Effective from 01-10-2024
Devaito cares deeply about the privacy of its visitors and users. To that end, this Privacy Policy (“Privacy Policy”) describes how Devaito Ltd., together with its affiliated companies worldwide (“Devaito”, “we”, “our”, or “us”), collect, use, and share your Personal Information, as well as an explanation of the data rights you may have in that Personal Information. This Privacy Policy applies to all Devaito users, including unregistered visitors, registered users, and premium users (collectively, “Users”, “you”, or “your”), and to all Devaito services, including our websites (the “Website”), web applications (“Devaito Apps”), mobile applications (“Mobile Apps”), and related services (collectively, the “Services”). This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you may have under other applicable data privacy laws.
Prior to accessing or using our Services, please read this policy and make sure you fully understand our practices in relation to your Personal Information. If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave and discontinue all use of any of our Services. If you have any questions or concerns regarding this policy, please contact us here.
By accessing or using any of our Services, you acknowledge that you have read this Privacy Policy.
To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). We collect Personal Information you provide us, from your use of the Services, and from other sources. Here are the types of Personal Information we collect about you:
Information you provide us. When you register for our Services, sign up for any Devaito events, subscribe to our blog(s) or newsletter(s), purchase and/or register domain names, use any of our Services, and/or when you contact us directly by any communication channel (e.g., Devaito’s support tickets, emails), you may provide us Personal Information, such as name, email address, phone number, payment information (for Users with Paid Services), information you include in your communications with us and with other users on our platform, and Personal Information contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents).
Information we collect when you use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.
Information we collect from other sources. We may receive Personal Information about you from third-party sources, such as: i) security providers, fraud detection and prevention providers, for example, to help us screen out users associated with fraud; ii) social media platforms, when you log-in or sign-up using your social media account, we may receive Personal Information from that service (e.g., your username, basic profile Personal Information) and in some cases, we may collect Personal Information from lead enhancement companies which help us to improve our service offering; iii) advertising and marketing partners in order to monitor, manage and measure our ad campaigns.
We may also collect Personal Information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf.
We also collect information that is provided to us by Devaito job candidates (“Applicants”), when they apply to any of the open positions published on our website, by e-mail, or otherwise (as further described in our Privacy Policy for Job Applicants).
We use your Personal Information for the following purposes:
To provide and operate the Services;
To further develop, customize, expand, and improve our Services, based on Users’ common or personal preferences, experiences, and difficulties;
To provide our Users with ongoing customer assistance and technical support;
To be able to contact our Users with general or personalized service-related notices and promotional messages;
To help us to update, expand, and analyze our records to identify new customers;
To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits;
To analyze our performance and marketing activities;
To create aggregated statistical data and other aggregated and/or inferred information, which we or our business partners may use to provide and improve our respective services;
To provide you with professional assistance;
To enhance our data security and fraud prevention capabilities; and
To comply with any applicable laws and regulations.
We may use techniques like “machine learning” (European law refers to this as “automated decision-making”) to help us improve our services. When we use machine learning, we either: (i) still have a human being involved in the process (and so are not fully automated); or (ii) use machine learning in ways that don’t have significant privacy implications (for example, reordering how applications might appear when you visit the Devaito App Market). We may also use machine learning to help us monitor, identify, and suspend accounts sending spam, or engaging in other abusive or fraudulent activity.
We use your Personal Information for the purposes set out in Section 3 where:
Our use of your Personal Information is necessary to perform a contract or to take steps to enter into a contract with you (e.g. to provide you with a website builder, to provide you with our customer assistance and technical support);
Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; or
Our use of your Personal Information is necessary to support legitimate interests and business purposes (for example, to maintain and improve our Services and the effectiveness of Devaito by identifying technical issues), provided it is conducted in a way that is proportionate and that respects your privacy rights.
We also collect and use Personal Information in order to contact Users and to comply with the laws applicable to us.
As part of the Devaito Services, Devaito provides access to artificial intelligence and machine learning tools (“AI Tools”) designed to assist in building User Platforms by generating content such as text, images, and designs. These AI Tools are used to enhance the overall user experience by providing quick, efficient, and creative solutions for creating and managing websites.
The AI Tools enable Users to input or submit prompts (in the form of text, image, or otherwise) into the AI Services, which then generate content as an output. This output is tailored based on the input provided by the User and is used to enhance the User Platform.
Users are responsible for reviewing all AI-generated content before using, publishing, transmitting, or displaying it in any manner. Users must ensure that they are legally permitted to use the generated content. Devaito does not claim ownership over the content generated through its AI Tools but retains the right to use the input provided by Users to improve its AI models and services.
Devaito does not guarantee the accuracy, completeness, or reliability of the content generated by its AI Tools. The nature of AI technology is such that it is difficult to fully control and predict outputs, and Devaito disclaims all responsibility for any errors, omissions, or inaccuracies in the generated content.
By using the AI Tools, you grant Devaito a non-exclusive, transferable, sub-licensable, royalty-free, worldwide license to use, reproduce, distribute, prepare derivative works of, and display your input and any AI-generated output solely for the purposes of improving the AI Tools, Services, and user experience. This license does not grant Devaito any ownership rights over your input or the content generated specifically for you but allows Devaito to enhance its services continually.
Devaito is committed to maintaining the privacy and security of your data. Any personal information used in conjunction with the AI Tools is processed in accordance with our Privacy Policy. We employ industry-standard measures to protect the confidentiality and integrity of your data while utilizing AI tools. However, due to the nature of AI technology, we advise users to avoid including sensitive personal information in the input provided to the AI Tools.
By using the AI Tools provided by Devaito, you acknowledge and accept that:
We may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances:
Third Party Service Providers: Devaito has partnered with a number of selected service providers, whose services and solutions complement, facilitate, and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”).
Devaito may share the following categories of Personal Information with Third Party Service Providers for a business purpose:
– Identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.
– Commercial Personal Information, for example, Personal Information regarding products or services purchased, obtained, or considered.
Devaito may disclose or otherwise allow access to any categories of your Personal Information described in this Privacy Policy pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.
Devaito may share any categories of your Personal Information described in this Privacy Policy if we believe in good faith that this will help protect the rights, property, or personal safety of Devaito, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.
We may share your Personal Information internally within our family of companies, for the purposes described in this Privacy Policy. For example, we may share your Personal Information with our subsidiaries in the course of facilitating and providing you (and your Users-of-Users) with our Services. Sharing Personal Information by Devaito subsidiaries and affiliated companies in the European Union, the United Kingdom, and Switzerland with Devaito’s subsidiaries located outside these regions will only take place under an approved transfer mechanism, such as the relevant Standard Contractual Clauses.
In addition, should Devaito or any of its affiliates undergo any change in control, including by means of merger, acquisition, or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event.
The Devaito Services enable you, through different techniques, to engage and procure various third-party services, products, and tools for enhancing your web or mobile sites, including, without limitation, applications and widgets offered to you by third parties through the Devaito Website, eCommerce payment providers, third-party designers who may assist you with your website, etc. (collectively, “Third Party Services”). If you choose to engage with such Third Party Services, they may have access to and process Personal Information of your Users-of-Users collected through your web or mobile sites. For example:
a) Framed Pages: Our Services may enable you to integrate Third Party Services directly into your web or mobile sites, such as via page framing techniques to serve content to or from Third Party Services or other parties (“Frames”). In these circumstances, the Third Party Services may collect Personal Information from your Users-of-Users.
b) App Market Developers: We allow third-party developers (“Third Party Developer(s)”) to develop and offer their own applications via the Devaito App Market (“Third Party App(s)”) to Users, which you may integrate into your web or mobile sites. Each Third Party Developer is bound by the Devaito App Market Partner Agreement, which, among other things, restricts the ways in which such developers may access, store, share, and use the Personal Information you and/or your Users-of-Users provide to them.
c) Social Media Features: Our Services may enable you to integrate certain Social Media features, widgets, and single sign-on features, such as “Facebook Connect,” or “Google Sign-in” (“Social Media Features”) into your web or mobile sites. These Social Media Features may collect certain Personal Information from your Users-of-Users such as identifiers, including name, alias, unique personal identifier, online identifier, internet protocol address, email address, or other similar identifiers. Social Media Features are hosted either by a third party or directly on our Services.
Please note that in the examples listed above in this Section 4.5, Devaito merely acts as an intermediary platform allowing you to procure the services of such Third Party Services (including, but not limited to, Third Party Developers, Third Party Apps, and Social Media Features) with which you are interacting directly, and at your discretion. In this respect, Devaito acts as a service provider to you, disclosing information to the Third Party Services on your behalf. Devaito will share your Users-of-Users’ Personal Information with Third Party Services only upon your direction or with your permission and is not, and shall not be, in any way responsible for such Third Party Services processing of such Personal Information, or liable with respect thereto.
Devaito does not control and is not responsible for the actions or policies of any Third Party Service, and your use of any Third Party Service is at your own risk. We encourage you to review any privacy policy accompanying a Third Party Service and ask such Third Party Service for any clarifications you may need before deciding to install and/or use their services.
Devaito processes data about individuals across the world and may transfer your Personal Information outside of your country. Your security, privacy, and confidentiality are our top priority, and that's why Devaito conducts a vetting process that includes an assessment of the privacy laws in those countries to validate they have strong data protection laws.
User's personal information is controlled by Devaito Ltd. in [Your Location], which [relevant authority] considers as a country offering an adequate level of protection for the Personal Information of E.U. Member State residents.
If you are in Europe, the U.K., or Switzerland, when we transfer your Personal Information to a location outside of Europe, We will make sure that (i) there is a level of protection deemed adequate by the European Commission or (ii) that the relevant Standard Contractual Clauses are in place, or (iii) we comply with Data Privacy Framework as applicable to data transfers to the United States and specified in clause 5.4 below, or (iv) we use another legally recognized transfer mechanism in the applicable jurisdiction.
Devaito’s data storage providers are contractually committed to protect and secure your data. Among other things, Devaito will ensure that there is the adequate level of protection or that relevant Standard Contractual Clauses are in place for the international transfer of our EU users’ data. When Devaito transfers E.U. Personal Information to a third country that the European Commission did not find will adequately protect your information, Devaito ensures that it has taken additional measures to comply with the European data protection laws.
Devaito and its covered entities comply with the Data Privacy Framework (“DPF”) that embeds the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the relevant authorities regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom, and Switzerland to the United States. Devaito has certified to the relevant authority that it adheres to the Data Privacy Framework Principles. If there is any conflict between the terms in this Policy and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern.
To learn more about the Data Privacy Framework Program, please visit the official website, and to view our certification, please click here.
Devaito may share personal information with third parties under certain circumstances described in this Policy, subject to obligations under the Data Privacy Framework Principles extend to third parties acting as agents who help us run our business and provide services, and Devaito remains liable should a third party acting as our agent process personal information subject to this Policy in a manner inconsistent with this Policy, except where Devaito is not responsible for the event giving rise to the damage.
In compliance with the Data Privacy Framework Principles, Devaito commits to resolve complaints about our collection or use of your personal information. E.U., UK, and Swiss individuals with inquiries or complaints regarding our Data Privacy Framework policy should first contact us at: [Your Privacy Email].
Devaito commits to cooperate and comply respectively with the advice of the panel established by the relevant data protection authorities with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.
Devaito has further committed to refer unresolved Data Privacy Framework complaints to an alternative dispute resolution provider located in the United States. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider for more information or to file a complaint. The services are provided at no cost to you.
If you have such an unresolved complaint, under the recourse mechanism, you may contact the applicable EU Data Protection Authorities (free of charge). Devaito commits to cooperate with the DPAs and comply with the advice given by such authorities.
If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, you may, under certain conditions described on the Data Privacy Framework website, invoke binding arbitration when other dispute resolution procedures have been exhausted.
Devaito may collect, store, and process certain Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, each of our Users is able to import their email contacts from third-party services like Gmail or otherwise collect and manage contacts via their User Website. Such contacts are then stored with Devaito, on the User’s behalf.
For such purposes, Devaito serves and shall be considered as a “Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Union General Data Protection Regulation (“GDPR”)) of such Users-of-Users Information.
The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.
The Processing of the Users-of-Users’ Personal Information shall take place within the territory of the European Union, Israel, or a third country, territory, or one or more specified sectors within that third country of which the European Commission has decided that it ensures an adequate level of protection and such processing and transfer will be in accordance with the Data Processing Addendum – Users (“DPA”). Any transfer to and Processing in a third country outside the European Union that does not ensure an adequate level of protection according to the European Commission, shall be conducted under an approved transfer mechanism, as detailed in the DPA.
You are responsible for the security, integrity, and authorized usage of Personal Information about Users-of-Users and for obtaining consents, permissions, and providing any required data subject rights and fair processing notices required for the collection and usage of such Personal Information.
Devaito cannot provide legal advice to Users or their Users-of-Users, however, we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites in accordance with any applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they understand and, to the extent required by applicable law, consent to them.
For more information on how Users-of-Users Personal Information may be handled by Devaito (which may be relevant for any specific notice you provide to and/or consent you obtain from your Users-of-Users), please see Sections 4, 12, and 13.
If you are a visitor, user, or customer of any of our Users, please read the following: Devaito has no direct relationship with Users-of-Users whose Personal Information it processes. If you are a visitor, user, or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to request to access, correct, amend, or delete inaccurate Personal Information processed by Devaito on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If Devaito is requested by our Users to remove any Users-of-Users’ Personal Information, we will respond to such requests in a timely manner upon verification and in accordance with applicable law (for example, thirty (30) days under the GDPR). Unless otherwise instructed by our User, we will retain their Users-of-Users’ Personal Information for the period set forth in Section 12 below.
We do this solely on our users’ behalf, and at their direction.
Our users are solely responsible for their users-of-users' information, including for its legality, security, and integrity.
Devaito has no direct relationship with any of its users’ users. If you are a user-of-user, please contact the Devaito site owner directly.
We and our Third Party Service Providers use cookies and other similar technologies (“Cookies”) in order for us to provide our Service and ensure that it performs properly, to analyze our performance and marketing activities, and to personalize your experience.
You can learn more about how we use cookies and similar technologies and how you can exercise control over them in our Cookie Policy.
Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
These technologies are used mostly for stability, security, functionality, performance, and advertising purposes.
We may use your Personal Information to send you promotional content and messages by e-mail, text messages, notifications within our platform, marketing calls, and similar forms of communication from Devaito or our partners (acting on Devaito’s behalf) through such means.
If you do not wish to receive such promotional messages or calls, you may notify Devaito at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
Devaito may also contact you with important information regarding our Services, or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Website; or notify you of material changes in our Services.
It is important that you are always able to receive such messages. For this reason, you are unable to opt-out of receiving such Service and Billing Messages unless you are no longer a Devaito User (which can be done by deactivating your account).
We may also contact you with service and billing-related messages and content. You will not be able to opt-out of receiving such messages.
Devaito believes that it is imperative that all Devaito users have control over their Personal Information. Therefore, depending on the way you use the Devaito Services, you may have the right to request access to, receive a copy of, update, amend or delete, port certain Personal Information to another service, restrict, or object to certain uses of your Personal Information (for example, for direct marketing purposes). Further, when we rely on your consent for processing of your Personal Information (for instance, for direct marketing) you can withdraw your consent at any time, and such withdrawal will take effect from thereon.
Devaito will not charge you more if you exercise any of these rights and will continue to provide you with the same level of service.
If you are a Devaito user, you can access and correct a lot of your Personal Information directly through your account, or via online forms Devaito makes available to you (as detailed below). You can also exercise your rights by sending your request to privacy@devaito.com, mailing it to Devaito Ltd, [Your Address], or reaching out to our customer care department. When we receive your right request, we may take steps to verify your identity before complying with the request to protect your privacy and security.
Before fulfilling your request, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g., if your request is unfounded or excessive).
You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).
If you are a Devaito User, and you wish to receive a copy, access, and/or request us to make corrections to the Personal Information that you have stored with us (either yours or your Users-of-Users’), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, please follow the instructions provided in these Help Center articles: “Retrieving Your Devaito Account Data” or "Permanently Deleting Your Devaito Account”. You can also mail your request to Devaito Ltd, [Your Address]. We will make reasonable efforts to honor your request promptly (unless we require further information from you in order to fulfil your request), subject to legal and other permissible considerations.
Please note that permanently deleting your Devaito account erases all of your Personal Information from Devaito's databases. After completing this process, you can no longer use any of your Devaito Services, your account and all its data will be removed permanently, and Devaito will not be able to restore your account or retrieve your data in the future. If you contact our support channels in the future, the system will not recognize your account and support agents will not be able to locate the deleted account.
Just reach out to us by e-mail, mail, or through our customer care team, or, when available, fill out our dedicated form.
You may also correct and/or update your Personal Information through your user account, if you have one.
You can also delete your Personal Information by deleting your entire account. We will respond to your requests within a reasonable timeframe.
If you have any questions or concerns about our collection, use, or disclosure of Personal Information, or if you believe that we have not complied with this Privacy Policy or applicable data protection laws, please contact us – our details are set out at the end of this Privacy Policy.
Our Data Protection Officer team will investigate the complaint and determine whether a breach has occurred and what action, if any, to take. We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly and in accordance with applicable law.
You can file a complaint with your local supervisory authority for data protection at any time, however, we recommend that you contact us first so we can try to resolve it.
We may retain your Personal Information (as well as your Users-of-Users’ Personal Information) for as long as your User Account is active, as indicated in this Privacy Policy, or as otherwise needed to provide you with our Services.
We may continue to retain your Personal Information after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements, and/or protect our legitimate interests.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of such data, the potential risk of harm from unauthorized use or disclosure of such data, the purposes for which we process it, and the applicable legal requirements.
Devaito has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic, and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.
Regardless of the measures and efforts taken by Devaito, we cannot and do not guarantee the absolute protection and security of your Personal Information, your Users-of-Users’ Personal Information, or any other information you upload, publish or otherwise share with Devaito or anyone else. We encourage you to set strong passwords for your User Account and User Website, and avoid providing us or anyone with any sensitive Personal Information of which you believe its disclosure could cause you substantial or irreparable harm.
Furthermore, because certain areas on our Services are less secure than others (for example, if you set your Support forum ticket to be “Public” instead of “Private”, or if you browse to a non-SSL page), and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.
If you have any questions regarding the security of our Services, you are welcome to contact us here.
However, as we can’t guarantee absolute protection – we encourage you to be careful, set a strong password for your account, and avoid submitting any sensitive information which, if exposed, could cause you major harm.
Our Services may contain links to other websites or services. We are not responsible for such websites’ or services’ privacy practices. We encourage you to be aware when you leave our Services and to read the privacy statements of each and every website and service you visit before providing your Personal Information. This Privacy Policy does not apply to such linked third-party websites and services.
Devaito welcomes all qualified Applicants to apply to any of the open positions published on our website, by sending us their contact details, CV, and other relevant information via the application form on our Website. Devaito will handle this data in accordance with our Privacy Policy for Job Applicants.
We will use such Personal Information solely for our internal recruitment, employment, and business purposes.
Our Services offer publicly accessible blogs, communities, and support forums. Please be aware that any Personal Information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blogs, communities, or forums, feel free to contact us here. In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third-party application to post a comment (e.g., the Facebook social plugin application) while logged into your related profile with such third party, you must log in into such application or contact its provider if you want to remove the Personal Information you posted on that platform.
In any event, we advise against posting any Personal Information (via any means) you don’t wish to publicize.
If you upload any user content to your User Account or post it on your User Website and provide it in any other way as part of the use of any Service, you do so at your own risk.
We have put adequate security measures in place to protect your Personal Information. However, we cannot control the actions of other Users or members of the public who may access your User Content, and are not responsible for the circumvention of any privacy settings or security measures you or we may have placed on your User Website (including, for instance, password-protected areas on your User Website). You understand and acknowledge that, even after its removal by you or us, copies of User Content may remain viewable in cached and archived pages or if any third parties (including any of your Users-of-Users) have copied or stored such User Content. To clarify, we advise against uploading or posting any information you do not wish to be public.
We may update this Privacy Policy as required by applicable law, and to reflect changes to our Personal Information collection, usage, and storage practices. If we make any changes that we deem as “material” (in our sole good faith discretion), we will notify you (using one of the notification methods set forth in Section 15.3 of the Terms of Use) prior to the change becoming effective. In relation to any updated Privacy Policy, we will, as required by applicable law, notify you, seek your consent and/or take any other measures. We encourage you to periodically review this page for the latest Information on our privacy practices. Unless stated otherwise, our most current Privacy Policy applies to all information that we have about you and your Users-of-Users, with respect to our Website, Devaito Apps, Mobile Apps, and other Services.
This Privacy Policy was written in English, and may be translated into other languages for your convenience. You may access and view other language versions by changing your Devaito Website language settings. If a translated (non-English) version of this Privacy Policy conflicts in any way with its English version, the provisions of the English version shall prevail.
Translated (non-English) versions of these terms are provided for convenience only.
If you have any questions about this Privacy Policy or wish to exercise any of your rights as described in Sections 9 or 10, please refer to those sections or contact the Data Protection Officer team via email at dpo@devaito.com. We will attempt to resolve any complaints regarding the use of your Personal Information in accordance with this Privacy Policy.
You may also contact us by mail at:
Devaito Ltd.: [Your Address]
For the purposes of GDPR (Article 27), you may contact our EU representative at Devaito Online Platforms Limited, [EU Address], Ireland.
For the purposes of UK GDPR (Article 27), you may contact our UK representative at Devaito (UK) Limited, [UK Address], United Kingdom.
This section of our Privacy Policy details what Personal Information we collect about you under U.S. applicable privacy laws and regulations, the sources of the Personal Information, the purposes of use and disclosure, and the categories of third parties that may receive that Personal Information. The information in this section applies to you if you are a U.S. resident in a state with an applicable privacy law or regulation.
Please read this section in combination with the other sections of this Privacy Policy for a complete understanding of how we collect, use, and disclose your personal information.
Here is a brief overview of your rights:
Right to Delete Your Information: Upon your request, we will delete the personal information we have collected from you, subject to certain legally permissible exceptions.
Right to Know and Access Your Personal Information: You have the right to ask us to confirm whether we process your personal information and for a copy of the personal information we maintain about you.
Right to Correct Inaccurate Personal Information: You have the right to request that we correct inaccurate personal information about you. Some personal information can be directly changed or corrected by you through our apps and websites.
Right to Opt Out of the Sale of Your Personal Information: You can tell us not to "sell" your personal information according to applicable law, even though we don't technically sell your information in the traditional sense. We may share certain categories of Personal Information with our Third Party Service Providers. However, the current regulation uses a very broad definition of “Sale.”
Right to Limit Use of Your Personal Information for Targeted Advertising: You can ask us not to use or disclose your personal information for targeted advertising. Just visit our Do Not Sell or Share My Personal Information page. You also can use the Global Privacy Control to signal your opt-out preference. To learn more about the GPC, please visit https://globalprivacycontrol.org.
You may exercise any of the rights described above by submitting a request by email to privacy@devaito.com or by mail to Devaito, [Your Address].
When you submit a request, we will usually ask you to provide an email address to verify your identity and prevent fraud.
No Discrimination. Devaito does not discriminate against any individual for exercising their rights under this section.
If we deny your request or cannot fulfill it, you may appeal our decision by contacting us as described in this Privacy Policy to ask us to review your request again. Your communication should include “Appeal” in the subject line.
Categories of Information: In the last 12 months, we collected the following categories of personal information (the same categories we collect from all users globally):
Sources of Information: We collect Personal Information from various sources, including information you provide to us, information collected through your use of the Services, and information obtained from third-party sources.
Disclosure of Information for Business Purposes: In the past 12 months, we may have disclosed each of the categories of personal information listed above to our affiliates, Third Party Service Providers, social media platforms, advertising partners, analytics partners, and promotional partners.
Sales or Sharing of Your Information: We may have "sold" or shared the categories of Personal Information listed above in the past 12 months to our affiliates, Third Party Service Providers, promotional partners, advertising partners, analytics partners, and social media platforms.
Retention of Information: We retain your Personal Information for the time period reasonably necessary to achieve the purposes described in this Privacy Policy, or any other notice provided at the time of collection. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of such data, the potential risk of harm from unauthorized use or disclosure of such data, the purposes for which we process it, and the applicable legal requirements.