Privacy policy

Last Updated: 18th September 2023

1. Introduction
   
   1.1 Overview
   
   Deviceology Ltd (“Deviceology,” “we,” “us,” or “our”) is committed to safeguarding the privacy and personal information of our users. This Privacy Policy sets forth the principles and procedures we employ to ensure the secure and ethical collection, use, storage, and dissemination of your personal data when you engage with our websites, mobile applications, and any other services we provide (collectively, “Services”).
   
   1.2 Compliance and Governance
   
   We continuously review our data protection obligations to align with globally accepted standards and legislations, including but not limited to:
   General Data Protection Regulation (EU GDPR) for residents of the European Union
   General Data Protection Regulation (UK GDPR) for residents of the United Kingdom
   Personal Information Protection and Electronic Documents Act (PIPEDA) for Canadian residents
   California Consumer Privacy Act (CCPA) for California residents
   Utah Consumer Privacy Act (UCPA) for Utah residents
   Virginia Consumer Data Protection Act (VCDPA) for Virginia residents
   Lei Geral de Proteção de Dados (LGPD) for Brazilian residents
   Act on the Protection of Personal Information (APPI) for residents of Japan
   Australian Privacy Principles (APPs) under the Privacy Act 1988 for Australian residents

2. Scope and Applicability
   
   2.1 General Scope
   This Privacy Policy applies to all individuals who use our Services, as well as entities who are data controllers and processors under the terms of this policy. This includes, but is not limited to:
   
   Visitors and users of our website
   Customers and clients
   Employees and affiliates
   Contractors and service providers
   Partners and third parties
   
   2.2 Data Controller and Processor
   For the purposes of UK GDPR, EU GDPR, and other relevant data protection laws, Deviceology Ltd acts as the Data Controller. We may also act as a Data Processor when processing data on behalf of a Data Controller.

3. Consent and Withdrawal
   
   3.1 Obtaining Consent
   Your engagement with our Services signifies your consent to this Privacy Policy. You may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice. Withdrawal of consent will not affect the validity of the data processing carried out before the withdrawal.
   
4. Jurisdiction-Specific Provision
   
   4.1 For EU Residents: GDPR Provisions
   Contact Authority: European Data Protection Board
   Contact Details: Website, Tel: +32 (0)2 807 37 00
   
   4.1.1 Data Subject Rights
   Under the GDPR, EU citizens have several rights, including the right to access, rectify, or erase their personal data. Data subjects also have the right to data portability and the right to object to the processing of their data.
   
   4.2 For UK Residents: UK GDPR Provisions
   Contact Authority: Information Commissioner’s Office (ICO), United Kingdom
   Contact Details: Website, Tel: 0303 123 1113
   
   4.2.1 Data Subject Rights
   Similar to the GDPR, UK residents have various rights including the right to be informed, the right to access, and the right to rectification. Data subjects may also object to data processing and have a right to data portability.
   
   4.3 For Canadian Residents: PIPEDA Provisions
   Contact Authority: Office of the Privacy Commissioner of Canada
   Contact Details: Website, Tel: 1-800-282-1376
   
   4.3.1 Transparency and Accountability
   Under PIPEDA, organizations must be transparent about their data collection practices and must take accountability for the data they hold. This includes implementing strong security measures and facilitating consumer rights to access and correct their data.
   
   4.4 For California Residents: CCPA Provisions
   Contact Authority: California Attorney General’s Office
   Contact Details: Website, Tel: (916) 210-6183
   
   4.4.1 Non-Discrimination
   Under the CCPA, consumers have the right to equal services and prices, even if they exercise their privacy rights. Discrimination against consumers who opt-out of data sales is prohibited.
   
   4.5 For Utah Residents: UCPA Provisions
   Contact Authority: Utah Division of Consumer Protection
   Contact Details: Website, Tel: (801) 530-6601
   
   4.5.1 Data Security
   Under the UCPA, organizations are obliged to implement reasonable security measures to protect personal data and must inform consumers of any data breaches.
   
   4.6 For Virginia Residents: VCDPA Provisions
   Contact Authority: Virginia Office of the Attorney General
   Contact Details: Website, Tel: (804) 786-2042
   
   4.6.1 Sensitive Data
   Under the VCDPA, organisations must seek explicit consent for processing sensitive data, which includes data like religious beliefs, sexual orientation, and genetic data.
   
   4.7 For Brazilian Residents: LGPD Provisions
   Contact Authority: National Data Protection Authority (ANPD)
   Contact Details: Website, Tel: +55 61 3445-9447
   
   4.7.1 International Transfers
   Under LGPD, international data transfers are only permitted under specific conditions, including adequacy decisions or standard contractual clauses.
   
   4.8 For Japanese Residents: APPI Provisions
   Contact Authority: Personal Information Protection Commission, Japan
   Contact Details: Website, Tel: +81-3-6457-9849
   
   4.8.1 Notification of Purpose
   Under APPI, data subjects must be informed of the purpose of data collection and usage. Data can only be used within the scope of the stated purpose.
   
   4.9 For Australian Residents: APPs Provisions
   Contact Authority: Office of the Australian Information Commissioner (OAIC)
   Contact Details: Website, Tel: +61 1300 363 992
   
   4.9.1 Complaints
   Under the APPs, Australian residents have the right to file a complaint with the OAIC if they believe their privacy has been breached.
   
   For all jurisdiction-specific queries, please reach out to our Data Protection Officer at DPO@letsdeploy.ai.
   
5. Information We Collect
   
   5.1 Personal Information
   5.1.1 Identifiers: Such as your name, email, phone number, and social security number.
   
   5.2 For Businesses
   5.2.1 Commercial Data: Business name, VAT number, and business type.
   
   5.3 Technical Data
   5.3.1 Log and Usage Data: Information gathered from your use of our Services, such as IP address and browser type.
   
   5.4 Special Category Data
   5.4.1 Biometric Information: Fingerprints or voice prints, where applicable.
   
   5.5 Financial Information
   5.5.1 Payment Information: Credit card details and billing addresses.
   
   5.6 Compliance Data
   5.6.1 Legal Requests: Any data required to be kept for compliance with legal obligations.
   
6. How We Use Your Information
   
   6.1 Operational Uses
   To provide, maintain, and improve our Services
   To manage your account and send you service updates
   To respond to your inquiries
   
   6.2 Analytical Uses
   To understand how you interact with our Services
   To develop new products or services
   To carry out data analysis and audits
   
   6.3 Marketing and Promotional Uses
   To send you marketing communications
   To assist in advertising campaigns
   
   6.4 Legal and Regulatory Uses
   To comply with legal obligations and law enforcement requirements
   To resolve disputes and enforce our agreements
   
7. Data Security Measures
   
   Your data is stored and processed in secure environments that are protected against unauthorised access, modification, or disclosure. We adhere to ISO/IEC 27001:2022 standards for Information Security Management Systems and apply rigorous access controls, encryption techniques, and regular security audits.
   
8. Policy Modifications and Updates
   
   We reserve the right to update this Privacy Policy to adapt to new technologies, practices, or changes in legal regulations. Any updates will be effective immediately upon the posting of the revised policy.
   
9. Contact Us
   
   For any questions, concerns, or complaints, please contact our Data Protection Officer at DPO@deviceology.net