This Privacy Policy describes how DevAccuracy LCC and its affiliated companies (collectively, “DevAccuracy”, “we”, “our” or “us”) collects, stores, uses and discloses the following categories of personal data:
User Data which relates to focal persons at our business customers, who directly engage with DevAccuracy concerning their organizational account, and users of the DevAccuracy User Management and Authentication platform (“Platform”) on behalf of such customers – e.g., the account administrators and users, billing contacts and authorized signatories on behalf of the customer (collectively, “Users”); as well as the customer’s business needs and preferences, as identified to us or recognized through our engagement with them;
Prospect Data relating to visitors of our website, participants at our events, and any other prospective customer, user or partner (collectively, “Prospects”) who visits or otherwise interacts with our website, online ads and content, emails, integrations or communications under our control (the “Sites”, and collectively with the Platform, the “Services”).
This Privacy Policy does not apply where we process personal data on behalf of our customers in our role as a data processor (e.g., our customers’ end-users).
Specifically, this Privacy Policy describes our practices regarding:
Data Collection & Processing
Data Uses
Data Location
Data Retention
Data Disclosure
Cookies and Data Collection Technologies
Communications
Data Security
Data Subject Rights
Data Controller/Processor
Additional Notice & Contact Details
If you are a User or a Prospect , please read this Privacy Policy carefully and make sure that you fully understand it.
You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our service providers (as described below), please do not provide it to us and avoid any interaction with us or with our Services.
- Data Collection & Processing
When we use the term “personal data” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.
Sometimes we collect personal data automatically when an individual interacts with our Services and sometimes, we collect personal data directly from an individual. At times, we may collect personal data about an individual from other sources and third parties (such as our customers and service providers), even before our first direct interaction.
We may collect or generate the following types of personal data about Users and Prospects through the Services:
Usage, login credentials, and device information concerning Users and Prospects as they interact with our Services (connectivity, technical and aggregated usage data, such as user agent, IP addresses and approximate location based upon such IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, log-in credentials to the Services, the cookies and pixels installed or utilized on their device, and inferred or presumed data on generated from their use of the Services);
Contact information concerning our Users and Prospects (contact and business details such as name, email, phone number, position, workplace and related business insights, our communications with such individuals, feedback received, contractual and billing details, as well as any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement).
- Data Uses
We use personal data as necessary for the performance of our Services (“Performance of Contract”); to comply with our legal obligations (“Legal Obligation”); and to support our legitimate interests in maintaining and improving our Services, e.g. in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our customers, Users, Prospects, ourselves and our Services (“Legitimate Interests”).
If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Services, or due to nature of such processing) (“Consent”), your acceptance of our Terms and Conditions and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at [email protected].
Specifically, we use personal data for the following purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):
User personal data
To facilitate, operate, enhance, and provide our Services (Performance of Contract; Legitimate Interests);
To provide our Users with assistance and support, to test and monitor the Services, or diagnose or fix technology problems, and to train our customers’ staff (Performance of Contract; Legitimate Interests);
To personalize our Services, including by recognizing an individual and remembering their information when they return to our Services, and to provide further localization and personalization capabilities (Performance of Contract; Legitimate Interests);
To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby are intended to increase your engagement and overall satisfaction with our Services. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners (Legitimate Interests; Consent);
To facilitate, sponsor and offer certain events, contests and promotions (Legitimate Interests);
User and Prospect personal data
To gain a better understanding on how individuals use and interact with our Services, which content and data they have processed through our Services, and how we could improve their and others’ user experience and the value they can generate from using the Services, so we could continue improving our products, offerings and the overall performance of our Services (Legitimate Interests);
To contact our Users and Prospects with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (Performance of Contract; Legitimate Interests; Consent);
To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activity (Performance of Contract; Legitimate Interests; Legal Obligation);
To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose (Legitimate Interests);
To enforce our Terms and Conditions (https://DevAccuracy.com/terms), to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties (Legitimate Interests);
To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards (Performance of Contract; Legitimate Interests; Legal Obligation); and
For any other lawful purpose, or other purpose that you consent to (Legal Obligation; Consent).
- Data Location
We and our authorized Service Providers (defined below) maintain, store and process personal data in the United States of America, Europe, Israel and other locations, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
While privacy laws may vary between jurisdictions, DevAccuracy is committed to protect personal data in accordance with this Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.
DevAccuracy Inc. is headquartered in the United States, and for data transfers from the EEA, Switzerland or the UK to countries which are not considered by the European Commission, the Swiss Federal Data Protection and Information Commissioner (FDPIC), and the UK Secretary of State to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered into Standard Contractual Clauses as approved by the European Commission, FDPIC and UK Information Commissioner’s Office (ICO). You can obtain a copy by contacting us as indicated in Section 11 below.
- Data Retention
We retain personal data for as long as we deem it as reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.
If you have any questions about our data retention policy, please contact us by e-mail at [email protected].
- Data Disclosure
We disclose personal data in the following ways:
Service Providers: We may engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, remote access services, analysis services, performance measurement, data optimization and marketing services, social and advertising networks, content and data enrichment providers, e-mail, voicemails, support, enablement and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers”). Our Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.
Event Sponsors: If you attend an event or webinar organized by us, or download or access an asset on our Sites related to such an event, webinar or other activity involving third-party sponsors or presenters, we may share your personal data with them. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your personal data will be subject to the sponsors’ privacy statements. If you do not wish for your personal data to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned, or you can opt-out in accordance with Section 9 below.
Business Customers: Our customers have access to any personal data we process on their behalf in our capacity as a “processor” or “service provider”, as further explained in Section 10 below.
Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
Protecting Rights and Safety: We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of DevAccuracy, any of our Users or customers, or any members of the general public.
DevAccuracy Subsidiaries and Affiliated Companies: We may share personal data internally within our group, for the purposes described in this Privacy Policy. In addition, should DevAccuracy or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, personal data may be shared with or transferred to the parties involved in such an event. We may disclose personal data to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy or receivership.
For the avoidance of doubt, DevAccuracy may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous.
- Cookies and Data Collection Technologies
We and our Service Providers use cookies and other technologies for performance, tracking, analytics and personalization purposes. We may share non-identifiable / aggregated extracts of such information with our partners for our legitimate business purposes.
Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.
We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Platform. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools. We may also use HTML5 local storage or other techniques for the above-mentioned purposes. These technologies differ from browser cookies in the amount and type of data they store, and how they store it.
Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services.
We also use web analytics tools, including Google Analytics. These tools help us understand Users’ behavior on our Services, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our analytics service providers is available at: www.google.com/policies/privacy/partners/. Further information about your option to opt-out of these analytics services is available at: https://tools.google.com/dlpage/gaoptout.
Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.
For more information on our cookie and data collection technologies practices, please see our
.
- Communications
We engage in service and promotional communications, through e-mail, phone, SMS and notifications.
Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. If you are registered as a User to our Services, you can typically control your communications and notifications settings from your profile settings, or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt out of receiving certain service communications which are integral to your use (e.g., one-time auth tokens or billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our User or Prospect. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify DevAccuracy at any time by sending an e-mail to: [email protected], changing your communications preferences in your profile settings whilst being logged as a User to our Services, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
- Data Security
We implement systems, applications and procedures intended to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, we cannot guarantee that our Sites or Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse. - Data Subject Rights
Individuals have rights concerning their personal data. Please contact us by e-mail at: [email protected] if you wish to exercise your privacy rights under any applicable law, including the EU or UK General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), such as – to the extent applicable – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with DevAccuracy, or to restrict or object to such personal data’s processing (including the right to direct us not to sell your personal data to third parties now or in the future), or to port such personal data, or the right to equal services and prices (e.g. freedom from discrimination) (each to the extent available to you under the laws which apply to you). If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable.
Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (i.e., as proof of the identity of the person submitting the request).
We may redact from the data which we will make available to you, any personal data related to others.
- Data Controller/Processor
Certain data protection laws and regulations, such as the EU GDPR, UK GDPR and the CCPA, typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
DevAccuracy is the “data controller” of User and Prospect Data. With respect to such data, we assume the responsibilities of the data controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will assume the role of “data processor”.
DevAccuracy is the “data processor” of its customers’ end-users’ personal data, which we process on behalf of our customer (who is the “data controller” of such data), strictly in accordance with their reasonable instructions subject to our data processing addendum and other commercial agreements with such customer.
Our customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the customer’s behalf or at their request, as well as all individuals whose personal data may be processed by or on behalf of the customer through the Services, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, use or other processing of data through our Services are fully met by the customer, including specifically in the context of an employment relationship. Our customers are also responsible for handling data subject rights requests under applicable law, by their Users and other individuals whose data they process through the Services.
- Additional Notices & Contact Details
Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.
California Requirements: This policy describes the categories of personal information we may collect and the sources of such information (Section 1), and our retention (Section 4) and deletion (Section 9) practices. We also included information about how we may process your information (in Sections 2 through 7), which includes for “business purposes” under the California Consumer Privacy Act (CCPA). We do not sell your personal information for the intents and purposes of CCPA. We may disclose personal data to third parties or allow them to collect personal data from our Services as described in Section 5 above, if those third parties are authorized Service Providers or business partners who have agreed to our contractual limitations as to, for example, their retention, use, and disclosure of such personal data, or if you integrate the services of third parties with our Services, or direct us to disclose your personal data to third parties, or as otherwise described in Section 5 above.
If you have any questions or would like to exercise your rights under the CCPA, you can contact us at [email protected].
External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Services.
Children: Our Services are not designed to attract children under the age of 16. We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such a child. If you believe that we might have any such data, please contact us by e-mail at [email protected].
Contacting Us: If you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal data held with us, please contact DevAccuracy’s support at [email protected].
Last updated: September 2022.
