Privacy Policy

How Evzino collects, uses, stores, and protects personal information appears here.

Effective date	24 September 2026
Version	1.0
Provider	Evergreen Venture Partners Co., Ltd, trading as Evzino

This Privacy Policy explains how Evergreen Venture Partners Co., Ltd, trading as Evzino ("Evzino", "we", "us" or "our"), collects, uses, stores, shares and otherwise processes personal information when you use Evzino, Evo, our website and applications, Evzino through WhatsApp, human advisory or coaching services, and other services that link to this Privacy Policy.

We take the privacy of health, wellness and behavioral information particularly seriously. This Privacy Policy should be read together with our Terms & Conditions, Health & Wellness Data Consent, and any additional privacy notice applicable in your jurisdiction.

1. Who is responsible for your information

The organization responsible for the personal information described in this Policy is Evergreen Venture Partners Co., Ltd, trading as Evzino.

Registered address: [REGISTERED ADDRESS]

Privacy contact: [PRIVACY EMAIL]

Data Protection Officer, where applicable: [DPO CONTACT]

EU representative, where applicable: [EU REPRESENTATIVE]

UK representative, where applicable: [UK REPRESENTATIVE]

2. What Evzino does

Evzino is a personalized nutrition, fitness, wellness and coaching service. Evo is Evzino's AI wellness coach.

Evzino combines information you provide with information generated through your use of the service to make your experience increasingly personalized. This may include learning from nutrition, meals, activity, workouts, routines, preferences, constraints, responses, progress, interactions with Evo, feedback or corrections, and advisor interactions.

3. Information we collect

3.1 Account and identity information

name;
email address;
account ID and authentication identifiers;
login information;
Google or other authentication identifiers where used;
timezone, language, country or region where relevant.

3.2 Profile and physiological information

date of birth and age;
sex used for physiological calculations;
height;
current weight and goal weight;
activity level and fitness status;
health or wellness goals.

3.3 Nutrition information

meal photographs and meal descriptions;
identified food items;
portion, calorie and macronutrient estimates;
meal timing, snacks and drinks;
hydration;
dietary patterns and restrictions;
allergies and medically relevant food avoidances;
food preferences.

3.4 Fitness and activity information

workouts and movement;
exercise type, duration and frequency;
workout timing;
training environment;
equipment information;
fitness preferences;
activity estimates.

3.5 Goals, preferences and routine information

primary goals and milestones;
preferred first focus;
routine constraints;
meal environment;
schedule information;
communication preferences;
barriers you tell us about;
six-month or other longer-term objectives.

3.6 WhatsApp and communication information

messages;
photographs;
replies and button selections;
timestamps;
interaction history;
communication preferences.

WhatsApp and other third-party platforms may independently process information according to their own terms and privacy policies.

3.7 Reminder and task information

task text;
requested date/time;
recurrence;
completion and snooze activity.

Because reminders can contain free text, you should avoid including sensitive information that is unnecessary for the reminder.

3.8 Advisor and coach information

advisor communications;
appointments;
advisor notes;
recommendations and corrections;
coaching outcomes;
service history.

Access is limited according to role and legitimate service requirements.

3.9 AI-generated and inferred information

Evzino's personalization system may create information from other information we hold. We attempt to distinguish what we know from what the system infers. An AI inference is not automatically treated as fact.

observations;
behavioral features;
routine patterns;
inferred preferences;
hypotheses;
confidence scores;
predictions;
personalized recommendations;
intervention history;
response patterns;
information about which forms of support appear more or less effective.

3.10 Subscription and transaction information

selected plan;
subscription status;
transaction amount;
billing dates;
trial or free-period status;
cancellation status;
failed-payment status;
payment processor reference;
limited payment-method information.

Full card details may be handled directly by our payment processor rather than Evzino.

3.11 Technical information

IP address;
browser type;
operating system;
device and application version;
session identifiers;
timestamps;
diagnostic logs;
security information;
crash and error information.

3.12 Analytics and acquisition information

referral source;
UTM parameters;
advertising campaign identifiers;
click identifiers;
landing-page activity;
onboarding activity;
experiment assignment;
conversion events;
general product analytics.

4. Where information comes from

We may obtain information directly from you when you complete onboarding, send Evo a message, upload a meal, log an activity, answer a question, create a reminder, correct Evo or purchase a subscription.

We may obtain information from your use of Evzino, such as interaction timing, meals logged, reminder responses, feature usage and subscription events.

We may obtain information from authorized service providers such as authentication providers, payment processors, messaging providers and connected services you choose to authorize.

We may also generate calculations, observations, patterns and inferences through Evzino's AI and analytical systems.

5. How we use information

5.1 Provide the service

create and operate your account;
authenticate you;
process your inputs;
log meals and activities;
calculate estimates;
generate Evo Briefs;
provide reminders;
deliver purchased services.

5.2 Personalize Evzino

understand your goals;
adapt recommendations;
remember preferences;
identify routines;
select relevant questions;
tailor messages;
identify potentially useful interventions;
learn which interventions appear useful for you.

5.3 Generate AI outputs

summarize;
estimate;
classify;
identify patterns;
generate recommendations;
provide conversational responses.

5.4 Human support

enable advisors or coaches to review relevant information;
provide coaching;
schedule services;
record relevant decisions or recommendations.

5.5 Operate and secure Evzino

fraud prevention;
account security;
troubleshooting and debugging;
availability monitoring;
abuse prevention;
incident investigation.

5.6 Improve Evzino

measure product performance;
identify errors;
evaluate whether recommendations work;
improve product design;
improve personalization quality.

Where reasonably possible and appropriate, broader analytical learning should use aggregated or de-identified information. Use of identifiable sensitive information for broader model-development purposes is subject to applicable law and any additional consent required.

5.7 Communicate with you

service communications;
reminders;
Evo Brief notifications;
billing notices;
security communications;
support.

Marketing communications are handled according to applicable law and your preferences.

5.8 Process subscriptions and payments

establish a subscription;
process payment;
manage renewals and cancellations;
handle failed payments and refunds;
provide billing support.

5.9 Comply with law

respond to lawful legal process;
maintain required records;
enforce legal rights;
meet regulatory obligations.

Where European Economic Area or UK data-protection law applies, we rely on an appropriate legal basis for each purpose.

Depending on the processing, this may include contract where processing is necessary to provide requested services; consent for health or other special-category data where required, optional marketing, non-essential cookies or other consent-based processing; legitimate interests where legally permitted for security, reliability and certain internal analytics; and legal obligation where processing is necessary to comply with law.

Where we rely on consent, you may withdraw it. Where health information is treated as special-category data and explicit consent is the relevant condition, we use the separate Health & Wellness Data Consent or another appropriate mechanism.

We do not rely on legitimate interests where your rights and interests override those interests. A separate condition is required where special-category information is involved.

7. Health and wellness information

Health and wellness information receives additional protections. Depending on jurisdiction, this may include weight, physical measurements, allergies, nutrition information, exercise information, health-related restrictions, and AI inferences that reveal health status.

Where required, we obtain separate consent before collecting or processing these categories. We do not treat your general acceptance of Evzino's Terms as an unlimited authorization to process sensitive health information.

8. Evo, AI and profiling

Evo uses AI to provide personalized experiences. Personalization can include receiving information from you, recording relevant behavior or events, distinguishing factual information from interpretations, identifying patterns, generating hypotheses or predictions, selecting appropriate recommendations or actions, observing how you respond, and refining future personalization.

We may maintain different kinds of information including recent working context, specific historical experiences, longer-term personalized understanding, structured profile information and behavioral patterns.

We aim to preserve the source and confidence of important inferences rather than treating every AI output as fact. You may ask us to correct important inaccurate information.

9. Automated decision-making

Evo automatically selects and generates many routine recommendations, reminders, summaries and personalized responses.

Evzino is not currently intended to use Evo to make decisions producing legal effects concerning you or similarly significant effects such as determining employment, credit, insurance, legal eligibility or access to essential public services.

If Evzino introduces materially different automated decision-making requiring additional rights or disclosures, we will provide them as required.

10. AI transparency

Unless it is otherwise obvious from context, Evzino will identify Evo as an AI system. Human advisors should not be misrepresented as AI, and AI interactions should not be misrepresented as human communications.

We may disclose information to service providers or processors that perform services for Evzino, including cloud hosting, database/storage, security, AI infrastructure, meal or image analysis, messaging, email, authentication, payments, analytics, customer support and scheduling.

We may disclose information to authorized Evzino employees and contractors whose work requires access, to advisors and coaches where your plan includes human support and the information is reasonably necessary, to professional advisers such as lawyers, accountants, auditors and insurers, to authorities where disclosure is required by valid law or necessary to protect legal rights, and in connection with a legitimate corporate transaction subject to applicable law.

Service providers are required to process information according to applicable contractual and legal obligations.

12. Advertising and sensitive information

Evzino may use non-sensitive acquisition and campaign information to understand advertising performance.

Evzino does not use this Privacy Policy or the Health & Wellness Data Consent as authorization to send detailed health/wellness profile information or AI-derived health insights to advertising platforms for advertising optimization or targeting.

Examples of information that should not be provided to advertising platforms for that purpose include current weight, goal weight, allergies, meal details, health restrictions, detailed nutrition profiles, detailed workout profiles, and AI-generated health or behavioral hypotheses.

Where applicable law provides rights concerning targeted advertising, sale or sharing of personal information, those rights will be respected.

13. Sale of health data

Acceptance of this Privacy Policy or the Health & Wellness Data Consent does not authorize the sale of consumer health data.

If Evzino were ever to engage in an activity legally classified as a sale of protected consumer health data requiring specific authorization, we would obtain the legally required separate authorization before doing so.

14. Third-party platforms

When you use Evzino through WhatsApp, Google authentication, a payment provider or another third-party service, that provider may independently process information. Their processing is governed by their own privacy policies.

Evzino remains responsible for its own processing and for applicable obligations regarding processors acting on its behalf.

15. Cookies and similar technologies

Our websites may use strictly necessary technologies for authentication, security, account operation, fraud prevention and essential functionality; analytics technologies to understand product and website usage; and advertising technologies, where permitted, for advertising measurement, attribution or marketing.

Where law requires consent before placing non-essential cookies or trackers, we will request that consent. You may manage applicable preferences using our cookie controls.

16. Marketing communications

We may send marketing communications where you have consented or another legal basis permits them. You may unsubscribe using an unsubscribe link, messaging preference controls or instructions provided in the relevant communication.

Service messages necessary to operate an account or subscription may still be sent.

17. International transfers

Evzino and its providers may process information in countries other than the country where you live.

Where applicable law requires transfer safeguards, we will use an appropriate mechanism such as adequacy decisions, contractual safeguards, Standard Contractual Clauses, UK transfer mechanisms, or another legally recognized safeguard.

Additional transfer information may be requested from [PRIVACY EMAIL].

18. Retention

We do not intend to retain identifiable personal information indefinitely simply because storage is technically possible. Retention depends on account status, purpose, sensitivity, user expectations, legal requirements, security needs, disputes and accounting obligations.

Account information is generally retained while the account is active and for an appropriate period afterward where necessary. Health and personalization information is retained while required to provide the personalized service and thereafter only where a lawful purpose remains. Raw logs and events may be retained for security, audit, debugging and personalization, subject to applicable retention limits and deletion rights. Transaction records may be retained for legally required accounting, tax, chargeback and financial-record purposes. Consent records may be retained to demonstrate the consent provided and withdrawals made.

When information is required to be deleted, we take reasonable measures to remove, anonymize or otherwise render it no longer personal, subject to lawful retention exceptions and backup-management processes. A formal retention schedule should govern these periods internally.

19. Security

We use administrative, technical and organizational safeguards designed to protect personal information. These should include, as appropriate, access controls, least-privilege permissions, authentication controls, encryption in transit, appropriate encryption at rest, logging and monitoring, vendor controls, backup and recovery measures, and security incident procedures.

No system can guarantee absolute security.

20. Data breaches

If a security incident involving personal information occurs, we will investigate, contain and remediate it as appropriate, assess legal notification requirements, and notify affected individuals and regulators where required by applicable law.

21. Your rights

Privacy rights differ depending on jurisdiction. Where applicable, you may have the right to access personal information, correct inaccurate information, request deletion, obtain portable information, withdraw consent, request restriction, object to certain processing, opt out of targeted advertising, sale, sharing or specified automated processing, appeal certain privacy decisions, and complain to a privacy or data-protection authority.

22. Health-data rights

Depending on your jurisdiction, additional rights may apply to health-related information, including rights to confirm whether Evzino collects health information, access it, obtain information about certain recipients, withdraw consent, request deletion, and appeal refusal of a request.

Requests may be submitted to [PRIVACY EMAIL] or through applicable account controls. Where applicable law requires a separate consumer health data privacy notice, that notice will supplement this Policy.

23. EEA rights

If GDPR applies, you may have rights including access, rectification, erasure, restriction, portability, objection, withdrawal of consent and rights relating to certain automated decisions. You may complain to the competent supervisory authority.

24. UK rights

If UK data-protection law applies, you may have corresponding UK rights and may lodge a complaint with the UK Information Commissioner's Office.

25. United States state privacy rights

Residents of certain U.S. states may have additional rights depending on whether the applicable law applies to Evzino. These may include access, correction, deletion, portability, opt-out rights, rights regarding sensitive information and appeal rights.

Where a state-specific notice is required, it will supplement this Privacy Policy.

26. Exercising your rights

You may submit a privacy request by email to [PRIVACY EMAIL] or through [PRIVACY REQUEST URL]. We may need to verify your identity before fulfilling certain requests.

You may use an authorized agent where applicable law permits. We will not unlawfully discriminate against you for exercising a privacy right.

27. Account deletion

You may request account deletion through Evzino account settings, where available, or by contacting [PRIVACY EMAIL].

Deletion requests will be processed in accordance with applicable law. Certain information may remain where retention is legally permitted or required, including financial records, fraud/security records, consent evidence and records necessary for legal claims.

Where applicable, deletion will be propagated to service providers required to delete the information.

28. Correcting Evo

Because Evzino uses personalization, corrections are especially important. If Evo incorrectly interprets information about you, you may correct Evo in conversation where supported, update relevant profile information, or contact us to correct important inaccurate information.

Corrections may update Evzino's current understanding without necessarily erasing the historical fact that an earlier inference was made where retaining that audit trail is lawful and appropriate.

You may withdraw your Health & Wellness Data Consent through available privacy controls or by contacting [PRIVACY EMAIL].

Withdrawal does not make prior lawful processing unlawful. It may prevent Evzino from providing features that require personalized health and wellness information.

30. Children and minors

Evzino is intended for adults aged 18 and over. We do not knowingly offer the Services to children.

If we learn that a person below the applicable minimum age has created an account or provided information contrary to our requirements, we will take appropriate steps consistent with applicable law. Parents or guardians who believe a minor has improperly provided information may contact [PRIVACY EMAIL].

31. Changes to this Privacy Policy

We may update this Policy when our Services change, our data practices change, laws change, or security or operational requirements change.

The "Last updated" date identifies the current version. Where required, we will provide notice of material changes or obtain new consent before materially changing a consent-based purpose.

32. Contact us

Evzino is operated by Evergreen Venture Partners Co., Ltd.