When you visit the Sites or use or interact with any of our Services, we will collect information from or about you or your device, and this information will be handled as described herein.
We may use information collected through the Sites and Services in various ways, depending on whether you are a (i) customer utilizing our Services (“Customer”); (ii) a user who uses our Services to interact with our Customers (“User”); or (iii) a visitor to our Sites, or online content which features our Services (“Visitor”).
- Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Services to you.
- Types of Data Collected
- Personal Data
When you register for an account, as either a Customer or a User, you will provide us with information about yourself and payment information (“Personal Data”). This may include information about your online profile, such as contact information, profile pictures, gender, date of birth, interests, and related information that can be found on your social media profiles that you attach to your interactions with Devfi.
Devfi utilizes a third-party payment processing service to process your payment. We do not retain any such payment or financial information following your transaction. If you believe your payment information has been submitted without your consent, please contact us immediately, and we will work with you to resolve any concerns with our payment processing service. Personally, identifiable information may include, but is not limited to:
- Email address
- First name and last name
- ZIP/Postal code
Devfi’s third-party payment processing service collects, stores, and utilizes payment information, including, without limitation, credit card, debit card, bank account, or other payment data. See Section 10(a) below for more information.
- Usage Data
We may also collect information on how the Services or Sites are viewed, accessed, and used (“Usage Data”) from Customers, Users, and Visitors. This Usage Data may include: (a) information related to the devices you use to access or interact with the Services, such as IP addresses, geolocation information, unique device identifiers, and other information about your mobile phone or other mobile device (s), browser types and browser language; and (b) information related to the ways in which you interact with the Services, such as the pages that have directed you to the Services and pages that you go to when exiting the Services, as well as URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, and other similar information. We may collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and we may use that information to customize the Services with location-based information and features.
We may obtain this data from third-parties.
You may also see or interact with our Services via third-parties. What data such third- parties collect and how they handle that data is governed by their respective privacy policies.
We may also process information contained in any inquiry you submit to us regarding the Services (“Inquiry Data”). The Inquiry Data may be processed for the purposes of offering, marketing, and selling relevant goods and/or services to you.
We may also process your personal data that is provided in the course of the use of our Services (“Service Data“). The Service Data may include information relating to our customer relationships, including customer contact information, and may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications, and promoting our products and services to customers.
We may also process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“Transaction Data“). The Transaction Data may include your contact details, your card details, and the transaction details. The source of the Transaction Data is you and/or our payment Service Provider. We may also process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters. We may also process information contained in or relating to any communication that you send to us, which may include the communication content and metadata associated with the communications.
Inquiry Data, Service Data, and Transaction Data are considered Usage Data.
- Tracking Cookies Data
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used, such as beacons, tags, and scripts, to collect and track information and improve and analyze our Services.
You can instruct your browser to refuse all cookies or indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.
- Use of Data
Devfi uses the collected data for various purposes:
- Personal Data
Devfi may share your Personal Data with third parties for the purposes of providing the Services to Customers and Users and as needed to implement the Services. We will share your name and email, and other related information with Customers with whom you have interacted with. We may also use this information to communicate with our Customers and Users, including through promotional or information emails. Whether you receive such communications will depend on whether you opted-in to such communications when creating your account. You may update or change your Personal Data or opt-in or out at any time.
Regarding User’s Personal Data, in addition to the uses set forth above, we may utilize your Personal Data to tailor the content and information that we may send or display to Users or otherwise personalize your experience.
In all other cases, we will ask your consent before disclosing your Personal Data to an unaffiliated third-party or for a purpose other than those for which it was originally collected or specifically authorized subject to the provision herein. Third parties to which Devfi may disclose personal information include the Service Providers set forth below.
- Usage Data
Devfi may collect and share Usage Data collected from Customers, Users, and Visitors with third parties for any purpose, including, without limitation, to gather analysis or valuable information so that we can improve our Services, to tailor the content and information that we may send or display to Users, marketing and advertising, and to monitor the usage of our Services and/or to detect, prevent and address technical issues. We may also disclose Usage Data to our Customers.
- Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
We may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests, and it is not overridden by your rights
- For payment processing purposes
- To comply with the law
- Retention of Data
We will also retain Usage Data for internal analysis purposes. Usage Data is the exclusive property of Devfi and may be retained for any period of time.
- Transfer of Data
Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside of the United States and choose to provide information to us, please note that we may transfer the data, including Personal Data, to the United States and process it there.
- Disclosure of Data
- Business Transaction
- Disclosure for Law Enforcement
Under certain circumstances, Devfi may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
- Legal Requirements
Devfi may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Devfi
- To prevent or investigate possible wrongdoing in connection with the Services
- To protect the personal safety of users of the Services or the public
- To protect against legal liability
- Security of Data
- Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
- Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
Under Chapter 3 of the GDPR, you have certain rights, including:
- The right to be informed; This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
- The right of access; this is your right to see what data is held about you by a Data Controller.
- The right to rectification; the right to have your data corrected or amended if what is held is incorrect in some way.
- The right to erasure; under certain circumstances, you can ask for your personal data to be deleted. This is also called ‘the Right to be Forgotten’. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
- The right to restrict processing; gives you the right to ask for a temporary halt to the processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
- The right to data portability; you have the right to ask for any data supplied directly to the Data Controller by him or her, to be provided in a structured, commonly used, and machine-readable format.
- The right to object; you have the right to object to the further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
Rights in relation to automated decision making and profiling; Data Subjects have the right not to be subject to a decision based solely on automated processing.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EEA.
- Service Providers
We may employ third-party companies and individuals to facilitate our Services (“Service Providers”), provide the Services on our behalf, perform Service-related services or assist us in analyzing how our Services are used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may provide paid products and/or services within the Services. In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are available by contacting Devfi below.
- Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
- Children’s Privacy
Our Services do not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
- By email: [email protected]