Evolvio Privacy Statement

Evolvio LLC ("Evolvio," "we") provides a behavioral self-management tool that helps you understand and improve how you show up at work. Evolvio is designed around user control of your private behavioral record. This Statement explains what information we collect, what we keep, how we use it, and the choices and rights available to you.

What we collect (“Information”)

• Account information. Your name, email address, authentication or account identifiers, and account settings when you create or use an Evolvio account.
• Profile, goal, and preference information. Information you choose to provide about your professional goals, role or work context, development priorities, preferences, corrections, and other inputs used to personalize Evolvio.
• Session and integration data. Session identifiers, timestamps, permission and consent status, and limited application or meeting context needed to operate the service and associate a session with your Evolvio account, including the meeting identifier and current application context. In the Zoom experience, Evolvio uses Zoom's indication of which participant is currently speaking in order to identify which portions of your microphone audio are your own speech. Evolvio does not collect Zoom participant lists, participant names or identifiers, video, screen sharing, or Zoom-supplied meeting audio.
• Your microphone audio, and — only if you choose — meeting audio context. During a session, Evolvio captures audio from the audio-input device you select after you grant microphone permission. Before coaching begins, you choose whether Evolvio uses only your own speech, or also uses what others say in the meeting as context (“Everyone's audio”). The broader option is off by default, is never enabled automatically, and your choice is locked for that meeting. In the browser extension, enabling the broader option starts capture of the meeting tab's audio as a separate stream; in the default self-only mode, the tab stream is not requested or captured at all. The extension declares the tab-capture permission when it is installed, but the tab stream is only ever started after you explicitly select “Everyone's audio” and begin coaching. In the Zoom desktop experience, there is no tab audio and Evolvio has access only to your selected microphone. The microphone connection remains open during a coaching session, but in self-only mode Evolvio records and transmits audio for transcription only during the intervals Zoom identifies you as the active speaker; audio outside those intervals is not recorded or transmitted. A physical microphone may incidentally pick up sound audible around you — including another person's voice — during your speaking intervals, and speaker separation cannot be guaranteed to be perfect. Evolvio analyzes and creates a behavioral record only about you, never about other participants. Raw audio is processed transiently and is never retained.
• Transcript text. Evolvio uses a transcription provider to convert short audio segments into text for analysis. The transcript of your own words is kept for one year as part of your record. Other participants' words, however they reach Evolvio, are used only in the moment as context for coaching you and are discarded immediately — they are never stored, never appear in your reports, and are never used to build a record about anyone else.
• Platform captions and transcripts. Where your meeting platform generates captions or a transcript and displays its own indicator to participants, Evolvio may use that text as context for coaching you, under the same rule: your words join your record; other participants' words are discarded immediately after use. Evolvio never turns captions on for a meeting itself.
• Imported transcripts. You may import a transcript you already hold from another tool (for example, a notetaker you use). Imported transcripts are treated exactly like live ones: your own lines join your record under the one-year rule, and other participants' lines are used only as context and discarded immediately.
• Calendar information (future feature). Evolvio does not currently read your calendar. If calendar features are added, they will require your explicit, separate permission, and will read only meeting times, titles, and attendee information to provide coaching context and recognize schedule patterns such as back-to-back days. Raw calendar data will not be stored — only derived patterns and assessment outputs, under the retention policy in this Statement. Any use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
• Payment information (when paid subscriptions launch). Evolvio is free during the beta and does not collect payment information today. When paid subscriptions launch, payment will be processed by Stripe; Evolvio will receive subscription status and billing details needed to manage your account but will never store your card number.
• Your derived behavioral record. Evolvio may generate and retain user-focused information such as paraphrased evidence summaries, behavioral observations, interpretations, possible impacts, alternative explanations, confidence indicators, goal relevance, longitudinal patterns, reports, practices, corrections, and other product outputs. These outputs are created for your self-management and are not designed to diagnose psychological or medical conditions, assign personality types, or make employment evaluations.
• Usage and operational data. Standard technical and operational information such as device or browser type, app version, service events, diagnostic information, and security or support logs used to operate, troubleshoot, secure, and improve the service.

How we use your information

We use Information to provide and personalize Evolvio; transcribe permitted microphone segments; analyze the authenticated user's observable workplace behavior; generate live cues, post-session observations, reports, longitudinal patterns, practices, and other user-facing outputs; maintain and update your behavioral record; incorporate corrections and preferences; operate, secure, troubleshoot, develop, and improve the service; communicate with you about your account and service changes; prevent fraud, illegal activity, or abuse; and meet legal obligations. We may also process Information with your consent for a specific purpose disclosed at the time. We may aggregate or de-identify Information so that it no longer identifies you and use that information for lawful product, security, and research purposes consistent with this Statement.

Service architecture. Vercel hosts the product's web interface. Render hosts Evolvio's canonical behavioral intelligence service. Evolvio may also use service providers for authentication, hosting, transcription, AI processing, communications, analytics, security, and support. These providers may process Information only as needed to provide and operate Evolvio, subject to the production configuration, applicable contracts or platform terms, and this Statement.

How behavioral analysis works

Evolvio uses AI-assisted behavioral analysis informed by research and applied frameworks from behavioral science, organizational behavior, communication, learning, negotiation, and behavior change. The service is designed to distinguish observed evidence from interpretation, use calibrated language when an impact or explanation is uncertain, and analyze the authenticated user rather than other meeting participants. Outputs are probabilistic and may be incomplete or inaccurate. Evolvio is not designed to diagnose psychological or medical conditions, assign personality types, or make clinical or employment assessments.

In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of our business, assets, or stock, We may share any collected information about you with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We may share such Information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.

You acknowledge and agree that any successor to, acquiror, affiliate entity, parent entity, or subsidiary entity of the Company (or its assets), any spin-off product lines into separate legal entities, and any consents to the assignment, license, or other transfer of intellectual property associated with the products and Services of the Company, will continue to have the right to use your Information in accordance with the terms of this Policy, without the need for additional consent by you.

What we do not do

• We do not access Zoom's meeting audio streams, video, screen sharing, participant lists, or separate per-participant media, and we do not use Zoom RTMS.
• We do not score, profile, or create behavioral records about other meeting participants. Their words, however they reach Evolvio, are context for coaching you only, and are discarded immediately after use.
• We do not provide your behavioral record to your employer or manager by default. You may deliberately choose to share selected Evolvio artifacts, links, or exported information.
• We do not use your behavioral record to train foundation AI models.
• Evolvio retains your derived behavioral record and the transcript of your own words — not a recording of the meeting. Raw audio is never retained, and other participants' words are never stored.
• We do not use the service to diagnose mental-health or psychological conditions, assign personality types, or generate employment-suitability scores.
• Evolvio does not make hiring, promotion, compensation, termination, or other employment decisions about you or anyone else.

Retention and deletion

Raw microphone audio is not retained. The transcript of your own words is kept for one year as part of your record. Other participants' words are used only in the moment, as context for coaching you, and are discarded immediately — they are never stored. Derived behavioral features, coaching prompts, and reports are retained for up to one year, and longitudinal patterns and your corrections for up to two years, after which they are deleted automatically. When you delete your account, your behavioral record and all associated meeting data are deleted immediately; we retain a minimal record that your account existed and that deletion occurred, in order to demonstrate that we honored your request. Deleted data may persist in encrypted backups for up to 30 days before being purged. Cancelling a subscription does not delete your record: coaching and new processing stop, but your dashboard and everything already in your record remain available until you delete your account. Cancelling a subscription and deleting your account are two separate actions. If a cancelled account remains inactive for twelve (12) months, we may delete the account and its data after first notifying you by email.

Sharing

We disclose Information to service providers and subprocessors that help us operate the service. Currently: Vercel (web interface hosting), Render (application hosting and the Evolvio intelligence service), OpenAI (transcription and AI processing), Google (sign-in), and GetLaunchList (waitlist), together with providers of email communications. When paid subscriptions launch, Stripe will process payments. These providers may process Information only as needed to provide and operate Evolvio, subject to contracts and this Statement. None of them may use your information to train AI models. We do not provide your behavioral record to employers, advertisers, or data brokers. Evolvio does not sell or share personal information as those terms are defined under applicable privacy law, including the California Privacy Rights Act, and has not done so in the preceding twelve (12) months.

Security

We use technical and organizational safeguards designed to protect Information, including access controls and encryption where appropriate. No method of transmission or storage is completely secure.

During the beta, a small number of named Evolvio staff may view a user's readouts solely to diagnose and fix errors. That access is logged. No one else at Evolvio has routine access to your record.

Your rights

Depending on where you live, you may have rights to access, correct, delete, or port your Information. Evolvio is designed to support user control of the behavioral record. You may request export or deletion through available product controls or by contacting privacy@evolvio.co.

Children's Privacy

The Beta is intended only for adults age 18 or older. We do not knowingly permit children under 18 to create Beta accounts. If you believe a person under 18 has provided personal information through the Beta, contact us so we can investigate and take appropriate action.

Your Rights as a Resident of California

The California Privacy Rights Act (CPRA) grants certain rights to California residents (subject to certain exceptions) with respect to their Information. If Our processing of your Information is subject to the CPRA, you are entitled to the following rights:

To exercise your right to know, access, or delete your Information, you may submit a request to the above-mentioned support email. Please include “CPRA Access/Deletion Request” in the subject line of your email. For requests submitted via email, you must provide Us with sufficient information that allows us to reasonably verify you are the person about whom We collected the Information and describe your request with sufficient detail to allow Us to properly evaluate and respond to it. If We are not able to verify your identity for access and deletion requests with the information provided, We may ask you for additional pieces of information. To exercise your right to know/access, you may submit a request by emailing the above-mentioned support email. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your Information. If you are an authorized agent making a request on behalf of another individual, you must provide Us with signed documentation that you are authorized to act on behalf of that individual.

Your Rights as a Resident of Nevada

If you are a User in the State of Nevada, you may request to opt-out of the current or future sale of your Information. We do not currently sell any of your Information under Nevada law, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales by contacting Us at the above-mentioned support email. Please include “Opt-Out Request Under Nevada Law” in the subject line of your message.

European Privacy; GDPR Compliance

International Transfer of Data

If personal information is transferred from the EEA, United Kingdom, or Switzerland to a country that has not been recognized as providing an adequate level of protection, Evolvio will rely on an appropriate lawful transfer mechanism where required, such as an applicable adequacy decision, Standard Contractual Clauses, or another lawful mechanism. Where a provider or organization validly participates in an applicable data-privacy framework, that framework may also be used as permitted by law.

Transferring Your Information Outside the European Economic Area

Service providers may process information in the United States or other countries. Where applicable law requires transfer safeguards, Evolvio will use appropriate lawful transfer mechanisms and additional measures where required.

Legal Basis for Processing Information from EEA Residents

Whenever We require your consent for the processing of your Information, such processing will be justified pursuant to Article 6(1) lit. (a) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). If the processing of your Information is necessary for the performance of a contract between you and Us, or for taking any pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b). Where the processing is necessary for Us to comply with a legal obligation, we will process your information on the basis of GDPR Article 6(1) lit. (c), and where the processing is necessary for the purposes of our legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f).

Cross-Border Transfer.

We may share Information with our affiliates’ employees, consultants, and third-party service providers outside your country, but only for purposes of performing the Services for which you provided your Information, even to countries that might not offer a level of protection for your Information that is equivalent to the one offered in your country of residence. We will obtain your express consent, however, before using your Information for any purposes other than performing the Services for which you provided the Information or for any of the uses described in this Privacy Policy.

Choice/Opt-Out.

If you no longer wish to receive additional information or promotional materials from the Company, you may opt-out of receiving these communications by sending an email with the word ‘unsubscribe’ in the subject line to the above-mentioned support email or using the opt-out mechanism described in the relevant email.

Changes

We may update this Statement from time to time. If a change materially affects how we handle your Information, we will provide notice as required by applicable law and update the effective date above.