Want to read the full policy? It can be found below this quick summary.
Looking for the quick summary? Please, read on:
- Use of user-friendly language. We use plain language to make our policy easy to understand.
- Easy navigation. Get easy and quick access to our policy to find what matters most to you.
- How we use data collected online. Clear and simple explanation of how we collect data online and how and why we use it for marketing purposes.
- Control your own information. How we keep your information secure and how you can access to it.
Chris & Teija DeVere
This policy will be effective starting on May 25, 2018
What this policy covers
Your privacy is important to us. We want to be transparent about how we collect, use, and share information about you. This user-friendly policy intends to help you understand why and how we collect data online.
What information do we collect about you?
Information you provide to us:
We collect information about you when you input it into our website, social media, email exchange, or otherwise provide directly to us.
- Customer File Information: We collect information about you when you sign up for our services as a customer. This information contains but is not limited to: name, address, e-mail address, phone number, website, domains, social media accounts
- Content you provide through our website: This content includes websites owned or operated by us. For example, you provide content to us when you participate in interactive features, surveys, promotions, contests, activities, events, or provide feedback.
- Payment Information: In some cases, we collect certain payment and billing information when you purchase services or products on our website. You might provide payment information, such as payment card details, which we collect via secure payment processing services.
Information we collect automatically when you use the services:
We collect information about you when you use our services, including browsing our websites and taking certain actions within the services.
- Your use of the services: We keep track of certain information about you when you visit and interact with any of our online services. This information includes but is not limited to: links you click on our websites, how you interact with others through our services, attachments and files you upload to our services.
- Device and connection information: We collect information about your computer, phone, tablet, or other devices you use to access the services. This device information includes your connection type and settings when you access, or use our services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, or country preference in order to approximate your location to provide you a better service experience. How much of this information we collect depends on the type of the device you use to access the services.
How we use information we collect
How we use information we collect depends in part on which services you use, how you use them, and on preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.
- To provide the services and personalize your experience: We use information about you to provide the services to you, including to process transactions with you, provide customer service, and operate and maintain the services.
- For research and development: We are always looking for ways to make our services better, more customer friendly and useful to you. We use collective learnings about how people use our online services and feedback to improve our services.
- To communicate with you about the services: We use your contact information to send transactional communications via email and within the services, including confirming your transactions and purchases, responding to your comments, questions, and requests, providing customer service, sending you updates and technical notices, security alerts, and administrative messages.
- To market, promote, and drive engagement with the services: We use your information about how you use our services to send promotional communications that may be of specific interest to you. These promotional communications may be emails, ads of different platforms, such as Facebook and Google.
- Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, and to analyze, repair, and improve our services.
- To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests, and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
- With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the service, with your permission.
- Legal bases for processing (for EEA users): If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the service you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the service, including to operate the services, provide customer support, and personalized features to protect the safety and security of the services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object that use though, in some cases, this may mean no longer using the services.
How we share information we collect
We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our services.
- Service providers: We work with third-party service providers to provide website development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information.
- Links to third-party sites: Our websites may include links that direct you to other websites or services whose privacy practices may differ from ours. Your use of and any information you submit to any of those third-party sites is governed by their privacy policies, not this one.
- With your consent: We share information about you with third parties when you give us consent to do so. For example, we may display personal testimonials on our public websites. With your consent, we may post your name alongside the testimonial.
- Compliance with enforcement requests and applicable laws; Enforcement of our rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect DeVere Marketing, our customers, or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of a person.
How we store and secure information we collect
Information storage and security
We use data hosting service providers in Finland and United States to host the information we collect, and we use technical measures to secure your data. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the internet, we cannot guarantee that data, during transmissions through the internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion of other. We will respond about this within a reasonable timeframe.
How long we keep information
How long we keep information we collect about you depends on the type of information. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
How to access and control your information
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations. We will respond to requests about this within reasonable timeframe.
You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. For all requests, you may contact us as provided in the Contact Us section below to request assistance.
Your request and choices may be limited in certain cases: for example, if filling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.
- Access and update your information: Contact us to update or access your customer information, and to make updates, for example, address change.
- Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don’t have the appropriate rights to do so. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is a delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request in honored or the dispute is resolved, provided your administrator does not object to do so.
- Opt out on communications: You may opt out of receiving promotional communications from us by contacting us as provided below. We will remove your contact information from our promotional email list.
- Turn off cookie controls: Relevant browser-based cookie controls are described in our Cookies & Tracking Notice.
How we transfer information we collect internationally
International transfers of information we collect
We collect information globally and primarily store that information in Finland. We may transfer, process and store your information outside of your country of residence to where ever we DeVere Marketing or our third-party service providers operate for the purpose of providing you the services. Whenever we transfer your information, we take steps to protect it.
Privacy Shield Notice
Under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, we are responsible for the processing of information about you we receive from the EU and Switzerland and onward transfers to a third party acting as an agent on our behalf. We comply with the Privacy Shield Principles for such onward transfers and remain liable in accordance with the Privacy Shield Principles if third-party agents that we engage to process such information about you on our behalf do so in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.
To learn more about the Privacy Shield Program, and to view our certification, please visit our public Privacy Shield Listing.
Other important privacy information
Notice to end users
Where the services are made available to you through an organization (e.g. your employer), that organization is the administrator of the services and is responsible for the end-users and/or service sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy.
Your information is controlled by DeVere Marketing. If you have questions or concerns about how your information is handled, please direct your inquiry to DeVere Marketing as set forth below.
DeVere Marketing Oy
Ajurinkatu 2, 3. Krs