“Personal Information” generally has the same meaning as personal data or personal identifiable information (PII). Personal Information is defined in the data privacy laws applicable in your country. It includes any information relating to an identified or identifiable natural person. This means any individual who can be identified directly or indirectly by reference to an identifier such as name, identification number, location data, online identifiers (for example, IP addresses – if they can be used to identify you) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Put simply, this includes data which either by itself or with other data held by us or available to us, can be used to identify you.
By registering or using this website or the DevonWay Service, users of the DevonWay Service (“User,” “you,” or “your”) explicitly accept, without limitation or qualification, the collection, use, and transfer of Personal Information provided by you in the manner described in this Policy.
Please read this Policy carefully as it affects your rights and liabilities. If you disagree with the way that DevonWay collects and processes Personal Information, please do not use the DevonWay website or the DevonWay Service. Any inquiries should be sent to firstname.lastname@example.org.
- DevonWay's role
- Information we collect
- How we collect your data
- How we use your data
- How we store your data
- How we share information
- Your rights and choices
- Standard Contractual Clauses
- Data Integrity
- How to contact us
DevonWay is acting in the capacity of Controller (defined below) when collecting and processing Personal Information on its own behalf and for its own purposes. This means situations in which DevonWay determines the purposes and the means of such processing at its own discretion. The “Controller” or “Processor” (as applicable) for the purposes of the GDPR, other data protection laws applicable in member states of the European Union and other provisions related to data protection is: DevonWay, Inc., 601 California Street, Suite 615, San Francisco, CA 94108.
For certain services, DevonWay has been retained by our customers to process Personal Information as a Processor. In such cases, DevonWay shall process your Personal Information on behalf of and based on the specific instructions given by our customer as the Controller. The subject-matter and duration of the processing, the nature and purposes of the processing, the type of Personal Information and categories of data subjects, together with the rights and obligations of the parties with respect to such processing will be covered by a data processing agreement (or equivalent terms) agreed between DevonWay and our customer.
When a DevonWay customer uploads Personal Information (typically contact information) to the DevonWay Service, then the DevonWay customer is the Controller of such Personal Information.
Information we collect.
DevonWay may collect the following categories of Personal Information to supply users with the DevonWay Services:
- Personal identification information (Name, email address, office phone number, work qualifications, etc.);
- IP address information.
Under special circumstances, DevonWay may collect and store sensitive Personal Information that you or your employer provide to us, such as social security number and protected health information. We will not use such sensitive Personal Information except for the specific purpose for which you provide it and to carry out the DevonWay Services.
How we collect your data.
You directly provide DevonWay with most of the data we collect. We collect and process data when you or your employer:
- Register online or place an order for the DevonWay Services;
- Voluntarily submit information;
- Use or view our website via your browser’s cookies.
You can set your browser not to accept cookies and/or remove cookies from your browser. If you do not want us to collect cookies from your use of the DevonWay website, you may opt out through the pop-up banner that appears when you first access the website.
How we use your data.
We use your Personal Information for legitimate business purposes, including:
- Providing access to our services;
- Providing you with customer service;
- Processing your order;
- Sending you information about the DevonWay Service;
- Our business purposes;
- Personalizing the DevonWay Service;
- Maintaining data security.
Hubspot aggregates information provided by you to help us analyze and respond to the individuals and companies that research information on our website. If you do not want us to collect this information, you may opt out through the pop-up that appears on our website when you first access it.
We may also use aggregated and anonymized information to help improve and market the DevonWay Services.
How we store your data.
We will not retain your data for longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.
We securely store your data at data centers certified to SSAE 16 Type II and ISO 27001. Depending on the terms of the service agreement between you and your employer, these data centers may be located in the United States, European Union, or Canada.
We will keep your Personal Information for the length of time required by your employer. Once this time period has expired, we will delete your data.
How we share information.
We do not sell your Personal Information to anyone.
We may preserve, use, share, or disclose your information if we believe that it is reasonably necessary to:
- Comply with a law, regulation, legal process, or request by government and/or public authorities, including to meet national security or law enforcement requirements;
- Address fraud, security, or technical issues;
- Protect our rights or property, or the rights or property of those who use the DevonWay
DevonWay contracts with third-party data centers, including Rackspace, Inc. (“Rackspace”) in the United States and Amazon Web Services (“AWS”) in the United States, Canada, and the European Union, to provide bandwidth and data hosting. Rackspace and AWS have agreed to maintain the confidentiality of Personal Information and not use it for any other purpose than to provide services related to the DevonWay Service.
We may also disclose and/or transfer your Personal Information to a third party who acquires any or all of DevonWay’s assets and business units, whether such acquisition is by merger, consolidation, or purchase of all or a substantial portion of DevonWay’s assets. This Policy will apply to your Personal Information that is shared with (before and after the close of any transaction) or transferred to the new entity.
In the event DevonWay becomes the subject of an insolvency proceeding, whether voluntary or involuntary, DevonWay or its liquidator, administrator, receiver, or administrative receiver may dispose of such information in a transaction approved by court.
Your rights and choices.
We want to ensure that you are fully aware of all of your data protection rights. Users covered under the California Consumer Privacy Act (“CCPA”) or the European General Data Protection Regulation (“GDPR”) are entitled to the following:
- The right to be informed – You have the right to request from DevonWay what data is being collected, how it is being used, how long it will be kept, and whether it will be shared with third parties.
- The right to access – You have the right to request from DevonWay copies of your Personal Information. There may be a fee associated for this service.
- The right to correct – You have the right to request that DevonWay correct any information you believe is inaccurate. You also have the right to request DevonWay to complete information you believe is incomplete.
- The right to delete – You have the right to request that DevonWay delete your Personal Information, under certain conditions.
- The right to limit/restrict processing – You have the right to request that DevonWay restrict the processing of your Personal Information, under certain conditions.
- The right to object to processing – You have the right to object to DevonWay’s processing of your Personal Information, under certain conditions.
- The right to data portability – You have the right to request that DevonWay transfer the data that we have collected to another organization, or directly to you, under certain conditions.
- The right to opt-out – You have the right to request that DevonWay stop sharing your Personal Information for the purpose of cross-context behavioral advertising (targeted advertising to a user based on the user’s Personal Information obtained from the user’s online activity across numerous websites).
If you would like to exercise any of these rights, please submit a request to email@example.com.
Transfers outside your country.
Your Personal Information may be collected, transferred to and stored by us in the United States and by our affiliates and third parties based in other countries.
Therefore, your Personal Information may be processed outside your country or jurisdiction, including in places that are not subject to an adequacy decision by the European Commission or your local legislature or regulator, and that may not provide for the same level of data protection. We ensure that the recipient of your Personal Information offers an adequate level of protection and security, for instance by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission (Art. 46 GDPR) or other applicable regulators or legislators. Where required by applicable law, we will only share, transfer or store your Personal Information outside of your jurisdiction with your prior consent.
We take reasonable precautions to protect your information. Please keep in mind that messages you send to us by Internet e-mail may not be secure. We maintain appropriate physical, electronic and procedural safeguards to ensure the security, integrity and privacy of your Personal Information within our company. Only those employees who may require your information to perform a specific job are granted access to your organization’s identifiable information. Furthermore, all employees are kept up to date on our security and privacy practices.
DevonWay’s use of your Personal Information is limited to the information that is relevant for the purposes of processing such information as part of the DevonWay Service. To the extent necessary, we will take reasonable steps to ensure that Personal Information is reliable for its intended use, accurate, complete, and current.
If we decide to make substantial and material changes or updates to the substance of the Policy, we may contact you (when required by law) via the email address that you provided to us. We will also post those changes through a prominent notice on the DevonWay website so that you will know what information we collect, how we might use that information, and to whom we may disclose it.
How to contact us.
If there are any questions about the DevonWay website or the DevonWay Service, please contact us at firstname.lastname@example.org.
This Policy was last updated as of September 2023.