Dev-Byrne & Company Privacy Policy

Dev-Byrne & Company (“Dev-Byrne,” “our,” or “we”) is committed to safeguarding the privacy of our website visitors, customers, strategic partners, and others. We respect and value the individual privacy of our website visitors, clients, strategic partners, and others. This Privacy Policy (the “Policy”) explains what personal information we collect, how we use that information, and your privacy rights.

Introduction

This policy applies where we are acting as a data controller concerning the personal information of our website visitors, clients, employees, strategic partners, and others; in other words, where we determine the purposes and means of the processing of that personal information. For purposes of this Privacy Policy, the term “personal information,” as identified below, refers to information that identifies an individual or relates to an identifiable individual. The types of personal information collected and used by Dev-Byrne are identified below. Non-personal information is information that does not permit direct association with an individual. Dev-Byrne may collect, use, transfer and disclose non-personal information for any purpose.

Data Privacy Officer

Dev-Byrne has a designated Data Privacy Officer responsible for our compliance with and enforcement of this Policy. Dev-Byrne educates its employees that will be in possession of personal information concerning compliance with this policy and undertakes self-assessment to assure compliance. Questions or complaints regarding this Policy and any privacy-related issue should be submitted by mail or email to the attention of the Data Privacy Officer, at the address found at the end of this policy.

Website Visitors: Personal Information Collected

Dev-Byrne collects personal information about a visitor to our website only when the visitor chooses to provide such data. Dev-Byrne collects personal data that you provide through registration on our website, subscribing to our blog, responding to a survey, filling out a form, or by communicating with a Dev-Byrne representative by telephone, e-mail or chat. When ordering or registering on our site you may be asked to enter your name, e-mail address, mailing address or phone number. On certain pages, for example, a visitor can choose to provide his/her personal information such as name, company, address, phone number, and email address. By supplying such information to Dev-Byrne, a visitor can request details about our products and services.

Dev-Byrne uses the personal information we collect to respond to informational requests about our company, products, and services, register your company on our sites and identify you as a registered user, and to analyze trends and statistics regarding visitors’ use of our sites. The information collected may be used in one or more of the following ways: to personalize your experience, to improve our website, to improve customer service, to process transactions, to administer a contest, or to send periodic emails, promotions, surveys, and other kinds of communications to you. If you choose to visit our website, your visit and any dispute over privacy are subject to this Policy and our website terms of use.

Clients: Personal Information Collected

Dev-Byrne receives from customers to provide our services and solutions, information which may be considered personal data. The information may be collected by members of our marketing, sales, operations, professional services, client support, and administrative teams. This information may be received directly from the customer and or through the processing of customer invoices, call detail records and from the shipping of wireless devices on behalf of customers. The type of information received may be one or more of the following: Employee Id, Name, Title, Department, Cost Center, Email Address, Phone Numbers and Mailing Addresses. This information is used solely to provide contracted services.

To deliver Dev-Byrne services, we receive employee information from our clients that may contain one or more of the following data elements which are considered personal information: employee Id, name, title, location, corporate e-mail address, department/cost center, phone numbers, and corporate address.

Strategic Partners and Others: Personal Information Collected

Dev-Byrne collects personal information from our strategic partners and others. The information may be collected by members of our marketing, sales, operations, professional services, client support, and administrative teams. The type of information collected includes but is not limited to: contact information (name, address, telephone numbers, e-mail address, company, etc.), user preferences, and event and conference participation information.

Dev-Byrne uses the personal information it collects to respond to requests for information about our company, products, and services, to manage your participation in our events, conferences, surveys, and other promotions and to enable you to communicate with Dev-Byrne through our blogs, online forums, social media pages, and other interactive media.

Use of Personal Information

Dev-Byrne may use personal information in various ways. Among other things, we use personal information to: provide products and services to you and respond to other requests that you have; update and expand our records with new information and analyze our records to identify potential customers; evaluate the frequency, duration, and patterns of usage of our website to improve the user experience; and contact you with tailored advertising for products and services that may be of interest to you. When required by applicable law (e.g., the GDPR as applied to Data Subjects in the EU), we will only send you marketing information by e-mail if you expressly provide to us consent for us to do so. If necessary, we also may use your data to comply with applicable laws and for our legitimate purpose of protecting our legal rights, for example, in connection with legal claims, compliance, regulatory, or investigative purposes.

Website Cookies

Dev-Byrne uses cookies to improve the visitor’s online experience and to allow Dev-Byrne to better provide support to its website visitors. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. We use cookies for the following purposes:

A) To identify you when you visit our website and as you navigate our website.

B) To help us to determine if you are logged into our website.

C) To store information about your preferences and to personalize the website for you.

D) As an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally.

E) To help us to display advertisements that will be relevant to you.

F) To help us to analyze the use and performance of our website and services.

Disclosure to Third Parties

Dev-Byrne does not sell trade or rent personal data to third parties; however, Dev-Byrne reserves the right to use third-party contractors to supplement workforce activities. Dev-Byrne will only disclose information to unaffiliated third parties if required by law or authorized individuals of the respective customer. In the event, Dev-Byrne uses a third party or must disclose information to a third party we will have in place a data processing agreement acknowledging that the personal data will only be used for the intended purpose and safeguarded in a manner consistent with this Policy. Dev-Byrne remains liable under the Privacy Policy if its onward transfer recipients process personal data in a manner inconsistent with the Privacy Policy unless Dev-Byrne proves that it is not responsible for the event giving rise to the damage.

Security

Dev-Byrne uses administrative, organizational, technical, and physical safeguards to protect your data. Dev-Byrne’s hosted solutions maintain personal data on secure servers located in secure data centers. Dev-Byrne will take reasonable precautions to protect personal data in its possession from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Personal data stored on these servers are protected by firewalls restricting access and requires login ids and passwords to access the information. Dev-Byrne limits access to personal data to those persons in our organization or contractor’s organization that have a specific business purpose for maintaining and processing such personal data. Any individuals who are granted access to personal data will have been made aware of their responsibilities to protect the security, confidentiality, and integrity of that data and will have been provided training and instruction on how to do so. We require our partners to use appropriate security measures.

International Data Transfer

Dev-Byrne delivers services globally and has employees in many locations, enabling us to deliver an effective local service and deliver cost savings to clients. As a standard, our services may be delivered by employees based in any of our locations which include the United States, the European Union, India, and China. Dev-Byrne will hold the primary contact details for every client on our central database hosted in the USA.

EU data protection legislation requires Dev-Byrne’s clients to make a decision on their international data protection preferences and to communicate this requirement. As such the locations that a client’s data may be hosted, managed and accessed in will reflect the client contract terms agreed.

Retention of Personal Data

Dev-Byrne will retain personal data while we have a justifiable business need to do so unless a longer retention period is required or permitted by law (such as tax, legal, accounting, or other purposes). For example, if you are a customer, we will keep your data for the duration of the contractual relationship you or your company has with us and after the end of that relationship for as long as necessary to perform the functions set forth above or to comply with legal obligations. When we have no justifiable business need to process your data, we will either delete or anonymize it, or if this is not possible, we will securely store your personal data and isolate it from any further processing until deletion is possible.

User Access and Choice

You are entitled to ask us for a copy of your data, to correct it, erase or restrict its processing, or to ask us to transfer (parts of) this data to other organizations. You also have the right to object to certain processing activities, such as the profiling we may perform for direct marketing as discussed above in this Policy. Where we have asked for your consent to process your data, you have the right to withdraw this consent, for example, by using the opt-out or unsubscribe functionalities in our communications with you. These rights can be limited where we can demonstrate that we have a legal requirement or legitimate basis to process your data, and under such circumstances, we can retain your data even if you withdraw your consent.

Changes to This Policy

This Policy was last revised on September 12th, 2017. Dev-Byrne reserves the right to change, modify or amend this Policy at any time. When the Policy is changed, modified, and amended, the revised Policy will be posted on Dev-Byrne’s website. If required by applicable law, we will notify you of any material changes to the Policy, and we will provide such notification posting a notice on our website before the changes becoming effective. Any revised privacy policy will only apply prospectively to personal data collected or modified after the effective date of the revised policy.

Contact Information

Dev-Byrne supports our clients in their compliance with the EU Data Protection Directive 1995, the UK Data Protection Act 1988 and will make reasonable efforts to support our clients in meeting their obligations and compliance with any relevant local data privacy laws, as they instruct Dev-Byrne. If you have any questions regarding this Policy, you can write to Dev-Byrne’s Data Privacy Officer, who may be contacted by e-mail at dataprivacyofficer@dev-byrne.com or by mail at:

Data Privacy Officer
Dev-Byrne & Company
1177 Avenue of the Americas
Fifth Floor
New York, NY 10036

AGREEMENT TO TERMS AND CONDITIONS

Access to and use of Dev-Byrne & Company sites by an individual shall form an acknowledgment and acceptance by such individual of these terms and conditions and this privacy policy.