DevicePilot understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
We are the data controller and therefore responsible for, and control the processing of, the Personal data collected via Our Site, in accordance with the General Data protection Regulations and Data Protection Act 2018 (the “GDPR/ the “Act”). “Personal data” means any information that identifies a living individual or makes the individual identifiable.
1.Definitions and Interpretation
1.1 In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of Our Site;|
|“Cookie”||means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;|
|“Our Site”||means this website, http://devicepilot.com;|
|“UK and EU Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and|
|“We/Us/Our”||means DevicePilot Ltd., a limited company registered in England under 08413230, whose registered address is 14 Rosebery Avenue, London, EC1R 4TD, UK.|
2. Information About Us
2.1 Our Site, devicepilot.com, is owned and operated by DevicePilot.
3. Scope – What Does This Policy Cover?
4. What Data Do We Collect?
4.1 Some data will be collected automatically by Our Site, other data will only be collected if you voluntarily submit it, for example, when signing up for an Account or to be on our mailing list. Depending upon your use of Our Site, We may collect some or all of the following data:
4.1.1 personal information including name, title;
4.1.2 employment/ business details including business/company name and job title;
4.1.3 contact information including email addresses, telephone number and address;
4.1.4 demographic information including post code, preferences and interests;
4.1.5 financial information including account details, credit / debit card numbers;
4.1.6 details of any enquiries made by you through Our Site, together with details relating to subsequent correspondence; and
4.1.7 technical information including IP address (automatically collected), web browser type and version (automatically collected), operating system (automatically collected), a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected) and other data as collected by industry standard analytics tools such as Google Analytics.
4.2 We may monitor your use of Our Site through ‘cookies’ and similar tracking technologies. We may also monitor traffic, location and other data and information about users of the Website. Such data and information, to the extent that you are individually identifiable from it, shall constitute Information as defined above. However, some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.
5. How Do We Use Your Data?
5.1 In accordance with the GDPR/ the Act, We may use your Personal data if we have a legal basis for doing so, For the purpose of this Policy, our legal basis for processing your personal data is set out below.
|Why we will process your Personal data||The legal basis for which is…|
|To operate, administer, maintain, provide, personalise, analyse, and improve Our Site||This processing is necessary for the legitimate interest we pursue in improving Our Site, subject to your raising an objection, requiring us to check that our interest is not overridden by any risk to your rights.
|To investigate and address any comments, queries or complaints made by you regarding Our Site||This processing is necessary for the legitimate interest we pursue in responding to enquires, subject to your raising an objection, requiring us to check that our interest is not overridden by any risk to your rights.
Where an enquiry relates to your account or our contract for services this processing may be necessary for the performance of a contract.
|Providing and managing your Account||This processing is necessary for the performance of a contract between us and information is processed to enable us to provide an account to you.
|Supplying Our products and services to you||This processing is necessary for the performance of a contract between us and information is processed to enable us to provide our services to you.
|Personalising and tailoring Our products and services for you||This processing is necessary for the performance of a contract between us and information is processed to enable us to provide our services to you.
This processing is necessary for the legitimate interest we pursue in keeping our products competitive and relevant to you, subject to your raising an objection, requiring us to check that our interest is not overridden by any risk to your rights.
|Processing any claim, including a breach of contract, payment of money due etc.
|This is necessary for the legitimate interests we pursue in obtaining payment for the Services we provide and/ or advancing or defending a claim in relation to the services we provide, subject to you raising an objection, requiring us to check that our interest is not overridden by any risk to your rights.
|Supplying you with emails that you have subscribed to||This processing is necessary for the legitimate interest we pursue in maintaining contact with you for our business purposes, subject to your raising an objection, requiring us to check that our interest is not overridden by any risk to your rights.
|To disclose your Personal data to selected third parties as set out below||This processing is necessary for the performance of a contract between us and information is processed to enable us to provide our services to you.
|To contact you for marketing purposes.
(See marketing clause below)
|This processing is necessary for the legitimate interest we pursue in marketing other products and services to you, subject to your raising an objection, requiring us to check that our interest is not overridden by any risk to your rights.
|Where required to comply with our legal obligations, including identity checks, requests from HMRC etc||This processing is necessary to comply with our|
6.How long we keep your Personal data
6.1 We only keep your data for as long as We need to in order to use it as described above in section 5. As a guide we will usually retain your Personal data for 7 years following termination of our contract/ services with you.
6.2 If required, we will be entitled to hold your Personal data for longer periods in order to comply with our legal or regulatory obligations.
7. Who do We Share Your Data with?
7.1 We may share your data with other companies in Our group. This includes Our subsidiaries and or Our holding company and its subsidiaries.
7.2 We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your Personal data. Where any of your Personal data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
7.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
7.4 In certain circumstances We may need to share your data with third parties, such as legal counsel (barristers, solicitors), to advance or defend a claim.
7.5 In certain circumstances We may be legally required to share certain data held by Us, which may include your Personal data, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority.
7.6 To any prospective buyer or seller (and their representative) in the event that we sell or buy a business or asset.
8. Overseas transfers
8.1 Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein) including: USA because our cloud service provider are based there.
8.2. Such countries may not have similar protections in place regarding data protection. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA. Such steps may include, but not be limited to, only transferring to countries subject to an adequacy decision, the use of approved contractual clauses (model clauses or the use of legally binding corporate terms.
9. Security measures
9.1 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
9.2 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
10.1 For the purposes of the GDPR and Act We have a legitimate interest in processing your Personal data (name and contact details) for marketing communications.
10.2 For marketing communications that are business to business we do not require your permission, in line with current regulations. Where marketing communications are aimed at you as an individual we may require your permission to send these communications in certain circumstances, which are set out below.
10.3 Where you have previously ordered products or services from us, unless you have told us not to, we may contact you by telephone, email or post about similar products, services, promotions and special offers that may be of interest to you “soft opt-in”.
10.4 In addition, with your permission, we may contact you by telephone, email or post to provide information in relation to other products, services, promotions, special offers and other information we think may be of interest to you.
10.5 Further, with your permission, we may share your details with carefully selected third parties and they may contact you directly (unless you ask them not to) by telephone, email or post about products, services, promotions and special offers that may be of interest to you.
10.6 You have the right at any time to ask us, [or any third party], to stop processing your information for direct marketing purposes. If you wish to exercise this right please follow the unsubscribe link on the communications or contact us on the below details, or the relevant third party, giving us or them enough information to identify you and process your request.
10.7 Where you have requested that we no longer contact you for marketing communications, we may retain your Personal data as a record of this request.
11. Your rights in respect of your personal data
11.1 This section sets out the legal rights of individuals in respect of the personal information we are holding and/ or processing. If you wish to exercise any of your legal rights you should put your request in writing to us (using the contact details below) giving us enough information to identify you and respond to your request. Details of your rights are set out below:
11.1.1 The right of access – you have a right to access the Personal data we hold about you. Most requests will receive a response within one month of receipt of a valid request; those which are more complex or numerous may take up to three months. You may not be entitled to see all of the information about you if an exemption applies;
11.1.2 The right to rectification – if the personal information that we hold about you is incorrect, you have the right to ask us to amend it. Taking into account the purposes of the processing of personal data, the data can be rectified or, if data is incomplete, completed;
11.1.3 The right to erasure – in certain circumstances you have the right to request that the personal data held about you is deleted or removed. The GDPR outlines specific circumstances when this right applies; including: where data is no longer needed for the purposes for which it was collected or otherwise processed. There are certain exemptions to the right; including: when processing is necessary to comply with a legal obligation.
11.1.4 The right to restrict processing – in certain circumstances you are entitled to restrict process of personal data; this includes: where you contest the accuracy of the data; we no longer need the data for the purposes of processing. You may also request processing is restricted were you object to our legitimate interests as the basis of processing your personal data or you believe continued processing to be unlawful. If this right is exercised, any further processing of your data will take place only with your consent or in certain circumstances in which the GDPR allows such processing to take place;
11.1.5 The right to data portability – in certain circumstances you have the right, on request, to ask us to provide a copy of the personal data that you have previously supplied to us, i.e. where the processing is by automated means and you wish to transfer to a new service provider;
11.1.6 The right to object – in certain circumstances you have the right to object to the processing of your personal data by us. In particular, where you can demonstrate that such processing would be detrimental to your interests. If this right is exercised processing of personal data will stop, subject to us demonstrating compelling legitimate grounds for the processing to continue; or for the establishment, exercise or defence of legal claims.
11.2 If you seek to exercise a right and we consider an exemption applicable (or the relevant right is not exercisable), we will explain this to you in as clear a way as possible.
12. What Cookies Do We Use and What For?
12.2 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site to better understand visitors to our site.. These Cookies are not integral to the functioning of Our Site.
12.3 All Cookies used by and on Our Site are used in accordance with current UK and EU Cookie Law.
12.4 Certain features of Our Site depend on Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.10, but please be aware that Our Site may not work as intended if you do so.
12.5 The following first party Cookies may be placed on your computer or device:
Cookies belonging to website tools for remembering preferences
and the following third party Cookies may be placed on your computer or device:
Cookies for tracking return visitors by industry standard tools such as Google Analytics
12.6 Our Site uses analytics services provided by Google and others. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
12.7 The analytics service(s) used by Our Site use(s) Cookies to gather the required information. Certain of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 12.10.
12.8 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
12.9 You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
12.10 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
13. Contacting Us
We welcome your feedback and questions on this policy or Our Site. If you wish to contact us, please email us at firstname.lastname@example.org.
14.1 If you have any concerns about how we collect or process your Information, please contact us on the above details.
14.2 Should you remain dissatisfied with our response or would prefer to contact the ICO direct you can do so. You have the right to lodge a complaint with a supervisory authority, which for the UK is the UK Information Commissioner’s Office (“ICO”). Complaints can be submitted to the ICO through the ICO helpline by calling 0303 123 1113. Further information about reporting concerns to the ICO is available at https://ico.org.uk/concerns/.