Evolution Global Inc
Last Updated: March 2026
This Privacy Policy (“Policy”) governs how Evolution Global Inc. ("Evolution," "we," "us," or "our") collects, processes, stores, and discloses personal information in connection with the use of our website, mobile application, and all associated services (collectively, the "Services"). By accessing or using our Services, you acknowledge that you have read and agree to this Policy, which is incorporated by reference into our Terms of Service. This Policy applies to all users globally, with particular application to individuals accessing our Services from Nigeria and other emerging markets. Where jurisdiction-specific obligations apply, we will identify them expressly.
1.1 Information You Provide
When you register for or use an Evolution account, we collect personal information you voluntarily provide, including:
• Full legal name and date of birth
• Government-issued identification (e.g., National Identification Number (NIN), International Passport, Voter's Card)
• Bank Verification Number (BVN), where applicable • Residential and mailing address • Email address and phone number
• Occupation, source of funds, and business information
• Bank account details and payment information
• Any additional documentation required for Know Your Customer (KYC) or Anti-Money Laundering (AML) compliance
1.2 Information We Collect Automatically
When you interact with our Services, we automatically collect:
• Device and Technical Data: ", "Device type, operating system, browser type, unique device identifiers, and IP address.
• Usage Data: ", "Features accessed, transaction history, session duration, timestamps, and navigation patterns.
• Financial Transaction Data: ", "Payment details, amounts, counterparties, rails used (ACH, Fedwire, SEPA, blockchain), and settlement records.
• Location Data: ", "Approximate location derived from IP address or, where permitted, device GPS.
1.3 Information from Third Parties
We may receive personal information about you from third-party identity verification providers, financial institutions, fraud detection services, regulatory databases, and publicly available sources for the purposes of verifying your identity and assessing risk.
We process your personal information on the following lawful bases and for the following purposes:
• Account Creation and Service Delivery: ", "To register your account, verify your identity, provision virtual USD and EUR accounts, virtual Naira accounts, process inbound payments via ACH, Fedwire, SEPA, and stablecoin rails, and maintain your unified USD balance.
• Compliance with Legal Obligations: ", "To satisfy AML, Counter-Terrorism Financing (CTF), KYC, sanctions screening, and reporting obligations under applicable Nigerian, U.S., EU, and international financial regulations.
• Fraud Prevention and Security: ", "To detect, investigate, and prevent unauthorized transactions, account compromise, and other fraudulent or illegal activity.
• Product Improvement: ", "To analyze usage patterns, conduct internal research, troubleshoot technical issues, and develop new features—including the forthcoming virtual dollar card.
• Communications: ", "To send transaction notifications, account alerts, security notices, and, where you have consented, marketing communications.
• Legal Claims: ", "To establish, exercise, or defend legal rights, and to comply with judicial processes and regulatory inquiries.
Evolution does not sell your personal information. We share your data only in the following limited circumstances:
• Banking and Payment Partners: ", "With licensed banking partners, payment processors, correspondent banks, and stablecoin infrastructure providers necessary to execute your transactions.
• Identity Verification Providers: ", "With third-party KYC/AML vendors to verify your identity and screen against sanctions and watchlists.
• Regulatory Authorities: With the U.S. Financial Crimes Enforcement Network (FinCEN), OFAC, the Central Bank of Nigeria (CBN), the Nigerian Financial Intelligence Unit (NFIU), and other applicable regulators as required by law.
• Legal Process: ", "In response to valid subpoenas, court orders, or governmental requests.
• Business Transfers: ", "In connection with a merger, acquisition, or sale of assets, subject to prior notice to affected users.
• With Your Consent: ", "For any purpose to which you expressly consent
All third-party service providers are bound by data processing agreements requiring them to protect your data and process it solely on our instructions.
Evolution is headquartered in the United States, and your data is primarily processed on U.S.- based infrastructure. Where data is transferred to or processed in other jurisdictions including Nigeria or EU member states, we implement appropriate contractual safeguards consistent with applicable data protection frameworks.
We retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including to meet our legal, regulatory, accounting, and reporting obligations. As a U.S.-registered Money Services Business (MSB) regulated by FinCEN under the Bank Secrecy Act (BSA), Evolution is required to retain transaction records, identity documentation, and Suspicious Activity Reports (SARs) for a minimum of five (5) years. Additional retention periods may apply under Nigerian, EU, or other applicable laws. Where data is no longer required, we delete or anonymize it using secure methods. Where anonymization is not feasible, data is retained in a form that prevents re-identification.
Subject to applicable law, you have the following rights regarding your personal information:
• Right of Access: ", "To request a copy of the personal information we hold about you.
• Right to Rectification: ", "To request correction of inaccurate or incomplete information.
• Right to Erasure: ", "To request deletion of your data where it is no longer necessary, subject to our legal retention obligations.
• Right to Restriction: ", "To request that we limit the processing of your data in certain circumstances.
• Right to Data Portability: ", "To receive your data in a structured, machinereadable format.
• Right to Object: ", "To object to processing based on legitimate interests, including for direct marketing purposes.
• Right to Withdraw Consent: ", "Where processing is based on consent, to withdraw that consent at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, contact us at privacy@getevolution.co. We will respond within thirty (30) days of receiving a verifiable request.
We implement industry-standard technical and organizational security measures, including AES256 encryption for data at rest, TLS 1.2+ for data in transit, multi-factor authentication, role-based access controls, and regular security audits. However, no electronic transmission or storage system is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials. In the event of a data breach that poses a risk to your rights and freedoms, we will notify affected users and applicable regulators in accordance with the timelines prescribed by law.
We use cookies and similar tracking technologies to recognize you, maintain session integrity, analyze usage patterns, and prevent fraud. You may configure your browser to decline nonessential cookies; however, certain features of our Services may not function correctly if you do so. By using our Services, you consent to our use of cookies as described in this Policy.
Our Services are intended for individuals aged 18 and above. We do not knowingly collect personal information from persons under 18. If you become aware that a minor has submitted personal information to us, please contact us immediately at privacy@getevolution.co and we will delete such information promptly.
We may update this Policy periodically to reflect changes in our practices, technology, or legal requirements. Where changes are material, we will notify you by email or in-app notice at least fourteen (14) days before the changes take effect. Continued use of our Services following notice constitutes acceptance of the revised Policy.
Evolution Global Inc.
Data Protection Officer
Email: hello@evolutionglobal.xyz
Evolution is incorporated and registered in the United States. Users may also have rights under their local data protection laws. For complaints, you may contact the relevant supervisory authority in your jurisdiction, including the Nigeria Data Protection Commission (NDPC) where applicable.
