationship and thereafter for the periods required by applicable tax, accounting, contractual or legal regulations.
• Diagnostics and assessments: for the time necessary to deliver the results and carry out the requested follow-up, with a general maximum of 24 months if no business relationship is established.
• Browsing and cookie data: for the periods established in the Cookie Policy or in the settings panel.
• Data related to claims or disputes: until the corresponding legal or statute-of-limitations periods end.
• Security logs: for the time reasonably necessary to investigate incidents, prevent fraud or protect systems.

When data is no longer necessary, it will be deleted, anonymized, or, where required by law, blocked for the corresponding period.

Depending on applicable law, individuals may exercise one or more of the following rights:

• Access: to know what personal data we process and obtain a copy.
• Rectification: to correct inaccurate or incomplete data.
• Erasure: to request deletion of the data when it is no longer necessary.
• Objection: to object to certain processing, particularly commercial communications.
• Restriction: to request that processing be restricted under certain circumstances.
• Portability: to receive the data provided in a structured format and transmit it to another controller where applicable.
• Withdrawal of consent: to withdraw any consent given, without affecting the lawfulness of processing carried out previously.
• Right to be informed: to request information about the categories, purposes and recipients of the data.
• Non-discrimination: not to receive discriminatory treatment for exercising legally recognized privacy rights.
• Not to be subject to solely automated decisions: when these produce legal effects or significantly affect the individual.
• Filing a complaint: to approach the competent privacy or data protection authority.

To exercise these rights, you may write to contacto@evolutivas.com.

Please indicate “Data Protection” in the subject line and specify the right you wish to exercise.

Where there are reasonable doubts about the identity of the individual, we may request additional information to verify it.

We may also request information necessary to determine which law applies to the request.

Evolutivas will respond within the time period established by applicable law.

Individuals may file a complaint with the competent privacy or data protection authority in their place of residence.

Individuals located in Spain may contact the Agencia Española de Protección de Datos.

Individuals may request at any time to stop receiving commercial communications.

To do so, they may:

• Use the unsubscribe link included in the communication.
• Reply directly to the message received.
• Write to contacto@evolutivas.com.

Objecting to or unsubscribing from commercial communications will not prevent Evolutivas from sending messages necessary to manage a contractual relationship, provide a service, respond to an inquiry, or comply with legal obligations.

Evolutivas may retain minimal information to record and honor an unsubscribe or objection request.

Evolutivas does not, as a general rule, make solely automated decisions that produce legal effects on individuals or similarly significantly affect them.

Some diagnostic tools may automatically generate:

• Results.
• Scores.
• Classifications.
• Recommendations.
• Indicative action plans.

These results are informative and indicative in nature.

They do not replace professional, legal, technical, financial or compliance assessment and do not, by themselves, produce legal or contractual consequences.

Where an automated decision with significant effects is subject to specific requirements, Evolutivas will provide the information and safeguards required by applicable law.

Evolutivas may use artificial intelligence tools and systems to support certain activities, such as:

• Analyzing information provided in diagnostics.
• Generating drafts, summaries or recommendations.
• Classifying inquiries.
• Improving internal processes.
• Automating operational tasks.
• Supporting service delivery.

Where external artificial intelligence providers are used, Evolutivas will seek to limit the information shared to what is strictly necessary and to apply reasonable confidentiality and protection measures.

Highly confidential information, trade secrets, sensitive data or third-party personal information should not be entered into forms or tools unless expressly authorized.

Results generated through artificial intelligence may contain errors or inaccuracies and should be reviewed before making relevant decisions.

Evolutivas applies reasonable technical and organizational measures to protect personal data against:

• Unauthorized access.
• Accidental alteration or loss.
• Destruction.
• Improper disclosure.
• Unlawful processing.
• Unauthorized use.

Access to the data is limited to individuals and providers who need it to perform their functions.

The measures applied may include:

• Access controls.
• Passwords and authentication systems.
• Backups.
• Encryption where appropriate.
• Limitation of permissions.
• Confidentiality agreements.
• Provider review.
• Incident management procedures.

However, no system connected to the internet can guarantee absolute security.

In the event of a security breach, Evolutivas will apply the assessment, mitigation and notification procedures required by applicable law.

If you provide personal data about another person, you represent that:

• You have sufficient authorization to do so.
• The information is adequate, relevant and necessary.
• You have informed the person about the disclosure of their data where required.
• You are not infringing their rights or confidentiality obligations.

Third-party data that is not necessary for the inquiry or requested service should not be provided.

Evolutivas' services are primarily aimed at companies, organizations, professionals and individuals over 18 years of age.

Evolutivas does not knowingly collect personal data from minors.

If we discover that we have received data from a minor without the necessary authorization, we will take reasonable measures to delete it.

The website may include links to pages, social networks, tools or services managed by third parties.

Evolutivas does not control the privacy policies or practices of such third parties.

Before providing personal data on those services, we recommend reviewing the information provided by their respective controllers.

The inclusion of a link does not imply that Evolutivas endorses or assumes responsibility for the third party's privacy practices.

The website uses technical cookies necessary for its operation and may use analytics, personalization, measurement or advertising cookies.

Where required by applicable law, non-essential cookies will only be used after the individual has given their consent.

Information about the cookies used, their providers, purposes, duration and configuration options is available in the Cookie Policy and in the website's “Cookie Settings” panel.

The individual may modify or withdraw their consent at any time through that panel, without affecting the lawfulness of processing carried out previously.

In the event of a merger, acquisition, reorganization, asset sale, investment, financing, or total or partial transfer of the business, personal data may be disclosed to the parties involved in the transaction.

These parties must treat the information confidentially and use it solely to evaluate, negotiate or execute the transaction.

Where required, Evolutivas will inform individuals of any relevant change in the data controller or in the use of their data.

Evolutivas may update this Privacy Policy to reflect:

• Legal or regulatory changes.
• Technical changes.
• New services or features.
• Changes in our processes.
• Changes in providers or tools.
• New practices related to data processing.

The date of the last update will appear at the beginning of the document.

When relevant changes are introduced, Evolutivas may notify individuals through the website, email or other reasonable means.

For inquiries related to this policy or the processing of personal data:

Global Talent Consulting LLC – Evolutivas1209 Mountain Road Pl NE, Ste RAlbuquerque, NM 87110United StatesEmail: contacto@evolutivas.com

Contact for the European Economic Area

Michael SchneiderTaunusanlage 860329 Frankfurt am MainGermanyEmail: michael@evolutivas.com