Privacy Policy

Last Modified: April 5, 2026

Scope of This Notice

Please read this privacy notice ("Notice") carefully to understand our policies and practices regarding your personal data and how we will treat it. This Notice applies to individuals who interact with ADAPTIVE EVOLUTION, LLC d/b/a Evolynt. Evolynt provides services to consumers ("you") on the sites and platforms on which it appears. This Notice explains how your personal data (which some jurisdictions may refer to as "personal information") is collected, used, and disclosed by Evolynt. Evolynt, and third parties acting on our behalf (collectively "Company", "We", "Us" "Our") on the sites and platforms on which this policy appears. It also tells you how you can access and update your personal data and make certain choices about how your personal data is used.

This Notice covers both our online and offline data collection activities where this policy is provided to you or is otherwise referenced. This includes personal data that We collect through our various channels such as websites, apps, third-party social networks, consumer affairs, points of sale, and events where this policy is provided to you. Please note that We might combine personal data from different sources (website, offline event). We also may combine data from third parties with data We already have.

In some instances, if you do not provide personal data to Us, We may not be able to provide you with certain goods and/or services. We will indicate to you when this is the case, for example, by stating so on our registration forms.

Personal Data That We Collect About You

Evolynt operates with a three-tier user model that affects how personal data is collected and processed. Evolynt provides the platform infrastructure and is the data controller for Creator data and data processor for Client data. Creators are the direct customers of Evolynt and are the data controllers of Client data. Clients are the individuals who purchase products from Creators through the Evolynt platform. The Client's primary contractual and privacy relationship with the Creator. Please contact the Creator directly to exercise your privacy rights.

As a Creator on Evolynt, We will collect:

Account Login Data: Any data that is required to give you access to your specific account profile. Examples include your login ID/email address, screen name, password in unrecoverable form, and/or security question and answer.

Payment Information: This information is collected via Stripe and includes any data that We need in order to fulfill an order, or that you use to make a purchase, such as your debit or credit card details (cardholder name, card number, expiration date, etc.) or other forms of payment (if such are made available). However, We do not store card numbers.

Business Data: Any data that We need to create your online business platform. This may include the business name, specific branding settings, and other information.

Content: Any data related to Content you created on the platform, including, courses, community posts, email templates, funnel pages, etc.

API Data: Any data related to data collected by and for third-party connected services. This data is used by all Evolynt frontend applications, and thus is subject to the same privacy protections as the Evolynt UI. Further, the Evolynt platform will log all API requests, including the timestamp, IP address, the user ID, and the endpoint.

As a Client, only limited data will be processed by Evolynt. The Creator from which you solicit services will ultimately control any remaining data that is collected. Evolynt will collect:

Contact Data: Any data you provide to Us that would allow Us to contact you, such as your name, postal address, e-mail address, social network details, or phone number.

Device Data: Data about the computer system or other technological device that you use to access one of our websites or apps, such as the Internet protocol (IP) address used to connect your computer or device to the Internet and other online identifiers. If you access one of the sites or apps subject to this policy via a mobile device such as a smartphone, the collected data will also include, where permitted, your phone's unique device ID, advertising ID, and other similar mobile device data.

Demographic Data: Creators may collect demographic or behavioral data from Clients through custom form fields on the Evolynt platform. Evolynt does not collect demographic data such as gender, geographic location, or company data as standard fields. In some cases, this could include data that you give Us about someone else. For example, if you provide another individual or company's email address for a referral.

Third-Party Payment Service Data: Any data that you share publicly on a third-party payment service or data that is part of your profile on the payment service provider (such as Stripe) and that you allow the third-party social network to share with Us. Examples include your basic account data (e.g., name, email address, credit card information, banking and account information, etc.) and any other additional data or activities that you permit the third-party payment provider to share. We do not take custody of or retain or hold any of your financial or banking information.

Site Usage Data: This includes information about how you use Evolynt, its community, and other Creator-generated courses and subscriptions. For example, as you navigate through and interact with our websites/apps or emails, We use automatic data collection technologies to collect certain data about your device(s) and your actions. This includes data such as which links you click on, which pages or content you view and for how long, and other similar data and statistics about your interactions, such as content response times, download errors, and length of visits to certain pages, as well as operating system type and web browser type and version. We may also visually record your interactions with our website, including your mouse clicks, movement, scrolling, and navigation through our website.

Feedback Data: Any information that you share with Us about your experience of using our products and services. This includes any content that you create and then share with Us on third-party social networks or one of our websites or apps. Examples include photos, videos, personal stories, or other similar media or content. This may also include information you provide during your conversations with consumer affairs.

Geolocation Data: We may collect information about your approximate geographic location based on your IP address.

Inferences: We may draw inferences from the data We collect from and about you to create a profile reflecting your preferences, characteristics, and behavior. Such inferences are generated for platform optimization purposes only and shall not be construed as definitive assessments of any individual. Evolynt makes no representations or warranties as to the accuracy of any inference drawn from your data.

Data Controller and Processor Roles

The following summarizes the data controller and data processor relationships on the Evolynt platform:

Creator Data:

Data Controller: Evolynt
Data Processor: Evolynt

Client Data:

Data Controller: Creator
Data Processor: Evolynt

How We Collect Personal Data About You

We collect personal data directly from you, when you choose to provide it to us. For example, We collect data when you place an order with us. We collect data when you register on one of our websites or apps. We collect data when you sign up for our emails. We collect data from digital registrations and similar forms. If We run promotions or events in the future, We may collect data through those channels as well. We collect data if you fill out a request or use other tools on our websites or apps. We also collect data if you contact Us through our websites or apps, via email, or through social media.

We collect data from you passively. For example, We use tracking tools like browser cookies and web beacons. We do this in our digital platforms and in emails that We send to you. We collect data about you over time when you use this website. This includes usage and browser data. We may have service providers or other third parties collect data this way. We also collect data from our mobile apps.

We get data about you from other sources. For example, our affiliates and business partners may give Us data about you. Social media platforms may also give Us data about you. We may get data about your interactions with our ads on third-party sites.

Personal Data of Children

We do not knowingly solicit or collect personal data from children below the age of 18. Our Terms of Use require all Creators to be at least 18 years old. If you are a parent or legal guardian and think that your child under 18 has given Us data, you can contact Us by email as provided below under the section titled CONTACT.

Creators who use the Evolynt platform to create products or services that may be directed at children under 13 are solely responsible for ensuring compliance with the Children's Online Privacy Protection Act (COPPA) and any other applicable laws regarding the collection of data from minors. Creators who collect personal data from individuals they know or have reason to know are under 18 shall indemnify, defend, and hold harmless Evolynt and its officers, directors, employees, and agents from and against any claims, penalties, damages, or liabilities arising from such collection or processing.

Uses for Your Personal Data

The following paragraphs describe the various purposes for which We collect and use your personal data, and the different types of personal data that are collected for each purpose. Please note that not all of the uses below will be relevant to every individual.

Consumer service: We use your personal data for consumer service purposes. Consumer service activities could be responding to your inquiries or complaints.

Marketing and promotions: We may use your personal data to provide you with information about goods or services (e.g., marketing communications or campaigns or promotions). This can be done via email, ads, and SMS to the extent permitted by applicable laws. If We run contests or promotions in the future, some may be run on third-party websites and/or social networks, and official rules or details will be posted with each contest/promotion.

Personalization: With your consent (where required), We may use your personal data to personalize your experience with us. For example, we may use these categories of personal information: (i) to analyze your preferences and habits; (ii) to anticipate your needs based on our analysis of your profile; (iii) to improve and personalize your experience on our websites and apps; (iv) to ensure that content from our websites/apps is optimized for you and for your computer or device; (v) to provide you with targeted advertising and content, and (vi) to allow you to participate in interactive features, when you choose to do so. For example, We remember your login ID/email address or screen name so that you can quickly login the next time you visit our site. Based on this type of information, and with your consent (where required), We also show you specific content or promotions that are tailored to your interests.

Order fulfillment: We use your personal data to process and service your orders, inform you about the status of your orders, correct addresses, and conduct identity verification and other fraud detection activities. This involves the use of certain personal data and payment information.

Targeted advertising: We may use your personal data to deliver targeted advertising to you through third-party advertising platforms such as Google Ads or Meta. This may include retargeting campaigns based on your interactions with our platform. You can learn more about how to opt out of targeted advertising by reviewing the privacy settings of the relevant advertising platforms.

AI-powered features: We may use your personal data in connection with AI-powered features on our platform. When you use these features, your inputs may be sent to third-party AI service providers (such as OpenAI or Anthropic) for processing. These providers process data on our behalf and in accordance with their respective privacy policies and our data processing agreements. We will clearly disclose when a feature is AI-powered at the point of use.

Other general purposes (e.g. internal or market research, analytics, security): In accordance with applicable laws, We use your personal data for other general business purposes, such as maintaining your account, conducting internal or market research, and measuring the effectiveness of advertising campaigns. This also includes improving our websites and services. We also use your personal data for management and operation of our communications, IT, and security systems. We may also use personal data for product development, de-identification and aggregation, and training of internal models used to improve the platform. Additionally, We may use personal data for any other lawful business purpose consistent with the context in which it was collected and applicable law.

Disclosure of Your Personal Data

The following paragraphs describe how and to whom We disclose your data.

Service providers. We share data with our service providers. These are external companies that We use to help Us run our business (e.g., service or order fulfilment, payment processing, fraud detection and identity verification, website operation, market research companies, support services, promotions, website development, data analysis, CRC, etc.). For individuals in California this information may have been shared in the last 12 months.

Creators. If you are a Client, We share your personal data with the Creator from whom you purchased products or services. The Creator is the data controller for Client data, and your primary privacy relationship is with the Creator. Creators may use your data in accordance with their own privacy practices, and Evolynt is not responsible for the Creator's use of your data beyond what is processed through the Evolynt platform.

Sharing personal data for legal reasons or due to merger/acquisition. In the event that ADAPTIVE EVOLUTION LLC or its assets are acquired by, or merged with, another company including through bankruptcy, We will share your personal data with any of our legal successors. We will also disclose your personal data to third parties (i) when required by applicable law; (ii) in response to legal proceedings; (iii) in response to a request from a competent law enforcement agency; (iv) to protect our rights, privacy, safety, or property, or the public; or (v) to enforce the terms of any agreement or the terms of our website. Evolynt expressly reserves the right to assign this Notice and any data rights hereunder without your consent in connection with any merger, acquisition, or sale of assets. We are not responsible for the data practices of any successor entity following such a transfer. We will endeavor to notify you of a transfer via email or a prominent notice on our platform.

Data Protection and Retention

We implement the following security measures to protect your personal data: encryption in transit (TLS/HTTPS) and at rest; role-based access controls; bcrypt password hashing; PCI compliance via Stripe for payment processing; multi-tenant data isolation between Creator workspaces; API key hashing; and active monitoring for unauthorized access. We use these and other security measures as required by applicable law. The transmission of information via the Internet is, unfortunately, not completely secure and despite our efforts to protect your personal data, We cannot guarantee the security of the data during transmission through our websites/apps. It is important that you also play a role in keeping your personal data safe and secure. When signing up for an online account, please be sure to choose an account password that would be difficult for others to guess and never reveal your password to anyone else. You are responsible for keeping this password confidential and for any use of your account. If you use a shared or public computer, never choose to have your login ID/email address or password remembered and make sure to log out of your account every time you leave the computer. You should also make use of any privacy settings or controls We provide you in our websites/apps.

To the maximum extent permitted by applicable law, Evolynt shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising out of or related to any unauthorized access to or alteration of your personal data. In no event shall Evolynt's total aggregate liability arising out of or related to this Notice exceed the lessor of: (a) the fees paid by you in the six (6) months preceding the incident giving rise to the claim, or (b) one hundred dollars ($100.00).

Retention of personal data. We keep personal data as long as it is necessary or relevant for the practices described in this Notice. We also keep personal data as otherwise required by law. However, credit card data and plain text passwords are never stored on the Evolynt platform. Specific retention schedules include: Creator account data is retained for the duration of the active account plus three (3) years following closure; Client transaction records are retained for three (3) years as required for tax, financial, and legal compliance. After applicable retention periods, data will be deleted or anonymized. We reserve the right to retain aggregated, de-identified data indefinitely.

Your Choices About How We Use and Disclose Your Personal Data

We strive to provide you with choices regarding the personal data that you provide to Us. The following mechanisms give you the following control over your personal data:

Advertising, marketing, and promotions. You can opt out of marketing emails by following the instructions provided in each such communication. Please note that even if you opt out from receiving marketing communications, you will still receive transactional communications from Us, such as order or other transaction confirmations, notifications about your account activities (e.g., account confirmations, password changes, confirmation of orders and submission, etc.), and other important non-marketing-related announcements.

Cookies, tracking tools, and targeted advertising. To learn how to manage how We and our vendors use cookies and other tracking tools, please refer to our Cookies Policy. We do not currently respond to Do Not Track (DNT) signals sent by web browsers. There is no industry consensus on how to interpret DNT signals, and We will continue to monitor developments in this area.

Third-Party Websites and Services

We may link to third-party websites or apps, including social media platforms. Those third-parties include, but are not limited to:

Stripe
Mailgun
SendGrid
Twilio
Zoom
Google Calendar
Microsoft Outlook
Slack
OpenAI
Anthropic
Amazon Web Services

We retain the right to expand our use of third-party websites or apps as the Evolynt platform continues to grow. This Notice does not apply to, and We are not responsible for, the privacy practices of these third-party websites or apps. Please read their privacy policies carefully. Evolynt is not responsible or liable for the data practices, security measures, or privacy policies of any third-party services listed herein integrated with the platform. Your use of these third-party services is at your own risk and subject to their respective terms and policies. The list of third-party services may be updated at any time without prior notice to you.

Your California Privacy Rights

California residents may also take advantage of the following rights:

Access. You may request, up to two times each year, that We disclose to you the personal data (i.e., "personal information," as the California Consumer Privacy Act ("CCPA") defines the term) that We collect, use, and disclose about you. In response to a verified request, We will provide (1) the categories and specific pieces of personal data that we have collected, (2) the categories of sources from which that data is collected, (3) the business or commercial purpose for collecting it, (4) the categories of third parties with whom We shared that data, and (5) the business or commercial purpose for sharing that data.

Delete. You may request that We delete any personal data that We have collected from or about you. Note that there are some reasons we will not be able to fully address your request, such as if We need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, to use the data for solely internal purposes, or to comply with a legal obligation.

To take advantage of any of these rights, or if you have any questions or concerns, please contact Us by email or our contact page on our website. For verification purposes, We may request your first and last name, email address and another email address as well as devices you may have used when registering with Us, including your phone number or any other phone number used at registration and a physical mailing address. If you are submitting on someone else's behalf we may ask for additional verification. This may include providing a signed letter verifying your right to make this request. We will not discriminate against you in response to your exercise of your privacy rights under the CCPA. We will respond to your access or deletion request within 45 days of receipt of your request, after proper verification, unless we need additional time, in which case we will let you know.

Sale of Information. In the preceding twelve months, We have not sold personal information as defined by the California Consumer Privacy Act. We do not disclose your personal information to third parties for the third parties' direct marketing purposes. While certain data sharing activities described in this Notice (such as sharing data with advertising platforms) could potentially be construed as a "sale" under California's broad definition, We do not sell personal information in the traditional sense. You may contact Us at privacy@evolynt.com to exercise your rights under the CCPA. We do not sell information of Californians under 16.

Your GDPR Privacy Rights

If you are located in the European Economic Area or the United Kingdom, you have the right to be informed about how we use your personal data and to request access to the personal data we hold about you. You also have the right to request correction of inaccurate data, request deletion of your data in certain circumstances, and request restriction of processing where applicable.

You may object to our processing of your personal data for direct marketing at any time and, where processing is based on legitimate interests, you may object if you believe your rights outweigh our interests. Where processing is based on your consent, you may withdraw that consent at any time. You also have the right to receive the personal data you provided to us in a structured, commonly used, machine-readable format and to have that data transmitted to another controller where technically feasible. Where Evolynt relies on legitimate interests as the lawful basis for processing personal data, those interests include: platform security, fraud prevention, product and service improvement, and direct marketing to existing customers. Objections to processing on legitimate interest grounds must be supported by specific reasons relating to your particular situation; general or blanket objections will not be honored. Withdrawal of consent will not affect the lawfulness of processing conduct prior to withdrawal.

You have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects, except where permitted by law. You also have the right to lodge a complaint with your local data protection authority, including the UK Information Commissioner's Office.

Information may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above (see above: Disclosure of Your Personal Data).

Some of these third parties may be based outside the EEA. To deliver services to you, it is sometimes necessary for us to share your personal information outside the EEA, e.g.:

With our offices outside the EEA;
With your and our service providers located outside the EEA;
If you are based outside the EEA; or
Where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection law.

Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses refer to the European Commission's website, where the Standard Contractual Clauses are publicly available: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.

We hope that We can resolve any query or concern you raise about our use of your information. The GDPR also gives you right to lodge a complaint with a supervisory authority, in the European Union (or EEA) state where you work, normally live, or where any alleged infringement of data protection laws occurred. The supervisory authority's for EEA countries can be found publicly available at: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

Exercise Your Rights

If you would like to exercise any of your rights as described in this Privacy Policy, please contact us at privacy@evolynt.com.

If you choose to contact us directly, you will need to provide us with:

Enough information to identify you (e.g., your full name, address and customer or matter reference number);
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification. Evolynt further reserves the right to deny requests that cannot be adequately verified, that are manifestly unfounded, excessive, or repetitive, or that would adversely affect the rights and freedoms of others. We may charge a reasonable administrative fee for manifestly unfounded or excess requests as permitted by applicable law.

Changes to This Notice

If We change the way We handle your personal data, We will update this Notice. We reserve the right to make changes to our practices and this Notice at any time as permitted by law. You can check back to see if there have been any updates or changes to our Notice. Changes will be effective upon posting to our website or platform, and your continued use of the Evolynt platform after the posting of any revised Notice constitutes your acceptance of such changes. We are not obligated to provide individualized notice of any changes to this Notice unless required by applicable law.

Contact

To contact us about this Notice and/or our privacy practices, please contact Us at privacy@evolynt.com.