Introduction
Devie Ltd. (“Devie”, “us”, “we” or “our”) is committed to protecting and respecting your privacy. This Privacy Notice describes how we collect, store, use and distribute personal data through our software,website, mobile application (“App”), documentation, and related services (together, the “Services”).
This privacy notice sets out why we collect personal data, how we collect and use it and who it isshared with. It also explains the legal basis for the use of your personal data and the legal rights youhave over the way it is used
In this Privacy Policy, references to “you” means the person whose personal data we collect, use and process. Please read this Privacy Policy carefully to understand our treatment and use of personal data.
We will use your personal data only for the purposes and in the manner outlined below, and in compliance with applicable laws.
Please note that by using the Services, you acknowledge that you have read and understand this Privacy Policy.
About Us
Devie is a social enterprise which provides digital coaching to parents.
For the purposes of the General Data Protection Regulation (“GDPR”) and the Data Protection Act2018, the controller of your personal data is Devie Ltd, a company registered in the United Kingdom,having its registered office address at 8 Dereham Place Flat 9 London, UK EC2A3HJ.
Contact details
Devie’s Data Protection Officer can be contacted at:
Email: team@deviecoach.com
Address: 8 Dereham Place Flat 9 London, UK EC2A3HJ
The types of personal data we collect and the purposes for which it is collected
The type and amount of personal data we collect depends on the purpose for which it is beingprovided and processed:
User account information: if you choose to set up an account with Devie, we will collect personalinformation such as your first name, preferred pronoun, information about your children (number ofchildren, first names, birth month and year) and email address. This information will be used in orderfor us to provide you with our services, including digital coaching.We may also use this information tomaintain service user lists, respond to enquiries, provide you with our newsletter, and to providetechnical support.
Additional user information: We may also collect referral code, platform and operating systemversion, responses to feedback requests and surveys. This information may be used for identificationand authentication purposes, for service improvement, and to address issues like malicious use ofDevie’s services.
Information provided by you in communications with Devie: if you use Devie’s digital coachingservice, we will collect information about you that you choose to share with us in communications withthe Devie coach, for example, details about your family life.
Financial and billing information: information which will be collected in order to take payment forservices includes billing name, address and credit card number, as applicable.
Hardware diagnostic and login information: this may include crash reports, along with logginginformation from your system documenting the error, information regarding your operating systemversion, hardware, browser version (and .NET version information in case of Windows systems), and your email address, if provided. Additionally, certain login information may be maintained in a cookiestored locally on your device in order to streamline the login process (further information aboutcookies is below).
Analytics information: collected through the use of cookies, log files and web beacons (suchinformation may include standard information regarding your mobile device, browser type, browserlanguage, operating system, Internet Protocol address, and the actions you take on our web site(such as the web pages viewed and the links clicked) or while using the services. We collect thisinformation in order to help us administer, protect and improve our services, to analyse usage andimprove customer experience overall.
Special Category Personal Data
Certain categories of personal information are regarded by data protection law as more sensitive thanothers. Known as ‘special category personal data”, this relates to information about you, and whoeveryou choose to share information about within your family, including but not limited to health, racial orethnic origin, details of sexual life, sexual orientation, religious beliefs, political opinions or any geneticor biometric data that is used to identify you.
We do not usually process special category personal data about you unless you choose to share itwith us in order for us to provide our services. We will always make it clear when we collect thisinformation from you what sensitive personal data we are collecting and why.
How we collect your personal data
Personal information that we obtain from you is collected:
Personal information may be collected from third parties such as:
If you fail to provide personal data
Where we need to collect personal data in order to provide our services and you fail to provide thatdata when requested, we may not be able to carry out your instructions or perform the contract wehave or are trying to enter into with you. In this case, we may have to cancel our engagement, but wewill notify you if this is the case at the time.
What we use your personal data for and our legal reasons for doing so
We process your personal data for the purposes set out in this Privacy Notice. Data protection lawalso requires us to have a legal reason for processing your personal data. Depending on the purposesfor which we use your data, one or more of the legal reasons listed below may be relevant:
Legal reason: Legitimate Interests
We rely on the legal reason of “legitimate interests’ in order to process your personal data where webelieve it is necessary for the legitimate interests of Devie or another party providing that thoseinterests are not outweighed by the impact on your own rights and freedoms.
Examples of where we may process your personal data for the legal reason of “legitimate interests”include:
To provide the Services, to maintain our customer/visitor lists, to respond to your inquiries or providefeedback, for identification and authentication purposes, for service improvement, and to addressissues like malicious use of the Services.
You have the legal right to object to us processing your personal data for the legal reason of“legitimate interest”. To learn more about how to exercise that right please see below, “Your rights”.
Legal reason: Performance of a contract
When you sign up to use our Services, we will need to process your personal data in order to fulfil our contractual obligations.
Legal reason: Consent:
We may rely upon your specific consent to use your personal data when you request informationabout our services, register for our newsletter, request customer or technical support, or otherwisecommunicate with us.
We may also rely on your explicit consent in order to collect, use or share special category datarelating to you with a third party.
Where we rely on your consent to use your personal data, you have the right to withdraw that consentat any point in time. To learn more about how to exercise that right please see below, “Your rights”.
You can unsubscribe at any time by clicking the unsubscribe link in each email or by contacting us viathe methods described in “Contact Details” above.
Legal reason: to comply with a legal obligation
For example, where we are compelled to process your personal information to comply with a court order or a law.
Who we may share your personal data with
We will not sell, exchange or rent your personal data with any third party for marketing purposes. Wemay however disclose your information for the following purposes:
Transfers of your information to other countries
We may transfer your information to countries or territories outside the UK and / or the EuropeanEconomic Area (EEA) which do not provide the same level of data protection as the country in whichyou reside and are not recognised by the European Commission as providing an adequate level ofprotection for personal data. Examples include:
Software development teams and hosting services
We ensure that any transfer of your personal data is adequately protected and secure by ensuringthat it is subject to appropriate safeguards as prescribed by GDPR. For example, in certain cases, wemay choose to only transfer your personal information to third parties that are based in countries thathave been approved by the European Commission or such other relevant regulatory authority in theUK, as providing adequate protection for personal data. Alternatively, we may require that the transferis subject to standard contractual clauses that are approved by the European Commission asproviding adequate protection for personal data. For more information about this please contact us.
If you would like to see a copy of any relevant provisions, please contact Devie’s Data ProtectionOfficer / Representative
Children’s Privacy
Our services are not aimed at children. In the limited circumstances where we may collect and usepersonal information about children (as described above) we will comply with relevant law andguidelines.
Security of your personal data
We understand the importance of security of personal information and take appropriate steps tosafeguard it.
For example, we ensure only authorised persons (that means our staff, volunteers and only necessaryservice providers) have access to your information
However, security of transmission of data over the internet cannot be guaranteed to be 100% secure.So, whilst we take appropriate technical and organisational measures to protect your personal datafrom being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, wecannot guarantee the security of any information you provide online and you do this at your own risk.
If you would like more information about the security measures we have implemented please contactus.
We have also put in place procedures to deal with any suspected personal data breach and will notifyyou and any applicable regulator of a breach where we are legally required to do so.
Our use of Cookies
A cookie is a small text file that is placed on a computer or other device by a web server. It is used toidentify a user or device and to collect information from a web browser.
Cookies typically are assigned to one of four categories, depending on their intended purpose:necessary cookies, performance cookies, functional cookies and cookies for marketing purposes. You can find out more information about cookies, the different types and how they work here, www.allaboutcookies.org.
Devie’s website uses a number of different types of cookies. These are used mainly to learn moreabout how visitors use our website and to recognise visitors when they return. It does not track userswhen they cross to third party websites, does not provide targeted advertising to them, and thereforedoes not respond to Do Not Track (DNT) signals. You can read our full Cookie policy here.
How long we keep personal data for
We will only retain your personal data for as long as necessary to fulfil the purposes we collected itfor, including for the purposes of satisfying any legal, accounting, or reporting requirements and,where required for us to assert or defend against legal claims, until the end of the relevant retentionperiod or until the claims in question have been settled.
To determine the appropriate retention period for personal data, we consider the amount, nature, andsensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of yourpersonal data, the purposes for which we process your personal data and whether we can achievethose purposes through other means, and the applicable legal requirements.
Upon expiry of the applicable retention period we will securely destroy your personal data inaccordance with data protection law or other applicable regulation.
Updating personal data about you
If any of the personal data that you have provided to us changes, for example if you change youremail address or if you wish to cancel any request you have made of us, or if you become aware wehave any inaccurate personal data about you, please let us know by sending an email to team@deviecoach.com. We will not be responsible for any losses arising from any inaccurate,inauthentic, deficient or incomplete personal data that you provide to us.
Your rights
You have various rights with respect to our use of your personal data:
You also have the following legal rights:
If you have provided your consent to the collection, processing and transfer of your personal data, youhave the right to fully or partly withdraw your consent. To withdraw your consent please contact team@deviecoach.com.
Once we have received notification that you have withdrawn your consent, we will no longer processyour information for the purpose(s) to which you originally consented unless there is another legalground for the processing. Withdrawal of consent may result in us no longer being able to provide ourServices to you.
Some of your legal rights are subject to safeguards, limitations or exemptions. To exercise any of yourlegal rights, please contact the Data Protection Officer (email: team@deviecoach.com, address:Dereham Place Flat 9 London, UK EC2A3HJ).
Complaints
If you believe that your data protection rights may have been breached, you have the right to lodge acomplaint with the Information Commissioner’s Office, or to seek a remedy through the courts.
Changes to this Privacy Notice
We will update and change this Privacy Notice from time to time to reflect changes to the way wehandle your personal data or changing legal requirements. Any changes we may make to our PrivacyNotice in the future will be posted on Devie’s website and, where appropriate, notified to you by email.Please check back frequently for changes to this Privacy Notice and each time you give us yourpersonal information.
