At Devicie we are passionate about helping organisations to protect people’s personal information, whether it be data about their employees, suppliers, partner companies, customers or third parties. And we’re equally committed in applying those principles to our own business.
While the Privacy Policy has to include clauses that protect us if something goes wrong – despite all our efforts –we can assure you we will do everything we can, within the limits of our expertise and what anyone could reasonably expect of us, to protect your data. So, if you entrust us with your name, telephone number, or anything else that relates to your personal identity, you can rest assured we will diligently protect it.
However, we also want you to be aware that no security measures are 100% effective, and despite our very best efforts, there is always a risk that your information could end up in the wrong hands. Should that happen, and as soon as we become aware it has happened, we will immediately let you know and do what we reasonably can to protect you from any harm that could arise. We will only process your personal data for the purposes necessary to provide our services to you, and in compliance with applicable data privacy laws including The Privacy Act 1988 (Cth. Australia), and the General Data Protection Regulation (EU) 2016/679 (GDPR).
This website is operated by Devicie Pty Ltd. with registration number ABN 84 638 067 188 of 320/1 Bryant Drive, Mariners Centre of Excellence Building, Tuggerah NSW 2259 (Devicie).
We respect your privacy
Devicie respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. We will only process data in compliance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth), the California Consumer Privacy Act of 2018 ( CCPA), the EU GDPR (the General Data Protection Regulation (EU) 2016/679, as amended from time to time), and the UK GDPR and the Data Protection Act 2018 where applicable and as incorporated into local laws and as amended from time to (Data Privacy Laws).
This policy sets out how we collect and treat your personal data. “Personal data" or “personal information” shall be used interchangeably and for the purposes of this Privacy Policy shall have the meaning provided by the relevant Data Privacy Laws. Devicie shall ensure that the compliant processing of such data in accordance with the legal definitions and requirements that may apply under Data Privacy Laws.
1. Collection of personal information
Devicie will, from time to time, process and store personal data that is collected automatically by our website, provided to us directly from you or given to us in other forms in connection with providing our services to you. We may process various types of personal data which include but are not limited to :
Your name, last name, business name and business information, email addresses, usernames, device ID (computer and phone), device configuration data, cookie data or other voluntarily submitted personal data on an opt-in basis.
By disclosing your personal data to us by using our website, speaking to us over the telephone or communicating with us by email, you consent to the collection, storage and processing of your personal data in the manner stated in this Privacy Policy. You may provide basic information such as your name, phone number, address, and email address to enable us to send information, provide updates and process your product or service order. We may collect additional personal data at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial information, or communicate with our customer support. Additionally, we may also collect any other information you provide while interacting with us.
2. How we collect your personal information
Devicie collects personal data from you in a variety of ways, including when you interact with us electronically or in person, when you access our website and when we provide our services to you. We may receive personal data from third parties. If we do, we will protect it as set out in this Privacy Policy.
We encourage you to keep your personal data accurate and up to date. Please ensure that you regularly update any personal data you have given to us by sending an email to us at [email protected]. Under the GDPR and subject to Section 8 of this Privacy Policy, you have the right to have your personal data amended, corrected, or erased if you notify us by email at [email protected]. If you are an EU citizen please contact us at [email protected] and if you are a UK citizen please contact us at [email protected].
3. Lawful basis of processing
When collecting your personal data, we are required to have a lawful basis for doing so under the Data Privacy Laws. There are different lawful bases that we can rely on, depending on what personal data we process and why we process it.
The legal bases that we rely on are:
Consent – when you provide explicit consent to the processing of your data for a specific purpose. This is the basis we rely on when you voluntarily provide your details to us such as when you create an account, sign up to use our services or opt-in to our marketing list.
Legal obligation – when our use of your personal data is necessary to comply with the law (excluding contractual obligations), for example, to enable us to comply with any equality, accounting or tax laws.
Legitimate interest – when our use of your personal data is necessary for our own or a third-party’s legitimate interests to provide our services to you (unless there is a good reason to protect your personal data which overrides our legitimate interests and that your privacy rights are not compromised).
Performance of contract – when our use of your personal data is necessary to enter into a contract with you in order to provide our services to you.
4. Use of your personal information
Devicie may use personal data collected from you to provide you with information, updates and to provide our services. We may also make you aware of new and additional products, services and opportunities available to you. We may use your personal data to improve our products and services and better understand your needs. We will only process personal data where we have a lawful basis to do so as per Section 4 of this Privacy Policy. Devicie may contact you by a variety of measures including, but not limited to telephone, email, SMS or mail. Under the GDPR you have the right to ask us not to process or to restrict the processing of your personal data for marketing purposes. Should you at any time want us to stop contacting you or to delete any and all personal data we hold on you, you can tell us by sending an email to [email protected]. We will take all appropriate measures to comply with your request however please allow a few business days to fully process your request.
5. Disclosure of your personal information
Unless you ask us not to, we may disclose your personal data to any of our employees, officers, insurers, professional advisers, agents, suppliers or sub-contractors to send you service-related communications, to send you marketing communications, to process payments, to ensure security and compliance as well as to improve and provide our services to you. Personal data is only supplied to a third party to the extent that it is necessary for the delivery of our services and for marketing purposes subject to your consent.
Where reasonably practical, we will request your permission beforehand. We will also request that the third party follow this Privacy Policy regarding handling your personal data. We have established processes to thoroughly vet our third-party providers to ensure that those third parties are bound by written agreements including equivalent terms to this Privacy Policy and that they process your data in compliance with Data Protection Laws. However, Devicie shall not be responsible for their data processing activities. You shall be bound by the privacy terms of our third parties with respect to data processing activities that relate to your personal data. We may from time to time need to disclose personal data to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request. We may also use your personal data to protect the copyright, trademarks, legal rights, property, or safety of Devicie, www.devicie.com, its customers, or third parties.
If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal data and non-personal data contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose personal data in good faith and where required by any of the above circumstances. By providing us with personal data, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Privacy Policy.
6. Security of your personal information.
Devicie is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
Devicie operates a security programme in accordance with the AICPA SOC2 programme incorporating the Trust Services Criteria relating to security, availability, and confidentiality. This programme has been independently audited as compliant to SOC2 Type I, and will be audited to the Type II standards in Q4 2022.
Devicie also operates its privacy programme aligned with the prevailing GDPR (EU and UK) and CCPA standards to ensure the safety and security of personal data.
The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal data that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.
Devicie’s Data Breach Policy is available on request.
7. Your data protection rights
You may request details of personal data that we hold about you in accordance with the provisions of the Data Privacy Laws. If you would like a copy of the personal data, which we hold about you or believe that any personal data we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at [email protected]. If you are an EU citizen please contact us at [email protected] and if you are a UK citizen please contact us at [email protected]. We reserve the right to refuse to fully comply with your request relating to your data protection rights in certain circumstances where Data Protection Laws prohibits us from doing so.
Under GDPR you have the following rights :
The right to access the personal data we hold about you;
The right to have your personal data erased;
The right to have your personal data amended;
The right to restrict the processing of your personal data for certain activities;
The right to object to the processing of your personal data for activities based on automated decision-making; and
The right to have your personal data transferred from our systems to a third-party compatible system by contacting us at [email protected].
Devicie’s Policy on Handling Data Subject Requests (GDPR) is available on request.
8. International Data Transfers
We process personal data in by default in Australia in connection to the provision of our services. Therefore, we may occasionally transfer to, stored at or processed by data relating to the European Economic Area ( “EEA”) or the UK citizens to our staff or third parties operating outside of the EEA or the UK. By accepting this Privacy Policy you agree to disclose your personal data to us and to such transfer, storing or processing of your personal data. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Data Privacy Laws.
Under Data Privacy laws, we can only transfer personal data from the EU and UK to a country outside the EEA or the UK where:
The European Commission or the UK government has decided that the particular country ensures an adequate level of protection of personal data (“adequacy decision”) further to Article 45 of the EU and the UK GDPR;
There are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
A specific exception applies under relevant Data Privacy Laws.
Where we transfer personal data from the EEA and UK outside the EEA or the UK, we do so on the basis of an adequacy decision or (where such is not available) on the basis of Standard Contractual Clauses as approved by the European Commission approved EU Commission Decision 2021/914/EU of 4 June 2021 and the UK Addendum as approved by the Commissioner’s Office under s.119A(1) of the Data Protection Act 2018.
9. Changes to Privacy Policy
We may need to update this Privacy Policy in the future, for instance to reflect changes in Data Privacy Laws, or our data. When we make any material change, we will place a message on our home page stating that a change has been made to our Privacy Policy. We will also state at the top of this Policy what changes have been made and leave that statement of change there for at least 3 (three) months.
10. When you visit our website
When you come to our website (https://devicie.com) we may collect certain personal data such as browser type, operating system, and other technical for operation of our site. This may be used in an aggregated manner to analyse how people use our site, such that we can improve our service. We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies, we use a third-party cookie management platform which implements a Cookie Policy and provides our visitors with the opportunity to choose which essential and non-essential cookies are permitted. You can also choose to reject cookies by changing your browser settings; however, this may prevent you from taking full advantage of our website. Our website may from time to time use cookies to analyse website traffic and help us provide a better website visitor experience, this is achieved through an anonymised and privacy focused third party - https://matomo.org/.
11. Contacts - Devicie UK and EU Privacy Representatives
Devicie has appointed the following to act as our UK and EU Representatives regarding Privacy.
UK Representative – GRCI Law Limited
EU Representative – IT Governance Europe Limited
If you wish to exercise your rights under the UK General Data Protection Regulation (GDPR) or have any queries in relation to your rights or privacy matters generally please email our Representative Helen Pettit at [email protected] or at GRCI Law Limited Registered number 11311669 of Unit 3, Clive Court, Bartholomew’s Walk, Cambridgeshire Business Park, Ely CB7 4EA, UK.
Similarly, if you wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR), or have any queries in relation to your rights or general privacy matters, please email our Representative Dr Loredana Tassone at [email protected] or at IT Governance Europe Limited (ITG EU), Registered number 509421 and of 6th Floor, South Bank House, Barrow Street, Dublin 4, Eire
12. Complaints
If you have any complaints about our privacy practices, please feel free to send in details of your complaints by email to [email protected] or mail to 320/1 Bryant Drive, Mariners Centre of Excellence Building, Tuggerah NSW 2259. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.
Last Updated 4 January 2023