Website Privacy Policy
How We Protect Your Privacy
This website privacy
policy tells you how we collect, use, and protect your personal information. By
visiting our website (DevWebSEO.com), you accept and agree to the terms and
conditions of this website privacy policy. In particular, you consent to our
collection and use of your personal information as described in this website
privacy policy.
Minors
We do not provide
services or sell products to children. However, we may sell products to adults
for use by children. Regardless of the intended end user of our products, only
adults should purchase anything from our website. If a product we offer is
legal only for adults to use or possess, no adult should purchase the product
for illegal use or possession by a minor.
If you are less than 18
years old, you may use our website only with the permission, active
involvement, and supervision of an adult parent or legal guardian. If you are a
minor, please do not provide us or other website visitors with any personal
information.
This Policy Is Part Of Our Terms And
Conditions Of Use
Our website privacy
policy is a part of, and subject to, our website’s Terms and Conditions of Use.
You may view these terms and conditions on our website.
This Policy and Customer Agreements
If you are our customer,
any customer agreement between us supersedes this policy to the extent there is
any conflict with the terms and conditions of the customer agreement.
The type of information we collect
from you and interest-based advertising.
Like most places on the
Internet, simply by visiting our website you automatically tell us certain
information. This includes basic information such as your IP address, when you
visited, the website from where you came prior to visiting us, the website
where you go when you leave our website, your computer’s operating system, and
the type of web browser that you are using. Our website automatically records
this basic information about you.
And like many other
websites, we may use cookies, web beacons, click redirects, pixel tags,
container tags, and similar technologies. In plain English, this means
information that our website’s server transfers to your computer. This
information can be used to track your session on our website and to customize
our website content for you as an individual.
If you are using one of
the common Internet Web browsers, you can set up your browser to either (a) let
you know when you are being tracked by us or to (b) deny us tracking access to
your computer or electronic mobile device. The manufacturer of the browser you
use has instructions on how to modify tracking settings. You may find these
instructions in the “Help” section of your browser or by contacting the
browser’s manufacturer.
If you download or use
mobile software applications (“Mobile Apps”) from our website, we may know your
location. In addition, your smart phone, computer tablet, or other electronic
device using our Mobile Apps may provide us information about the device,
including its unique identifier, make and model, operating system, mobile
network carrier, and your telephone number. Your mobile device may have the
ability to disable location services as well as deny us access to other
information described in this paragraph. To learn more, check your mobile
device’s user manual and/or contact your mobile device’s manufacturer or
service carrier.
We may also collect any
data that you provide us by posting it at our website or by sending to us via
email. You can always choose not to provide us with information. However, if
you do withhold information, we may deny you access to some or all of our
website’s services and features.
Some transactions
between you and our website may involve payment by credit card, debit card,
checks, money orders, and/or third party online payment services. In such
transactions, we will collect information related to the transaction as part of
the course of doing business with you, including your billing address,
telephone number, and other information related to the transaction.
What We Do With Your Information
We use your information
to operate our website’s business activities. For example, we may use this data
to contact you about changes to our website, direct marketing (e.g. new
products and services, special offers, etc.), resolve disputes, troubleshoot
issues, and enforce our website’s terms and conditions.
If you download or use
Mobile Apps from our website, the information we learn about you may be used by
us to give you personalized content based upon your location and other data you
share. If you do not want to share your location via Mobile Apps, check the
instruction manual for your electronic device or contact your device’s
manufacturer to see if you can turn off the locator feature.
As a general rule, we
will not give your data to third parties without your permission. However,
there are some important exceptions to this rule that are described in the
following paragraphs.
We may, in our sole
discretion, provide information about you to law enforcement or other government
officials for purposes of fraud investigations, alleged intellectual property
infringement, or any other suspected illegal activity or matters that may
expose us to legal liability.
Some government
intelligence agencies have the technological ability to access data from our
website without our cooperation, knowledge, or consent. Even if we were to
learn of such access, we may not be able to tell you because of national
security laws. Please take this risk into account before supplying information
to us or any other website owner.
Although we do not
disclose individually identifiable information, we may disclose aggregate data
about our website’s visitors to advertisers or other third parties for
marketing and promotional purposes.
From time to time, we
may use third party suppliers to provide services on our website. If a supplier
wants to collect information about you, you will be notified. However, you will
never be required to give information to a third party supplier. We restrict
the way third party suppliers can use your information. They are not allowed to
sell or give your information to others.
If we sell our website,
we may transfer your information to the purchaser of the site. Upon completion
of such a transfer, we will no longer possess or control the data received by
the purchaser.
Do-Not-Track, Interest-Based
Advertising, Remarketing, and Dynamic Ad Serving
Do-Not-Track
We try to honor any
Do-Not-Track signals you send through your web browser when visiting our
website. However, please read the following important information about
“Interest-Based Advertising,” “Remarketing,” and “Dynamic Ad Serving” so that
you understand the type of tracking that may be done by third party vendors
when you visit our site and how you can opt out of such tracking.
Interest-Based
Advertising
When you visit our
website, you may view advertisements posted on the site by Google or other
companies. These advertising companies may collect information about you while
you are visiting this website and other websites. They may use this data to
show you advertisements on this website and elsewhere on the Internet about
products and services you might like.
This website does not
collect the information or control the content of the advertisements that you
will see. You may be able to opt out of such advertising.
If you are in the United
States, you may opt out of some advertising via the Digital Advertising
Alliance at http://www.aboutads.info/choices/
If you are in Canada,
you may opt out of some advertising via the Digital Advertising Alliance of
Canada at http://youradchoices.ca/
If you are in Europe,
you may opt out of some advertising via the European Interactive Digital
Advertising Alliance at http://www.youronlinechoices.com/
To find out more about
Google privacy policies and its DoubleClick DART cookie used to generate
interest-based advertising, go to https://www.google.com/policies/technologies/ads/ .
Protect My Choices
If you are using
Internet Explorer, Mozilla Firefox, or Google Chrome browsers, you may wish to
install the “Protect My Choices” browser extensions that are designed to help
you protect your opt-out preferences. To learn more, go to http://www.aboutads.info/PMC.
Remarketing
This website may use a
remarketing tag to advertise online. This means that Google and other
third-party vendors may show our ads to you on sites across the Internet. These
third-party vendors, including Google, may use cookies to serve ads to you
based upon your past visits to our website.
If you would like to opt
out of Google’s use of cookies, you can visit the company’s Ad Preferences
Manager at https://www.google.com/ads/preferences/.
In the alternative, you
can opt out of the use of cookies by some third-party vendors by going to the
Network Advertising Initiative’s opt-out page located at http://www.networkadvertising.org/choices/ .
Dynamic Ad Serving
Our website may use
Google’s Dynamic Ad Serving feature. To opt out of interest-based ads by
Google, follow Google’s opt-out instructions located at https://support.google.com/ads/answer/2662922?hl=en .
DoubleClick Remarketing
Pixels
Our website may use
DoubleClick’s remarketing pixels. If you would like to opt out of DoubleClick’s
use of cookies, you can visit the DoubleClick opt-out page at https://www.google.com/settings/ads/onweb#display_optout.
Your use of this website
without opting out means that you understand and agree to data collection to
provide you with interest-based advertising.
User Names And Passwords
Your access to parts of
our website may be protected by a user name and a password. Do not give your
password to anyone. If you enter a section of our website that requires a
password, you should log out when you leave. As a safety precaution, you should
also close out of your web browser completely and re-open it before viewing
other parts of the Internet.
Use Of Information And Unsolicited
Commercial Email
If you obtain personally
identifiable information about another website user, you are not allowed to
disclose this information to anyone else without the consent of the user and
our consent too. If you communicate with other website users via our website
(or by other means), such third parties may have copies of your communications
even if you delete your own copies of such communications on our website and
your electronic devices.
We hate junk email
(spam). Information you obtain from our website about us or other site users
cannot be used by you or others to send unsolicited commercial email or to send
unsolicited commercial communications via our website’s posting or other
communication systems.
Your Voluntary Disclosure Of
Information To Third Parties Who Are Not Our Suppliers
You may choose to
provide personal information to website visitors or other third parties who are
not our suppliers. Please use caution when doing so. The privacy policies and
customs of these third parties determine what is done with your information.
Autoresponders
We may use
autoresponders to communicate with you by email. To protect your privacy, we
use a verified opt-in system for such communications and you can always opt-out
of such communications using the links contained in each autoresponder message.
If you have difficulties opting out, you may contact us by sending an email to
Support[at]DevWebSEO.com, or sending us mail to the address listed below.
Information Security
We try to keep your
information secure. If we become aware of a data vulnerability, where
economically feasible, we will attempt to promptly fix it in order to keep your
data safe. However, with governments spying online using sophisticated
technology and hackers data mining sites, no website owner can guarantee your
information will be completely safe from unauthorized access by others. Please
take these security risks into account before giving information to us or any
other website owner.
Data Retention
We will keep your data
for as long as we need it to provide you with products and services, comply
with applicable law, resolve any disputes between us or with third parties, and
to enforce any contracts between us.
California Privacy Rights
If you are a California
resident and our customer, Cal. Civ. Code § 1798.83 permits you to request
certain information about our disclosure of personal information to third
parties for their direct marketing purposes. To request this information,
please send an email to Support[at]DevWebSEO.com or write us at the following
address:
DevWebSEO
149 E Blackjack Branch
Way STE 2
Jacksonville, FL 32259
United States
European Union Privacy Rights
If you reside in the
European Union, you may have certain privacy rights under
Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), to
the extent the GDPR does not conflict with the laws of FL and United States.
Even if we do not have a legal obligation to do so, we may respond
to your requests made per the GDPR. However, voluntary responses are not a
waiver of our legal rights and obligations under the laws of FL and United
States or the arbitration provisions found within our website’s Terms and Conditions
of Use.
Small Or Medium-Sized
Enterprise Status
We are a small or
medium-sized enterprise (“SME”). This means that because of the size of our
business, to the extent (if any) the GDPR governs our relationship with you,
some of GDPR’s obligations do not apply because we are an SME.
How To Make A Request
To make a GDPR request,
please send an email to Support[at]DevWebSEO.com or write us at the following
address:
DevWebSEO
149 E Blackjack Branch
Way STE 2
Jacksonville, FL 32259
United States
We will respond within
thirty (30) days of receipt of your request.
Requests To Access
Personal Data
If we grant your request
to access personal data, we will: (1) confirm whether or not we are processing
your personal data; (2) provide you with a copy of any of your personal data
that we possess; and (3) provide you with information about how we process such
data (e.g. purposes, categories, recipients, etc.).
Requests To Delete Data
If you request that we
delete your personal data that we possess, we will do so unless: (1) the data
is needed to exercise the right of freedom of expression; (2) we have a legal
obligation to keep the data; (3) we must keep the data for reasons of public
interest; or (4) the data has been processed so that it is anonymized.
Any personal data we
processed unlawfully will be deleted. If you were a minor when we collected the
personal data, we will delete the data upon request.
If we believe any third
parties have acquired your personal data through us, we will take reasonable
steps to inform them that you have requested erasure of such data.
Objections To Processing
Of Personal Data
If your request is an
objection to the processing of your personal data for directing marketing
purposes, we will cease using your data for such purposes.
As a general rule, we
will comply with objections to processing personal data except: (1) where it is
not technically or commercially feasible to do so; or (2) we have a legal
obligation that overrides your individual rights and freedoms.
Portability Requests
If we collected personal
data from you because of a contract between us or based on your consent, and we
processed that data by automated means (in structured machine-readable format),
you can request that data be transmitted by us to another company or
organization.
We will provide such
data to the recipient third party in a commonly used open format electronic
file (e.g. CSV, JSON, XML, etc.).
Denied Requests
If we reject your
request, we will provide you with the reason(s) for doing so. You may then
choose to file a complaint with the Data Protection Authority and request a
judicial remedy to the extent such a request is not in conflict with the laws
of laws of FL and United States or the arbitration provisions of our website’s
Terms and Conditions of Use).
Processing Fees
As a general rule, there
is no fee for processing your GDPR request. However, we reserve the right to
refuse your request or charge a reasonable fee for processing it if the request
is manifestly unfounded or excessive. For example, it would be excessive to
make a repetitive second request to access your personal data one month after
we provided you with the data from a prior request.
Automated Processing
We may make decisions
through automated processing (e.g. algorithms) of personal data that are
legally binding or significantly affect you.
Any such automated
decision-making is done per your express consent or because it is necessary for
reasons of substantial public interest under applicable law.
Such an automated
decision may be made based on relevant law. However, if the decision is made
for other reasons, we will inform you of the process’ logic and potential
consequences of the decision. To the extent that the GDPR does not conflict
with the laws of FL and United States or the arbitration provisions found
within our website’s Terms and Conditions of Use, you may also
have a right to obtain human intervention and contest the automated decision.
Policy Changes
The terms of this
privacy policy may change from time to time. If such changes are made, we will
notify you by a notice posted on our website’s home page of the changes that
have been made. If you disagree with the changes that have been made, please
contact us (by email, using a website contact form, or in writing by mail), and
any changes made to this policy will not apply to information we have collected
from you prior to making the changes.
By continuing to access
our website after changes to this privacy policy go into effect, you are
agreeing to be legally bound by the revised policy.
If you are concerned
about the topic covered by this website privacy policy, you should read it each
time before you use our website.
Questions or Concerns
Any questions or
concerns about this website privacy policy should be brought to our attention
by sending an email to Support[at]DevWebSEO.com and providing us with
information relating to your concern.
You may also mail your
concerns to us at the following address:
DevWebSEO
149 E Blackjack Branch
Way STE 2
Jacksonville, FL 32259
United States
This website privacy
policy was last updated on August 10, 2018.
Copyright ©
2008-2018 Law Office of Michael E. Young PLLC and generated with Website Legal Forms
Generator software, and licensed for use
by the owner of this Website at DevWebSEO.com. All Rights Reserved. No portion
of this document may be copied or used by anyone other than the licensee
without the express written permission of the copyright owner. Use of this
document does not make the website owner a client of the law firm. Contact the
website owner with any questions or concerns about this site.
Legal & Policies
Legal & Policies
Thank you for visiting
our website (DevWebSEO.com), hereinafter referred to as “Website,” “website,”
or “Site.”
This page contains the following
legal documents and policies for our website:
* Accessibility Policy
* Terms and Conditions
of Use (including Video and Audio content)
* Electronic
Communications Policy
* Material Connections
and Compensation Disclosure
* External Links Policy
* Health and Earnings
Disclaimers
* Miscellaneous
Provisions
* This page also
includes our website’s Digital Millennium Copyright Act (“DMCA”) Notice
describing how copyright infringement issues are handled.
You may view our
website’s Privacy Policy and other policies on other web pages on this site.
Accessibility Policy
We are committed to
taking reasonable steps to make DevWebSEO.com accessible to visitors with
disabilities. If you need help using our website, please email us at
Support[at]DevWebSEO.com.
If you are
visually-impaired, we recommend using text-to-speech software, such as
Microsoft’s Narrator, Apple’s VoiceOver, and the KNFB Reader mobile application
(available in Apple’s App Store and at Google Play), to enjoy our website.
Terms and Conditions of Use
If you want to view or
use DevWebSEO.com, you must agree to conform to and be legally bound by the
terms and conditions described below. If you disagree with any of these terms
or conditions, do not use our website.
Our Website’s Privacy Policy Is Part Of These Terms And
Conditions
Our website’s Privacy
Policy is part of, and subject to, these Terms and Conditions of Use. You may
view our Privacy Policy elsewhere on our website. To the extent there is a
conflict, these Terms and Conditions of Use shall govern.
These Policies, Terms, Conditions, and
Customer Agreements
If you are our customer,
any customer agreement between us supersedes these policies, terms and
conditions to the extent there is any conflict with the terms and conditions of
the customer agreement.
Video and Audio Content
This website (DevWebSEO.com)
may contain one or more videos and/or audio recordings (individually and
collective hereinafter referred to as the “Recordings”). This section describes
our respective rights and responsibilities with regard to the Recordings.
Recordings Are For Entertainment And Informational Purposes
Only
All Recordings are to be
watched and/or listened to for informational and entertainment purposes only.
Recordings are not intended to provide specific legal, financial, tax, physical
or mental health advice, or any other advice whatsoever to you, any other
individual or company, and should not be relied upon in that regard. Any
products or services described in the Recordings are only offered in
jurisdictions where they may be legally offered. Information provided in
Recordings is not all-inclusive, is limited to information that is made
available, and such information should not be relied upon as all-inclusive or
accurate.
Embedded Recordings From External Social Media Sites Not
Owned By Us
Some of the Recordings
embedded for your viewing and listening pleasure are hosted on social media
websites not owned by us. This may include, but is not limited to, sites such
as YouTube.com (individually and collectively, the “Third Party Social Media
Sites”).
We make no claim to the
intellectual property rights of the owners of Third Party Social Media Sites.
We also make no claim to the intellectual property rights of third party
creators of Recordings hosted on Third Party Social Media Sites. Our embedding
of such Recordings on this website is done pursuant to applicable licenses to
do so granted by the Third Party Social Media Sites.
Embedding Recordings on
this website does not create an association, agency, joint venture, or
partnership between us and the owners of the Third Party Social Media Sites or
impose any liability attributable to such a relationship upon either party.
Recordings are only
provided for your convenience. We do not control or guarantee the accuracy,
completeness, relevance, or timeliness of any information contained in the
Recordings. You should know that Third Party Social Media Sites may track your
viewing and listening habits.
If Recordings embedded
on this website were created by us but are hosted on Third Party Social Media
Sites, we retain all intellectual property rights for such Recordings except to
the extent we granted a license to Third Party Social Media Sites to the
Recordings. The hosting of these Recordings by Third Party Social Media Sites
does not grant you any rights to such Recordings except to the extent provided
under the applicable licenses those sites grant to viewers and listeners of
Recordings they host on their websites.
Embedded Recordings Owned By Us And Hosted On Our Servers
Or Third Party Servers Excluding Third Party Social Media Sites
Some of the Recordings
embedded for your viewing and listening pleasure may be created by us and
hosted on our servers or third party servers. This may include, but is not
limited to cloud hosting services from Amazon.com or others but excludes the
Third Party Social Media Sites described above.
We own the copyrights
and all other intellectual property rights for these Recordings unless
otherwise expressly noted. We make no claim to the intellectual property rights
of the owners of third party servers who by contractual agreement are hosting
our Recordings for us.
Hosting our Recordings
on third party servers does not create an association, agency, joint venture,
or partnership between us and the owners of those servers, or impose any
liability attributable to such a relationship upon either party.
Recordings are only
provided for your convenience. We do not guarantee the accuracy, completeness,
relevance, or timeliness of any information contained in the Recordings. You
should know that we and/or the owners of third party servers hosting the
Recordings may track your viewing and/or listening habits.
Personal Non-Exclusive Revocable Nontransferable License
When you watch or listen
to the Recordings on this website, you understand and agree that you are doing
so pursuant to a personal non-exclusive revocable nontransferable license from
us to do so.
The Recordings remain
the sole and exclusive property of their respective owners, which retain all
rights thereto. You understand and agree that the Recordings may not be resold
by you or otherwise distributed with or without consideration. You will not
make the Recordings available to any third party. You may not reproduce or
summarize any of the Recordings in any manner.
You agree to destroy any
of the Recordings cached on your computer or otherwise in your possession
within 24 hours of watching or listening to said Recordings. Notwithstanding
this provision, you agree to immediately destroy any Recordings in your
possession upon material violation of the terms and conditions contained in
this document, or upon request by us that you do so.
Broken Or Obsolete Recordings
We review our website
periodically for broken or out-of-date Recordings. Any and all Recordings may
be posted, altered, or removed at any time. To report problems with Recordings
on our website, or for more information, please send an email to Support[at]DevWebSEO.com.
Licensee Status
You understand and agree
that your use of our website is limited and non-exclusive as an individual
nontransferable revocable licensee. We may, within our sole discretion,
terminate your license to use our website, and access to our website, for any
reason or no reason whatsoever, and without giving you notice.
Content Ownership
All content on our
website is owned by us or our content suppliers. On behalf of ourselves and our
content suppliers, we claim all property rights, including intellectual
property rights, for this content and you are not allowed to infringe upon
those rights. We will prosecute to the fullest extent of the law anyone who
attempts to steal our property.
You agree not to copy
content from our website without our permission. Any requests to use our
content should be submitted to us by email to Support[at]DevWebSEO.com.
If you believe that your
intellectual property rights have been infringed upon by our website content,
please notify us by sending an email to Support[at]DevWebSEO.com, or by sending
postal mail to us at the address listed below. Please describe in detail the
alleged infringement, including the factual and legal basis for your claim of
ownership.
For copyright
infringement issues, please follow the instructions in the DMCA Notice found
below on this web page.
Mobile Apps
We may provide you with
services via a computer program designed to run on smartphones, tablet
computers, or other mobile electronic devices (a “Mobile App”). If we provide
you with a Mobile App either directly (e.g. download from our website) or
indirectly (e.g. via a third party Mobile App store), you are solely
responsible for using the Mobile App in a safe manner, including but not
limited to obeying applicable pedestrian and motor vehicle traffic laws.
If a Mobile App
developed by or for a third party contains a link (affiliate or otherwise) to
our products or services, we are not responsible for the content of or your use
of the third party Mobile App.
Disclaimers And Limitations Of Liability
THE INFORMATION ON OUR
WEBSITE IS PROVIDED ON AN “AS IS,” “AS AVAILABLE” BASIS. YOU AGREE THAT YOUR
USE OF OUR WEBSITE IS AT YOUR SOLE RISK. WE DISCLAIM ALL WARRANTIES OF ANY
KIND, INCLUDING BUT NOT LIMITED TO, ANY EXPRESS WARRANTIES, STATUTORY
WARRANTIES, AND ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A
PARTICULAR PURPOSE, AND NON-INFRINGEMENT. WE DO NOT WARRANT THAT OUR WEBSITE
WILL ALWAYS BE AVAILABLE, ACCESS WILL BE UNINTERRUPTED, BE ERROR-FREE, MEET
YOUR REQUIREMENTS, OR THAT ANY DEFECTS IN OUR WEBSITE WILL BE CORRECTED.
INFORMATION ON OUR
WEBSITE SHOULD NOT NECESSARILY BE RELIED UPON AND SHOULD NEVER BE CONSTRUED TO
BE PROFESSIONAL ADVICE FROM US. WE DO NOT GUARANTEE THE ACCURACY OR
COMPLETENESS OF ANY OF THE INFORMATION PROVIDED, AND ARE NOT RESPONSIBLE FOR
ANY LOSS RESULTING FROM YOUR RELIANCE ON SUCH INFORMATION.
IF YOUR JURISDICTION
DOES NOT ALLOW LIMITATIONS ON WARRANTIES, THIS LIMITATION MAY NOT APPLY TO YOU.
YOUR SOLE AND EXCLUSIVE REMEDY RELATING TO YOUR USE OF THE SITE SHALL BE TO
DISCONTINUE USING THE SITE.
UNDER NO CIRCUMSTANCES
WILL WE BE LIABLE OR RESPONSIBLE FOR ANY DIRECT, INDIRECT, INCIDENTAL,
CONSEQUENTIAL (INCLUDING DAMAGES FROM LOSS OF BUSINESS, LOST PROFITS,
LITIGATION, OR THE LIKE), SPECIAL, EXEMPLARY, PUNITIVE, OR OTHER DAMAGES, UNDER
ANY LEGAL THEORY, ARISING OUT OF OR IN ANY WAY RELATING TO OUR WEBSITE, YOUR
WEBSITE USE, OR THE CONTENT, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH
DAMAGES.
OUR TOTAL LIABILITY FOR
ANY CLAIM ARISING OUT OF OR RELATING TO OUR WEBSITE SHALL NOT EXCEED ONE HUNDRED
($100) DOLLARS AND THAT AMOUNT SHALL BE IN LIEU OF ALL OTHER REMEDIES WHICH YOU
MAY HAVE AGAINST US OR OUR AFFILIATES (IF ANY). ANY SUCH CLAIM SHALL BE SUBJECT
TO CONFIDENTIAL BINDING ARBITRATION AS DESCRIBED LATER IN THIS DOCUMENT.
Cyber-Bullying and Internet Harassment
Cyber-bullying and
Internet harassment are prohibited. Although we support First Amendment free
speech rights, such rights are limited where the purpose or effect of the
expression is to bully, harass, threaten, ridicule, embarrass, and/or
intimidate others. This is particularly true in matters involving race,
ethnicity, national origin, religion, gender, sex, sexual orientation, physical
disability, and/or mental condition.
If we decide, in our
sole discretion, that you have committed cyber-bullying acts or Internet
harassment, we reserve the right to unilaterally suspend or ban your use of our
Website immediately with or without notice to you. Although we are not
obligated to do so, we reserve the right to monitor, investigate, and remove
material posted to our Website that we determine constitutes cyber-bullying or
Internet harassment.
If we suspect that the
cyber-bullying acts or Internet harassment constitutes illegal activity, we
may, in our sole discretion, provide information to law enforcement or other
government officials for purposes of investigating the misconduct. Examples of
illegal conduct include, but are not limited to, threats of violence, sending
sexually explicit images, and stalking others. This sharing of information is
consistent with our Website’s Privacy Policy terms governing suspected illegal
activity.
Obscene and Offensive Content
We are not responsible
for any obscene or offensive content that you receive or view from others while
using our website. However, if you do receive or view such content, please
contact us by email to Support[at]DevWebSEO.com so that we can investigate the
matter. Although we are not obligated to do so, we reserve the right to
monitor, investigate, and remove obscene or offensive material posted to our
website.
Business Opportunities
Without our express
prior written permission, you shall not use our Website to promote, market, or
advertise directly or indirectly on behalf of any “business opportunity”
covered by the U.S. Federal Trade Commission’s Business Opportunity Rule, 16
C.F.R. § 437.1 et seq. (as amended). This includes, but is not limited to,
comments, messages, and signature tag lines promoting a business opportunity.
If you violate this provision, as determined in our sole discretion, we reserve
the right to unilaterally suspend or ban your use of our Website immediately
with or without notice to you, and to remove all offending content from our
Website.
Indemnification
You understand and agree
that you will indemnify, defend and hold us and our affiliates (if any)
harmless from any liability, loss, claim and expense, including reasonable
attorney’s fees, arising from your use of our website or your violation of
these terms, conditions, and policies.
Compliance With Governing Law And Dispute Resolution
You agree to obey all
applicable laws while using our website.
You agree that the laws
of FL and United States govern these terms and conditions of use without regard
to conflicts of laws provisions. If you reside in the European Union, you
understand and agree that FL and United States laws govern these terms and
conditions, taking precedence over any rights you might otherwise have under
Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”). Any
GDPR rights you may have are ancillary and subservient to the laws of FL and
United States.
You also agree that any
dispute between you and us, excluding any intellectual property right
infringement claims we pursue against you, shall be settled solely by confidential
binding arbitration per the American Arbitration Association commercial
arbitration rules. All claims must arbitrated on an individual basis, and
cannot be consolidated in any arbitration with any claim or controversy of
anyone else. All arbitration must occur in St..Johns County, FL, United States.
Each party shall bear one half of the arbitration fees and costs incurred, and
each party is responsible for its own lawyer fees.
Electronic Communications Policy
We hate unsolicited
commercial email (“UCE”) as much as you do. Also known as spam or junk email,
UCE is a disservice to the Internet community.
We fully endorse and
comply with the requirements of the CAN-SPAM Act of 2003 (Controlling the
Assault of Non-Solicited Pornography and Marketing Act), and all other
applicable unsolicited commercial email laws. For example, California’s
anti-spam law, Cal. Bus. & Prof. Code § 17529, may apply if you are using
or sending to a California electronic mail address, and in other limited
circumstances.
If you subscribe to
electronic newsletters or other communications from us or our website, you will
always have an option to unsubscribe immediately.
When you communicate
with us by email, text message, telephone call, or other electronic means, you
are agreeing that we can respond to you by the same or other electronic means
of communication. You also agree that we can subsequently communicate with you
for marketing and other commercial purposes by electronic means using the
information you have provided to us (email address, mobile phone number, etc.)
unless and until you make a signed written request by email or by mail to our
address listed below that these subsequent communications cease. Your request
must include the specific contact information you no longer wish us to use for
communicating with you (email address, mobile phone number, etc.)
If you have additional
questions, comments or concerns, please contact us by sending an email to
Support[at]DevWebSEO.com and providing us with information relating to your
concern.
You may also mail your
concerns to us at the following address:
DevWebSEO
149 E Blackjack Branch
Way STE 2
Jacksonville, FL 32259
United States
Material Connections and Compensation
Disclosure Policy
You should always
conduct your own investigation (perform due diligence) before buying products
or services from anyone via the internet. This includes products and services
sold on this website and all other websites.
Material Connection
Unless otherwise
expressly stated, you should assume that all references to products and
services on DevWebSEO.com are made because material connections exist between
the website’s owner(s) (“Owner”) and the providers of the mentioned products
and services (“Provider”).
If there are affiliate
links or advertising on DevWebSEO.com for goods or services sold by Amazon.com,
Inc., its subsidiaries or sister companies (collectively “Amazon”), this means
the Owner is a participant in Provider Amazon Services LLC Associates Program
(“Amazon Associates Program”), an affiliate advertising program designed to
provide a means for sites to earn advertising fees by advertising and linking
to Amazon.com and other Amazon websites.
All references to Amazon
trademarks, service marks, and logos on DevWebSEO.com is made pursuant to a
limited, revocable, non-transferable, non-sublicensable, non-exclusive,
royalty-free license under the Amazon Associates Program and in accordance with
that program’s trademark guidelines.
Good Faith Recommendations
The Owner recommends
products and services on DevWebSEO.com based in part on a good faith belief
that the purchase of such products or services will help purchasers in general.
The Owner has this good faith belief because (a) the Owner has tried the product
or service mentioned prior to recommending it or (b) the Owner has researched
the reputation of the Provider and has made the decision to recommend the
Provider’s products or services based on the Provider’s history of providing
these or other products or services. The representations made by the Owner
about products and services reflect the Owner’s honest opinion based upon the
facts known to the Owner at the time a product or service is mentioned on DevWebSEO.com,
in social media, and/or email communications.
Potential Bias and Due Diligence
The Owner’s opinion
about a product or service may be partially formed (consciously or
subconsciously) in part based on the fact that the Owner has been, may be, or
will be compensated because of the Owner’s business relationships with the
Providers.
In some instances, the
Owner and a Provider will have a business or personal relationship that does
not involve the Owner receiving compensation related to products and services
mentioned on DevWebSEO.com. However, the nature of the relationship is
sufficient to establish a material connection between the Owner and the
Provider.
Because there may be a
material connection between the Owner and Providers of products or services
mentioned on DevWebSEO.com, you should always assume that the Owner may be
biased because of the Owner’s relationship with a Provider and/or because the
Owner has received or will receive something of value from a Provider.
Perform your own due
diligence before purchasing a product or service mentioned on DevWebSEO.com (or
any other website).
Compensation
The type of compensation
received by the Owner may vary. In some instances, the Owner may receive
complimentary products, services, or money from a Provider prior to mentioning
the Provider’s products or services on DevWebSEO.com.
In other instances, the
Owner may receive a monetary commission or non-monetary compensation when you
take action based on the content of DevWebSEO.com. This includes, but is not
limited to, when you purchase a product or service from a Provider after
clicking on an affiliate link on DevWebSEO.com.
External Links Policy
Our website, DevWebSEO.com,
contains hypertext links to websites and other information created and
maintained by other individuals and organizations. These links are only
provided for your convenience. We do not control or guarantee the accuracy,
completeness, relevance, or timeliness of any information or privacy policies
posted on these linked websites. You should know that these websites may track
visitor viewing habits.
Unless otherwise
expressly stated by us, hyperlinks to particular items do not reflect their
importance, and are not an endorsement of the individuals or organizations
sponsoring the websites, the views expressed on the websites, or the products
or services offered on the websites.
We permit links to our
website if they do not imply an endorsement by, or affiliation with, our
website absent written consent. If we operate an affiliate program, our
affiliates may link to our website pursuant to the terms and conditions of our
affiliate program agreement with them.
We review our website
periodically for broken or out-of-date links. Any and all links may be posted,
altered, or removed at any time. Please note that links to external websites
may expire over time. Such expiration is beyond our control. To report problems
with links on our website, or for more information about this policy, please
send an e-mail to Support[at]DevWebSEO.com.
Health and Earnings Disclaimers
This website may contain
references to health-related products and/or services. The site may also refer
to business opportunities or other money-making opportunities. If any such
content exists on this website, the following disclaimers apply.
You understand and agree
that there are important risk factors that should be considered by you when
deciding whether to purchase Wellness Cleanse. The following disclaimers apply
to the extent this website (DevWebSEO.com), our products or services, and/or
our communications with you refer to income, earnings, making money, or
health-related (physical and/or mental) matters.
No Earnings Projections, Promises Or Representations
You recognize and agree
that we have made no implications, warranties, promises, suggestions,
projections, representations or guarantees whatsoever to you about future
prospects or earnings, or that you will earn any money, with respect to your
purchase of Wellness Cleanse, and that we have not authorized any such
projection, promise, or representation by others.
Any earnings or income
statements, or any earnings or income examples, are only estimates of what we
think you could earn. There is no assurance you will do as well as stated in
any examples. If you rely upon any figures provided, you must accept the entire
risk of not doing as well as the information provided. This applies whether the
earnings or income examples are monetary in nature or pertain to advertising
credits which may be earned (whether such credits are convertible to cash or
not.
There is no assurance
that any prior successes or past results as to earnings or income (whether
monetary or advertising credits, whether convertible to cash or not) will
apply, nor can any prior successes be used, as an indication of your future
success or results from any of the information, content, or strategies. Any and
all claims or representations as to income or earnings (whether monetary or
advertising credits, whether convertible to cash or not) are not to be
considered as “average earnings”.
The Economy. The
economy, both where you do business, and on a national and even worldwide
scale, creates additional uncertainty and economic risk. An economic recession
or depression might negatively affect the results produced by Wellness Cleanse.
Your Success Or Lack Of
It. Your success in using the information or strategies provided at DevWebSEO.com
depends on a variety of factors. We have no way of knowing how well you will
do, as we do not know you, your background, your work ethic, your dedication,
your motivation, your desire, or your business skills or practices. Therefore,
we do not guarantee or imply that you will get rich, that you will do as well,
or that you will have any earnings (whether monetary or advertising credits,
whether convertible to cash or not), at all.
Internet businesses and
earnings derived therefrom involve unknown risks and are not suitable for
everyone. You may not rely on any information presented on the website or
otherwise provided by us, unless you do so with the knowledge and understanding
that you can experience significant losses (including, but not limited to, the
loss of any monies paid to purchase Wellness Cleanse, and/or any monies spent
setting up, operating, and/or marketing Wellness Cleanse, and further, that you
may have no earnings at all (whether monetary or advertising credits, whether
convertible to cash or not).
Forward-Looking
Statements. MATERIALS CONTAINED ON THIS WEBSITE OR IN MATERIALS PURCHASED
AND/OR DOWNLOADED FROM THIS WEBSITE MAY CONTAIN INFORMATION THAT INCLUDES OR IS
BASED UPON FORWARD-LOOKING STATEMENTS WITHIN THE MEANING OF THE SECURITIES
LITIGATION REFORM ACT OF 1995. FORWARD-LOOKING STATEMENTS GIVE OUR EXPECTATIONS
OR FORECASTS OF FUTURE EVENTS. YOU CAN IDENTIFY THESE STATEMENTS BY THE FACT
THAT THEY DO NOT RELATE STRICTLY TO HISTORICAL OR CURRENT FACTS. THEY USE WORDS
SUCH AS “ANTICIPATE,” “ESTIMATE,” “EXPECT,” “PROJECT,” “INTEND,” “PLAN,”
“BELIEVE,” AND OTHER WORDS AND TERMS OF SIMILAR MEANING IN CONNECTION WITH A
DESCRIPTION OF POTENTIAL EARNINGS OR FINANCIAL PERFORMANCE.
ANY AND ALL FORWARD
LOOKING STATEMENTS HERE, IN OTHER MATERIALS CONTAINED ON THIS WEBSITE OR IN
MATERIALS PURCHASED AND/OR DOWNLOADED FROM THIS WEBSITE ARE INTENDED TO EXPRESS
OUR OPINION OF EARNINGS POTENTIAL. MANY FACTORS WILL BE IMPORTANT IN
DETERMINING YOUR ACTUAL RESULTS AND NO GUARANTEES ARE MADE THAT YOU WILL
ACHIEVE RESULTS SIMILAR TO OURS OR ANYBODY ELSE, IN FACT NO GUARANTEES ARE MADE
THAT YOU WILL ACHIEVE ANY RESULTS FROM OUR IDEAS AND TECHNIQUES IN OUR MATERIAL.
Due Diligence. You are
advised to do your own due diligence when it comes to making business decisions
and should use caution and seek the advice of qualified professionals. You
should check with your accountant, lawyer, or professional advisor, before
acting on this or any information. You may not consider any examples,
documents, or other content on the website or otherwise provided by us to be
the equivalent of professional advice. Nothing contained on the website or in
materials available for sale or download on the website provides professional
advice in any way. You should consult with your own accountant, lawyer, or
professional advisor for any questions you may have.
We assume no
responsibility for any losses or damages resulting from your use of any link,
information, or opportunity contained within the website or within any
information disclosed by the owner of this site in any form whatsoever.
Purchase Price. Although
we believe the price is fair for the value that you receive, you understand and
agree that the purchase price for Wellness Cleanse has been arbitrarily set by
us. This price bears no relationship to objective standards.
Health Disclaimers
Any references to
physical or mental health on this website constitutes an educational service
consisting solely of general health information. The materials in DevWebSEO.com
are provided “as is” and without warranties of any kind either express or
implied.
Not a Substitute for
Professional Medical Advice or Treatment. The website’s content is not a
substitute for direct, personal, professional medical care and diagnosis. None
of the exercises or treatments (including products and services) mentioned at DevWebSEO.com
should be performed or otherwise used without clearance from your physician or health
care provider. The information contained within is not intended to provide
specific physical or mental health advice, or any other advice whatsoever, for
any individual or company and should not be relied upon in that regard. We are
not medical professionals and nothing on this website should be misconstrued to
mean otherwise.
Health Risks. There may
be risks associated with participating in activities mentioned on DevWebSEO.com
for people in poor health or with pre-existing physical or mental health
conditions. Because these risks exist, you will not participate in such
activities if you are in poor health or have a pre-existing mental or physical
condition. If you choose to participate in these risks, you do so of your own
free will and accord, knowingly and voluntarily assuming all risks associated
with such activities.
Accuracy and
Completeness. Facts and information are believed to be accurate at the time
they were placed in DevWebSEO.com. All data provided in this website is to be
used for information purposes only. Products and services described are only
offered in jurisdictions where they may be legally offered. Information
provided is not all-inclusive, and is limited to information that is made
available and such information should not be relied upon as all-inclusive or
accurate.
Injuries. You agree to
hold DevWebSEO.com, its owners, agents, and employees harmless from any and all
liability for all claims for damages due to injuries, including attorney fees
and costs, incurred by you or caused to third parties by you, arising out of
the activities discussed on this website, excepting only claims for gross
negligence or intentional tort.
Testimonials, Case Studies, and Examples
Testimonials, case
studies, and examples found at DevWebSEO.com are exceptional results, do not
reflect the typical purchaser’s experience, don’t apply to the average person
and are not intended to represent or guarantee that anyone will achieve the
same or similar results. If we have disclosed typical results based on information
provided to us by a manufacturer or other reputable third party source, you
should presume that the typical results as stated are more reliable than the
testimonials and examples found at DevWebSEO.com.
However, you should
always perform due diligence and not take such results at face value. We are
not responsible for any errors or omissions in typical results information
supplied to us by manufacturers or other reputable third parties.
Where specific income or
earnings (whether monetary or advertising credits, whether convertible to cash
or not), figures are used and attributed to a specific individual or business,
that individual or business has earned that amount. There is no assurance that
you will do as well using the same information or strategies. If you rely on
the specific income or earnings figures used, you must accept all the risk of
not doing as well. The described experiences are atypical. Your financial
results are likely to differ from those described in the testimonials.
If a product or service
is new, you understand that it may not have been available for purchase long
enough to provide an accurate earnings history.
Miscellaneous Provisions
Protecting Your Account
If you have an account
with us, you are responsible for protecting your account’s username and
password to prevent misuse of your account by others that is unlawful or
violates these terms and conditions of use. We reserve the right to suspend or
terminate your account for misuse.
Title to Returned Physical Products
We do not take title to
a returned physical product until we receive it. In limited circumstances, and
at our sole discretion, we may issue a full or partial refund without the
return of a physical product you purchased from us. If we issue such a refund
without a product return, we do not take title to the product. See our
website’s Refunds and Returns Policy for more details.
Shipment and Risk of Loss
When you buy a physical
product from our website, the purchase is made per a shipment contract. Whether
we ship the product directly to you, or it is shipped to you by a third party
(e.g. a drop shipper), the risk of loss and title for each product purchased
from us passes to you once it has been delivered to the carrier (e.g. U.S.
Postal Service, U.P.S., FedEx etc.). We are not responsible for items lost
during transit.
Posted and Submitted Content
If you post content on
or submit content to our website (e.g. photos, customer reviews, comments,
etc.), you represent that you have the legal right to share such content on our
website, the content is accurate, and it does not violate the law or these
terms and conditions of use.
We reserve the right to
edit or delete content that you post or submit. However, we are not liable or
responsible for content that you and others submit or post on our website.
By posting or submitting
content to us, you grant us an irrevocable, non-exclusive, royalty-free,
perpetual, transferable, and sublicensable right to use the content. This
includes a global right for us to adapt, alter, display, distribute, publish,
reproduce, and translate the content. We can also create derivative works from
the content in all media types (e.g. print, audio, video, etc). You also grant
us the right to use your name and username in connection with such content.
If claims are made
against us because of the content you post or submit, you agree to indemnify
and defend us against those claims at your sole expense.
Agreement Between Us
These terms, conditions,
and policies are an agreement between us that does not expressly or implicitly
create any third party beneficiary rights.
Severability Of These Terms, Conditions, and Policies
If any part of these
terms, conditions, and policies are determined by a court of competent
jurisdiction to be invalid or unenforceable, that part shall be limited or
eliminated to the minimum extent necessary so that the remainder of these terms
and conditions are fully enforceable and legally binding.
How To Contact Us
Any questions or
concerns about these terms, conditions, and policies should be brought to our
attention by email to Support[at]DevWebSEO.com, and providing us with
information relating to your concern.
You may also mail your
concerns to us at the following address:
DevWebSEO
149 E Blackjack Branch
Way STE 2
Jacksonville, FL 32259
United States
If you want to serve us
with a subpoena, you must serve it on us by mail at our address listed above or
to our local resident agent if we have one in your state. To determine whether
we have a resident agent in your jurisdiction, check your state’s Secretary of
State’s website or contact that state official’s office. Subpoenas sent by
electronic means (email, fax, text message, etc.) will be ignored. To expedite
our response to your subpoena, be sure to send to the attention of “Subpoena
Processing” and include complete and accurate information.
Entire Agreement
These terms and
conditions, including the policies incorporated herein by express reference,
constitute your entire agreement with us with respect to your use of our
website.
Modifications and Termination
The above terms,
conditions, and policies may change from time to time. If such changes are
made, they will be effective immediately, and we will notify you by a notice
posted on our website’s home page that changes have been made. If you disagree
with the changes that have been made, you should not use our website. By
continuing to access our website after changes are made to these terms,
conditions and policies, you are agreeing to be legally bound by the revised
terms, conditions and policies.
We may terminate these
terms, conditions, and policies for any reason and at any time without notice
to you.
If you are concerned
about these terms, conditions, and policies, you should read them each time
before you use our website. Any questions or concerns should be brought to our
attention by sending an email to Support[at]DevWebSEO.com, and providing us
with information relating to your concern.
These terms, conditions,
and policies were last updated on August 10, 2018.
Digital Millennium Copyright Act
(“DMCA”) Notice
This notice is for
informational purposes only. It is not intended as, nor should it be construed
as, legal advice. If you believe that your intellectual property rights have been
infringed upon, or if a notice of infringement has been filed against you, you
should immediately seek legal counsel.
This website, including
all text, HTML, scripts, and images are copyrighted, owned, and/or licensed by DevWebSEO.
All rights reserved.
NO PART OF THIS WEBSITE
MAY BE REPRODUCED OR TRANSMITTED IN ANY FORM OR BY ANY MEANS, MECHANICAL,
ELECTRONIC, OR OTHERWISE, INCLUDING PHOTOCOPYING AND RECORDING, OR BY ANY
INFORMATION STORAGE AND RETRIEVAL SYSTEM, OR TRANSMITTED BY E-MAIL, OR USED IN
ANY OTHER FASHION WITHOUT THE EXPRESS PRIOR WRITTEN PERMISSION OF THE WEBSITE
OWNER.
This, of course,
excludes the downloading and temporary caching of this website on a personal
computer for the explicit purpose of viewing this website, as well as any
information clearly marked as reproducible. This copyright notice applies to
everyone, including all visitors to this website.
DMCA Provisions
The Digital Millennium
Copyright Act of 1998, found at 17 U.S.C. § 512 (“DMCA”), provides recourse for
owners of copyrighted materials who believe that their rights under United
States copyright law have been infringed upon on the Internet.
Under the DMCA, the bona
fide owner of copyrighted materials who has a good faith belief that their
copyright has been infringed may contact not only the person or entity
infringing on their copyright, but may also contact the designated agent of an
Internet service provider to report alleged infringements of their protected
works, when such alleged infringements appear on pages contained within the
system of the Internet service provider (“ISP”).
The owner of this
website and the ISP are committed to complying with international trade law,
international trade practices, all United States laws, including United States
copyright law. Upon receipt of a properly filed complaint under the DMCA, the
owner and/or the ISP of this website will block access to the allegedly
infringing material. The website owner and/or the ISP will forward a copy of
the notification of claimed copyright infringement to the alleged infringer.
Anyone who believes in good faith that a notice of copyright infringement has
wrongfully been filed against them, may submit a Counternotice to the website
owner and/or the ISP.
Notification Of Claimed Copyright Infringement
Please send DMCA
notifications of claimed copyright infringement to:
THE WEBSITE OWNER
Copyright Agent
DevWebSEO
149 E Blackjack Branch
Way STE 2
Jacksonville, FL 32259
United States
THE INTERNET SERVICE
PROVIDER (“ISP”)
Copyright Agent
A2 HOSTING
P.O. Box 2998 Ann Arbor,
MI 48106
Ann Arbor, MI 48106
Ann Arbor
abuse[at]a2hosting.com
1 734-222-4678
To file a notice of
infringement with either the website owner or the ISP, you must provide a
written communication that sets forth the items specified below. You will be
liable for damages (including damages, costs, and attorneys’ fees) if you
materially misrepresent that the website or a web page is infringing your
copyright. Accordingly, if you are not sure whether certain material of yours
is protected by copyright laws, we suggest that you first contact an attorney.
To expedite our ability
to process your request, please use the following format (including section
numbers):
1. Identify in
sufficient detail the copyrighted work that you believe has been infringed
upon.
2. Identify the material
that you claim is infringing the copyrighted work listed in item #1 above. (You
must include the URL(s) (the location(s) of the page(s) that contains the
allegedly infringing material and also include a description of the specific
content which you claim is infringing on your copyright.)
3. Provide information
reasonably sufficient to permit the website owner to contact you (e-mail
address and a phone number are required at a minimum).
4. Include the following
statement: “I swear, under penalty of perjury, that the information in the
notification is accurate and that I am the copyright owner or am authorized to
act on behalf of the owner of an exclusive right that is allegedly infringed. I
also affirm that as the copyright owner, I have a good faith belief that use of
the material in the manner complained of is not authorized by me, my agent, or
the law.”
5. The signature of the
copyright owner or a person authorized to act on behalf of the copyright owner.
You may send your notice via email provided such notice includes a proper
electronic signature. The signature or electronic signature must be that of the
copyright owner, or a person authorized to act on behalf of the owner, of an
exclusive copyright that has allegedly been infringed.
For details on the
information required for valid notification, see 17 U.S.C. § 512(c)(3).
Counternotification To Claimed Copyright Infringement
If a notice of copyright
infringement has been filed with the website owner and/or the ISP against you,
the owner and/or the ISP will attempt to notify you and provide you with a copy
of the notice of copyright infringement. If you have a good faith belief that
you have been wrongfully accused, you may file a counternotification with the
website owner and/or the ISP. If website owner and/or the ISP receives a valid
counternotification, the DMCA provides that the removed or blocked information
will be restored or access re-enabled.
The website owner and/or
the ISP will replace the removed material and cease disabling access to it in
not less than 10, nor more than 14, business days following receipt of the
counternotification, unless the website owner and/or ISP first receives notice
from the complaining party that such complaining party has filed an action seeking
a court order to restrain the alleged infringer from engaging in infringing
activity relating to the material on this website.
Please be advised that
United States copyright law provides substantial penalties for a false
counternotice filed in response to a notice of copyright infringement.
Accordingly, if you are not sure whether certain material of yours is protected
by copyright laws, we suggest that you first contact an attorney.
Copyright ©
2008-2018 Law Office of Michael E. Young PLLC and generated with Website Legal Forms
Generator software, and licensed for use
by the owner of this Website at DevWebSEO.com. All Rights Reserved. No portion
of this document may be copied or used by anyone other than the licensee
without the express written permission of the copyright owner. Use of this
document does not make the website owner a client of the law firm. Contact the
website owner with any questions or concerns about this site.
Your data may be shared
outside the EEA.
For all SAR requests
please visit this link: https://app.gdprtracker.co.uk/sar/DevWebSEO
Terms and Conditions
In using this website
you are deemed to have read and agreed to the following terms and conditions:
The following terminology
applies to these Terms and Conditions, Privacy Statement and any
disclaimer Notice and any or all Agreements: “Client”, “You” and “Your”
refers to you, the person accessing this website and accepting the Company’s
terms and conditions. “The Company”, “Ourselves”, “We” and “Us”, refers to our
Company. “Party”, “Parties”, or “Us”, refers to both the Client and ourselves,
or either the Client or ourselves. All terms refer to the offer, acceptance and
consideration of payment necessary to undertake the process of our assistance
to the Client in the most appropriate manner, whether by formal meetings
of a fixed duration, or any other means, for the express purpose of meeting the
Client’s needs in respect of provision of the Company’s stated services/products,
in accordance with and subject to, prevailing English Law. Any use of the above
terminology or other words in the singular, plural, capitalisation
and/or he/she or they, are taken as interchangeable and therefore as
referring to same.
Privacy Statement
We are committed to protecting your privacy. Authorised employees within the
company on a need to know basis only use any information collected from
individual Clients. We constantly review our systems and data to ensure the
best possible service to our Clients. There are specific offences for
unauthorised actions against computer systems and data. We will investigate any
such actions with a view to prosecuting and/or taking civil proceedings to
recover damages against those responsible
Confidentiality
Any information
concerning the Client and their respective Client Records may be passed to
third parties. However, Client records are regarded as confidential and
therefore will not be divulged to any third party, other than our employees and
if legally required to do so to the appropriate authorities. Clients have the
right to request sight of, and copies of any and all Client Records we keep, on
the proviso that we are given reasonable notice of such a request. Clients are
requested to retain copies of any literature issued in relation to the
provision of our services. Where appropriate, we shall issue Client’s with
appropriate written information, handouts or copies of records as part of an
agreed contract, for the benefit of both parties.
We will not sell, share,
or rent your personal information to any third party or use your e-mail address
for unsolicited mail. Any emails sent by this Company will only be in
connection with the provision of agreed services and products.
Disclaimer
Exclusions and Limitations
The information on this web site is provided on an “as is” basis. To the
fullest extent permitted by law, this Company:
·
excludes all
representations and warranties relating to this website and its contents or
which is or may be provided by any affiliates or any other third party,
including in relation to any inaccuracies or omissions in this website and/or
the Company’s literature; and
·
excludes all liability
for damages arising out of or in connection with your use of this website. This
includes, without limitation, direct loss, loss of business or profits (whether
or not the loss of such profits was foreseeable, arose in the normal course of
things or you have advised this Company of the possibility of such potential
loss), damage caused to your computer, computer software, systems and programs
and the data thereon or any other direct or indirect, consequential and
incidental damages.
This Company does not
however exclude liability for death or personal injury caused by its
negligence. The above exclusions and limitations apply only to the extent
permitted by law. None of your statutory rights as a consumer are affected.
Availability
Unless otherwise stated, the services featured on this website are only
available within the United Kingdom, or in relation to postings from the United
Kingdom. All advertising is intended solely for the United Kingdom market. You
are solely responsible for evaluating the fitness for a particular purpose of
any downloads, programs and text available through this site. Redistribution or
republication of any part of this site or its content is prohibited, including
such by framing or other similar or any other means, without the express
written consent of the Company. The Company does not warrant that the service
from this site will be uninterrupted, timely or error free, although it is
provided to the best ability. By using this service you thereby indemnify this
Company, its employees, agents and affiliates against any loss or damage, in
whatever manner, howsoever caused.
Log Files
We use IP addresses to analyse trends,
administer the site, track user’s movement, and gather broad demographic
information for aggregate use. IP addresses are not linked to personally
identifiable information. Additionally, for systems administration, detecting
usage patterns and troubleshooting purposes, our web servers automatically log
standard access information including browser type, access times/open mail, URL
requested, and referral URL. This information is not shared with third parties
and is used only within this Company on a need-to-know basis. Any individually
identifiable information related to this data will never be used in any way
different to that stated above without your explicit permission.
Cookies
Like most interactive web sites this
Company’s website uses cookies to enable us to retrieve user details for each
visit. Cookies are used in some areas of our site to enable the functionality
of this area and ease of use for those people visiting. Some of our affiliate
partners may also use cookies. [If you do not use cookies, delete this clause]
Links to this website
You may not create a link to any page of this website without our prior written
consent. If you do create a link to a page of this website you do so at your
own risk and the exclusions and limitations set out above will apply to your
use of this website by linking to it.
Links from this website
We do not monitor or review the content of other party’s websites which are
linked to from this website. Opinions expressed or material appearing on such
websites are not necessarily shared or endorsed by us and should not be
regarded as the publisher of such opinions or material. Please be aware that we
are not responsible for the privacy practices, or content, of these sites. We
encourage our users to be aware when they leave our site & to read the
privacy statements of these sites. You should evaluate the security and
trustworthiness of any other site connected to this site or accessed through
this site yourself, before disclosing any personal information to them. This
Company will not accept any responsibility for any loss or damage in whatever
manner, howsoever caused, resulting from your disclosure to third parties of
personal information.
Copyright and Trademark
Copyright and other relevant intellectual property rights exists on all text
relating to the Company’s services and the full content of this website.
This Company’s logo is a
registered trademark of this Company in the United Kingdom and other countries.
The brand names and specific services of this Company featured on this web site
are trade marked
Communication
We have several different e-mail
addresses for different queries. These, & other contact information, can be
found on our Contact Us link on our website or via Company
literature or via the Company’s stated telephone, facsimile or mobile telephone
numbers.
Alex Woodward P.O. Box
600292 Jacksonville FL 32260
Force Majeure
Neither party shall be
liable to the other for any failure to perform any obligation under any
Agreement which is due to an event beyond the control of such party including
but not limited to any Act of God, terrorism, war, Political insurgence,
insurrection, riot, civil unrest, act of civil or military authority, uprising,
earthquake, flood or any other natural or man made eventuality outside of our
control, which causes the termination of an agreement or contract entered into,
nor which could have been reasonably foreseen. Any Party affected by such event
shall forthwith inform the other Party of the same and shall use all reasonable
endeavours to comply with the terms and conditions of any Agreement contained
herein.
Waiver
Failure of either Party
to insist upon strict performance of any provision of this or any Agreement or
the failure of either Party to exercise any right or remedy to which it, he or
they are entitled hereunder shall not constitute a waiver thereof and shall not
cause a diminution of the obligations under this or any Agreement. No waiver of
any of the provisions of this or any Agreement shall be effective unless it is
expressly stated to be such and signed by both Parties.
General
The laws of England and
Wales govern these terms and conditions. By accessing this website [and using
our services/buying our products] you consent to these terms and conditions and
to the exclusive jurisdiction of the English courts in all disputes arising out
of such access. If any of these terms are deemed invalid or unenforceable for
any reason (including, but not limited to the exclusions and limitations set
out above), then the invalid or unenforceable provision will be severed from
these terms and the remaining terms will continue to apply. Failure of the
Company to enforce any of the provisions set out in these Terms and Conditions
and any Agreement, or failure to exercise any option to terminate, shall not be
construed as waiver of such provisions and shall not affect the validity of
these Terms and Conditions or of any Agreement or any part thereof, or the
right thereafter to enforce each and every provision. These Terms and
Conditions shall not be amended, modified, varied or supplemented except in
writing and signed by duly authorised representatives of the Company.
Notification of Changes
The Company reserves the
right to change these conditions from time to time as it sees fit and your
continued use of the site will signify your acceptance of any adjustment to
these terms. If there are any changes to our privacy policy, we will announce
that these changes have been made on our home page and on other key pages on
our site. If there are any changes in how we use our site Clients’ Personally
Identifiable Information, notification by e-mail or postal mail will be made to
those affected by this change. Any changes to our privacy policy will be posted
on our web site 30 days prior to these changes taking place. You are therefore
advised to re-read this statement on a regular basis
© DevWebSEO 2020 All
Rights Reserved
DevWebSEO
Privacy Policy and
Cookie Policy
4/11/2020
Background:
DevWebSEO understands
that your privacy is important to you and that you care about how your
information is used and shared online. We respect and value the privacy of
everyone who visits Our Site and will only collect and use information in ways
that are useful to you and in a manner consistent with your rights and Our
obligations under the law.
This Policy applies to
Our use of any and all data collected by us in relation to your use of Our
Site. Please read this Privacy Policy carefully and ensure that you understand
it. [Your acceptance of Our Privacy Policy is deemed to occur upon your
first use of Our Site] AND/OR [You will be required to read and
accept this Privacy Policy when signing up for an Account]. If you do not
accept and agree with this Privacy Policy, you must stop using Our Site
immediately.
1.
Definitions and
Interpretation
In this Policy the
following terms shall have the following meanings:
“Account” |
means an account required to access and/or use certain
areas and features of Our Site; |
“Cookie” |
means a small text file placed on your computer or device
by Our Site when you visit certain parts of Our Site and/or when you use
certain features of Our Site. Details of the Cookies used by Our Site are set
out in section 12, below;] |
“Our Site” |
means this website, DevWebSEO.com; |
“USA and EU
Cookie Law” |
means the relevant parts of the Privacy and Electronic
Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and
2015; and] |
|
|
2.
Information About Us
·
Our Site, com,
is [owned and] operated by DevWebSEO, whose
main trading address is] OR Alex Woodward P.O. BOX 600292
Jacksonville FL 32260
3.
Scope – What Does This
Policy Cover?
This Privacy Policy
applies only to your use of Our Site. It does not extend to any websites that
are linked to from Our Site (whether We provide those links or whether they are
shared by other users). We have no control over how your data is collected,
stored or used by other websites and We advise you to check the privacy
policies of any such websites before providing any data to them.
4.
What Data Do We Collect?
Some data will be
collected automatically by Our Site [(for further details, please see
section 12 on Our use of Cookies [and Our Cookie Policy, other data will
only be collected if you voluntarily submit it and consent to Us using it for
the purposes set out in section 5, for example, when signing up for an Account.
Depending upon your use of Our Site, We may collect some or all of the
following data:
·
[Name;]
·
[date of birth;]
·
[gender;]
·
[business/company name]
·
[job title;]
·
[profession;]
·
[contact information
such as email addresses and telephone numbers;]
·
[demographic information
such as post code, preferences and interests;]
·
[financial information
such as credit / debit card numbers;]
·
[IP address
(automatically collected);]
·
[web browser type and
version (automatically collected);]
·
[operating system
(automatically collected);]
·
[a list of URLs starting
with a referring site, your activity on Our Site, and the site you exit to (automatically
collected);]
·
[add further information
as required.]
5.
How Do We Use Your Data?
·
All personal data is
stored securely in accordance with the EU General
Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6,
below.
·
We use your data to provide
the best possible [products and] services to you. This
includes:
·
[Providing and managing
your Account;]
·
[Providing and managing
your access to Our Site;]
·
[Personalising and
tailoring your experience on Our Site;]
·
[Supplying Our [products
and] services to you;]
·
[Personalising and
tailoring Our [products and] services for you;]
·
[Responding to
communications from you;]
·
[Supplying you with
email Insert Type of Email e.g. newsletters, alerts etc. that you have
subscribed to (you may unsubscribe or opt-out at any time by Insert Description
of Unsubscription Method;]
·
[Market research;]
·
[Analysing your use of
Our Site [and gathering feedback] to enable Us to continually improve Our Site
and your user experience;]
·
[Add further uses as
required.]
·
In some cases, the
collection of data may be a statutory or contractual requirement, and We will
be limited in the [products and] services We can provide you without your
consent for Us to be able to use such data.
·
With your permission
and/or where permitted by law, We may also use your data for marketing purposes
which may include contacting you by support@DevWebSEO.com with information, news
and offers on Our [products] AND/OR [services]. We will
not, however, send you any unsolicited marketing or spam and will take all
reasonable steps to ensure that We fully protect your rights and comply with
Our obligations under the GDPR and the Privacy and Electronic Communications
(EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
·
[Advertisers whose
content appears on Our Site may engage in what is known as “behavioural
advertising” – advertising which is tailored to your preferences, based on your
activity. Your activity is monitored using Cookies, as detailed below in
section 12. You can control and limit your data used in this way by adjusting
your web browser’s privacy settings. Please note that We do not control the
activities of such advertisers, nor the information they collect and use.
Limiting the use of your data in this way will not remove the advertising, but
it will make it less relevant to your interests and activities on Our Site.]
·
Under GDPR we will
ensure that your personal data is processed lawfully, fairly, and
transparently, without adversely affecting your rights. We will only process
your personal data if at least one of the following basis applies:
·
you have given consent
to the processing of your personal data for one or more specific purposes;
·
processing is necessary
for the performance of a contract to which you are a party or in order to take
steps at the request of you prior to entering into a contract;
·
processing is necessary
for compliance with a legal obligation to which we are subject;
·
processing is necessary
to protect the vital interests of you or of another natural person;
·
processing is necessary
for the performance of a task carried out in the public interest or in the
exercise of official authority vested in the controller; and/or
·
processing is necessary
for the purposes of the legitimate interests pursued by us or by a third party,
except where such interests are overridden by the fundamental rights and
freedoms of the data subject which require protection of personal data, in
particular where the data subject is a child. [List specific legitimate
interests if available].
6.
How and Where Do We
Store Your Data?
·
We only keep your data
for as long as We need to in order to use it as described above in section 5,
and/or for as long as We have your permission to keep it. In any event, We will
conduct an [annual] review to ascertain whether we need to
keep your data. Your data will be deleted if we no longer need it in accordance
with the terms of our Data Retention Policy. Our Data Retention Policies are:
Email
Medical data
Biometric data
Personal data
·
[Your data will only be
stored within the European Economic Area (“the EEA”) (The EEA consists of all
EU member states, plus Norway, Iceland and Liechtenstein).]
OR
·
[Some or all of your
data may be stored or transferred outside of the European Economic Area (“the
EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and
Liechtenstein). You are deemed to accept and agree to this by using Our Site
and submitting information to Us. If We do store or transfer data outside the
EEA, We will take all reasonable steps to ensure that your data is treated as
safely and securely as it would be within the EEA and under the GDPR. Such
steps may include, but not be limited to, the use of legally binding
contractual terms between Us and any third parties We engage and the use of the
EU-approved Model Contractual Arrangements. [If We intend at any time to
transfer any of your data outside the EEA, We will always obtain your consent beforehand
and we have put in place the following safeguards to protect your data:
password protected and encrypted by third-party services
·
Data security is of
great importance to Us, and to protect your data We have put in place suitable
physical, electronic and managerial procedures to safeguard and secure data
collected through Our Site.
·
Steps We take to secure
and protect your data include:
·
password protected and
encrypted by third-party services
·
Notwithstanding the
security measures that We take, it is important to remember that the
transmission of data via the internet may not be completely secure and that you
are advised to take suitable precautions when transmitting to Us data via the
internet.
7.
Do We Share Your Data?
·
[We may share your data
with other companies in Our group.
·
We may contract with
third parties to supply [products and] services to you
on Our behalf. These may include payment processing, delivery of goods, search
engine facilities, advertising and marketing. In some cases, the third parties
may require access to some or all of your data. Where any of your data is
required for such a purpose, We will take all reasonable steps to ensure that
your data will be handled safely, securely, and in accordance with your rights,
Our obligations, and the obligations of the third party under the law. We
currently contract with:
·
[We may compile
statistics about the use of Our Site including data on traffic, usage patterns,
user numbers, sales and other information. All such data will be anonymised and
will not include any personally identifying information. We may from time to
time share such data with third parties such as prospective investors,
affiliates, partners and advertisers. Data will only be shared and used within
the bounds of the law.]
·
In certain circumstances
We may be legally required to share certain data held by Us, which may include
your personal information, for example, where We are involved in legal
proceedings, where We are complying with the requirements of legislation, a
court order, or a governmental authority. We do not require any further consent
from you in order to share your data in such circumstances and will comply as
required with any legally binding request that is made of Us.
8.
What Happens If Our
Business Changes Hands?
·
We may, from time to
time, expand or reduce Our business and this may involve the sale and/or the
transfer of control of all or part of Our business. Data provided by users
will, where it is relevant to any part of Our business so transferred, be
transferred along with that part and the new owner or newly controlling party
will, under the terms of this Privacy Policy, be permitted to use the data for
the purposes for which it was originally collected by Us.
·
In the event that any of
your data is to be transferred in such a manner, you will [not] be
contacted in advance and informed of the changes. [When contacted you
will [not, however,] be given the choice to have your data deleted or withheld
from the new owner or controller.]
9.
How Can You Control Your
Data?
·
When you submit
information via Our Site, you may be given options to restrict Our use of your
data. We aim to give you strong controls on Our use of your data (including the
ability to opt-out of receiving emails from Us which you may do by unsubscribing
using the links provided in Our emails and [at the point of providing
your details] AND/OR [by managing your Account]).
·
You may also wish to
sign up to one or more of the preference services operating in the USA: The
Telephone Preference Service (“the TPS”), the Corporate Telephone Preference
Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may
help to prevent you receiving unsolicited marketing. Please note, however, that
these services will not prevent you from receiving marketing communications
that you have consented to receiving.
10.
Your Right to Withhold
Information and Your Right to Withdraw Information After You Have Given it
·
You may access [certain
areas of] Our Site without providing any data at all. [However,
to use all features and functions available on Our Site you may be required to
submit or allow for the collection of certain data.]
·
You may restrict your
internet browser’s use of Cookies. For more information, see section 12.
·
You may withdraw your
consent for Us to use your personal data as set out in section in 5 at any time
by contacting Us using the details set out in section 15, and We will delete
Your data from Our systems. However, you acknowledge this may limit Our ability
to provide the best possible [products and] services to you.
11.
How Can You Access Your
Data?
You have the legal right
to ask for a copy of any of your personal data held by Us (where such data is
held). Please contact Us for more details at support@DevWebSEO.com or using the contact
details below in section 14.
12.
[What Cookies Do We Use
and What For?
·
Our Site may place and
access certain first party Cookies on your computer or device. First party
Cookies are those placed directly by Us and are used only by Us. We use Cookies
to facilitate and improve your experience of Our Site and to provide and
improve Our [products and] For more details, please refer to
section 5, above, and to section 12.6 below. We have carefully chosen these
Cookies and have taken steps to ensure that your privacy is protected and
respected at all times.
·
By using Our Site you
may also receive certain third party Cookies on your computer or device. Third
party Cookies are those placed by websites, services, and/or parties other than
Us. We use third party Cookies on Our Site for analytics and to keep
improving your user experience. For more details, please refer to section
5, above, and to section 12.6 below. These Cookies are not integral to the
functioning of Our Site.
·
All Cookies used by and
on Our Site are used in accordance with current English and EU Cookie Law.
·
Before [any] Cookies
are placed on your computer or device [, subject to section
12.5] AND/OR [section 12.8], you will be shown a pop-up
tab on the bottom of our website requesting your consent to set those
Cookies. By giving your consent to the placing of Cookies you are enabling Us
to provide the best possible experience and service to you. You may, if you
wish, deny consent to the placing of Cookies; however certain features of Our
Site may not function fully or as intended. [You will be given the
opportunity to allow only first party Cookies and block third party Cookies.]
·
[Certain features of Our
Site depend on Cookies to function. [Your Country] and EU Cookie Law deems
these Cookies to be “strictly necessary”. These Cookies are shown below in
section 12.6. Your consent will not be sought to place these Cookies. You may
still block these Cookies by changing your internet browser’s settings as
detailed below in section 12.10, but please be aware that Our Site may not work
as intended if you do so. We have taken great care to ensure that your privacy
is not at risk by allowing them.]
·
The following first
party Cookies may be placed on your computer or device:
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·
Our Site uses analytics
services provided by Google Analytics, Thrive Themes, Active Champaign,
Stripe, Click Funnels, and Infusionsoft. Website analytics refers to a set
of tools used to collect and analyse usage statistics, enabling Us to better
understand how people use Our Site. This, in turn, enables Us to improve Our
Site and the [products and] services offered through it. You
do not have to allow Us to use these Cookies, as detailed below, however whilst
Our use of them does not pose any risk to your privacy or your safe use of Our
Site, it does enable Us to continually improve Our Site, making it a better and
more useful experience for you.
·
The analytics service(s)
used by Our Site use(s) Cookies to gather the required information. [Certain
of these Cookies may be placed immediately when you first visit Our Site and it
may not be possible for Us to obtain your prior consent. You may remove these
Cookies and prevent future use of them by following the steps set out below in
section 12.10.]
·
The analytics service(s)
used by Our Site use Cookies:
·
You can choose to enable
or disable Cookies in your internet browser. Most internet browsers also enable
you to choose whether you wish to disable all cookies or only third-party
cookies. By default, most internet browsers accept Cookies but this can be
changed. For further details, please consult the help menu in your internet
browser or the documentation that came with your device.
·
You can choose to delete
Cookies at any time however you may lose any information that enables you to
access Our Site more quickly and efficiently including, but not limited to,
login and personalisation settings.
·
It is recommended that
you keep your internet browser and operating system up-to-date and that you
consult the help and guidance provided by the developer of your internet
browser and manufacturer of your computer or device if you are unsure about
adjusting your privacy settings.]
OR
12.
[Cookies
Our Site may place and
access certain first party Cookies on your computer or device. First party
Cookies are those placed directly by Us and are used only by Us. We use Cookies
to facilitate and improve your experience of Our Site and to provide and
improve Our [products and] services. By using Our Site you may also
receive certain third party Cookies on your computer or device. Third party
Cookies are those placed by websites, services, and/or parties other than Us.
We use third party Cookies on Our Site for [Insert description of use of third
party cookies, e.g. advertising services]. In addition, Our Site uses
analytics services provided by [Insert name of analytics service provider(s)],
which also use Cookies. Website analytics refers to a set of tools used to
collect and analyse usage statistics, enabling Us to better understand how people
use Our Site. For more details, please refer to Our Cookie Policy.
13.
Summary of Your Rights
under GDPR
Under the GDPR, you
have:
·
the right to request
access to, deletion of or correction of, your personal data held by Us;
·
the right to complain to
a supervisory authority;
·
be informed of what data
processing is taking place;
·
the right to restrict
processing;
·
the right to data
portability;
·
object to processing of
your personal data;
·
rights with respect to
automated decision-making and profiling (see section 14 below).
To enforce any of the
foregoing rights or if you have any other questions about Our Site or this
Privacy Policy, please contact Us using the details set out in section 15
below.
14.
Automated
Decision-Making and Profiling
14.1
In the event that We use personal data for the purposes of
automated decision-making and those decisions have a legal (or similarly
significant effect) on You, You have the right to challenge to such decisions
under GDPR, requesting human intervention, expressing their own point of view,
and obtaining an explanation of the decision from Us.
14.2 The right described
in section 14.1 does not apply in the following circumstances:
1.
The decision is
necessary for the entry into, or performance of, a contract between the You and
Us;
2.
The decision is
authorised by law; or
3.
You have given you
explicit consent.
·
Where We use your
personal data for profiling purposes, the following shall apply:
1.
Clear information
explaining the profiling will be provided, including its significance and the
likely consequences;
2.
Appropriate mathematical
or statistical procedures will be used;
3.
Technical and
organisational measures necessary to minimise the risk of errors and to enable
such errors to be easily corrected shall be implemented; and
4.
All personal data
processed for profiling purposes shall be secured in order to prevent
discriminatory effects arising out of profiling.
·
We currently make the
following automated decisions:
14.5 We currently
profile your personal data for the following purposes:
15.
Contacting Us
If you have any
questions about Our Site or this Privacy Policy, please contact Us by email
at support@DevWebSEO.com. Please ensure that your query is clear,
particularly if it is a request for information about the data We hold about
you (as under section 11, above).
16.
Changes to Our Privacy
Policy
We may change this
Privacy Policy as we may deem necessary from time to time, or as may be
required by law. Any changes will be immediately posted on Our Site and you
will be deemed to have accepted the terms of the Privacy Policy on your first
use of Our Site following the alterations. We recommend that you check this
page regularly to keep up-to-date.
DevWebSEO
IT Security Policy
4/11/2020
1.
Introduction
This document sets out
the measures to be taken by all employees of DevWebSEO (the
“Company”) and by the Company as a whole in order to protect the Company’s
computer systems, devices, infrastructure, computing environment and any and
all other relevant equipment (collectively, “IT Systems”) from damage and
threats whether internal, external, deliberate or accidental.
2.
Key Principles
·
All IT Systems are to be
protected against unauthorised access.
·
All IT Systems are to be
used only in compliance with relevant Company Policies.
·
All data stored on IT
Systems are to be managed securely in compliance with all relevant parts of the
GDPR and all other laws governing data protection whether now or in the future
in force.
·
All employees of the
Company and any and all third parties authorised to use the IT Systems
including, but not limited to, contractors and sub-contractors (collectively,
“Users”), must ensure that they are familiar with this Policy and must adhere
to and comply with it at all times.
·
All line managers must
ensure that all Users under their control and direction must adhere to and
comply with this Policy at all times as required under paragraph 2.4.
·
All IT Systems are to be
installed, maintained, serviced, repaired and upgraded by (the “IT Department”)
or by such third party/parties as the IT Department may from time to time
authorise.
·
The responsibility for
the security and integrity of all IT Systems and the data stored thereon (including,
but not limited to, the security, integrity and confidentiality of that data)
lies with the IT Department unless expressly stated otherwise.
·
All breaches of security
pertaining to the IT Systems or any data stored thereon shall be reported and
subsequently investigated by the IT Department.
·
All Users must report
any and all security concerns relating to the IT Systems or to the data stored
thereon immediately to the IT Department.
3.
IT Department
Responsibilities
·
The IT Manager, shall be
responsible for the following:
1.
ensuring that all IT
Systems are assessed and deemed suitable for compliance with the Company’s
security requirements;
2.
ensuring that IT
security standards within the Company are effectively implemented and regularly
reviewed, by way of periodic audits and risk assessments, with regular reports
being made to the Company’s internal senior management on the condition of the
Company’s information security and compliance with this Policy;
3.
ensuring organisational
management and dedicated staff responsible for the development, implementation
and maintenance of this Policy;
4.
carrying out
vulnerability assessments and patch management by using threat protection
technologies and scheduled monitoring procedures designed to identify, assess,
mitigate and protect against identified security threats, viruses and other
malicious code; and
5.
ensuring that all Users
are kept aware of the requirements of this Policy and of all related
legislation, regulations and other relevant rules whether now or in the future
in force including, but not limited to, the GDPR and the Computer Misuse Act
1990.
·
The IT Department shall
be responsible for the following:
1.
assisting all Users in
understanding and complying with this Policy;
2.
providing all Users with
appropriate support and training in IT security matters and use of IT Systems;
3.
ensuring that all Users
are granted levels of access to IT Systems that are appropriate for each User,
taking into account their job role, responsibilities and any special security
requirements;
4.
receiving and handling
all reports relating to IT security matters and taking appropriate action in
response;
5.
taking proactive action,
where possible, to establish and implement IT security procedures and raise
User awareness;
6.
assisting the IT Manager
in monitoring all IT security within the Company and taking all necessary
action to implement this Policy and any changes made to this Policy in the
future;
7.
ensuring that regular
backups are taken of all data stored within the IT Systems at intervals no less
than year and that such backups are stored at a suitable
location off the Company premises; and
8.
[ensure compliance with
all IT security standards set out in ISO 27001, to the extent such standards
are not covered by the obligations set out in clause 3.2 a) – g).]
4.
Users’ Responsibilities
·
All Users must comply
with all relevant parts of this Policy at all times when using the IT Systems.
·
All Users must use the
IT Systems only within the bounds of English law and must not use the IT
Systems for any purpose or activity which is likely to contravene any English
law whether now or in the future in force.
·
Users must immediately
inform the IT Department of any and all security concerns relating to the IT
Systems.
·
Users must immediately
inform the IT Department of any other technical problems (including, but not
limited to, hardware failures and software errors) which may occur on the IT
Systems.
·
Any and all deliberate
or negligent breaches of this Policy by Users will be handled as appropriate
under the Company’s disciplinary procedures.
5.
Software Security
Measures
·
All software in use on
the IT Systems (including, but not limited to, operating systems and individual
software applications) will be kept up-to-date and any and all relevant
software updates, patches, fixes and other intermediate releases will be
applied at the sole discretion of the IT Department. This provision does not
extend to upgrading software to new ‘major releases’ (e.g. from version 1.0 to
version 2.0), only to updates within a particular major release (e.g. from
version 1.0 to version 1.0.1 etc.). Unless a software update is available
free of charge it will be classed as a major release and thus falls within the
remit of new software procurement and outside the scope of this provision.
·
Where any security flaw
is identified in any software that flaw will be either fixed immediately or the
software may be withdrawn from the IT Systems until such time as the security
flaw can be effectively remedied.
·
No Users may install any
software of their own, whether that software is supplied on physical media
(e.g. DVD-Rom) or whether it is downloaded, without the approval of the IT
Manager. Any software belonging to Users must be approved by the IT Manager and
may only be installed where that installation poses no security risk to the IT
Systems and where the installation would not breach any licence agreements to
which that software may be subject.
·
All software will be
installed onto the IT Systems by the IT Department unless an individual User is
given written permission to do so by the IT Manager. Such written permission
must clearly state which software may be installed and onto which computer(s)
or device(s) it may be installed.
6.
Anti-Virus Security
Measures
·
Most IT Systems
(including all computers and servers) will be protected with suitable
anti-virus, firewall and internet security software. All such anti-virus,
firewall and internet security software will be kept up-to-date with the latest
software updates and definitions.
·
All IT Systems protected
by anti-virus software will be subject to a full system scan at least
·
All storage media (e.g.
USB memory sticks or disks of any kind) used by Users for transferring files
must be virus-scanned before any files may be transferred. Such virus scans
shall be performed automatically upon connection / insertion of media]
OR by the IT Staff / Manager.
·
Users shall [not] be
permitted to transfer files using cloud storage systems. [All files
downloaded from any cloud storage system must be scanned for viruses during the
download process.]
·
Any files being sent to
third parties outside the Company, whether by email, on physical media or by
other means (e.g. FTP or shared cloud storage) must be scanned for viruses
before being sent or as part of the sending process, as appropriate. [All
email attachments are scanned automatically upon sending.]
·
Where any virus is
detected by a User this must be reported immediately to the IT Department (this
rule shall apply even where the anti-virus software automatically fixes the
problem). The IT Department shall promptly take any and all necessary action to
remedy the problem. In limited circumstances this may involve the
temporary removal of the affected computer or device. Wherever possible a
suitable replacement computer or device will be provided within 30 days to
limit disruption to the User.
·
Where any User
deliberately introduces any malicious software or virus to the IT Systems this
will constitute a criminal offence under the Computer Misuse Act 1990 and will
be handled as appropriate under the Company’s disciplinary procedures.
7.
Hardware Security
Measures
·
Wherever practical, IT
Systems will be located in rooms which may be securely locked when not in use
or, in appropriate cases, at all times whether in use or not (with authorised
Users being granted access by means of a key, smart card, door code or
similar). Where access to such locations is restricted, Users must not allow
any unauthorised individual access to such locations for any reason.
·
All IT Systems not intended
for normal use by Users (including, but not limited to, servers, networking
equipment and network infrastructure) and any other areas where personal data
may be stored (eg. data centre or server room facilities) shall be designed to
(i) protect information and physical assets from unauthorised physical access,
(ii) manage, monitor and log movement of persons into and out of the relevant
facilities, and (iii) guard against environmental hazards such as heat, fire
and water damage.
·
No Users shall have
access to any IT Systems not intended for normal use by Users (including such
devices mentioned above) without the express permission of the IT Manager.
Under normal circumstances whenever a problem with such IT Systems is
identified by a User, that problem must be reported to the IT Department.
Under no circumstances should a User attempt to rectify any such problems
without the express permission (and, in most cases, instruction and/or
supervision) of the IT Manager.
·
All non-mobile devices
(including, but not limited to, desktop computers, workstations and monitors)
shall, wherever possible and practical, be physically secured in place with a
suitable locking mechanism. Where the design of the hardware allows, computer
cases shall be locked to prevent tampering with or theft of internal
components.
·
All mobile devices
(including, but not limited to, laptops, netbooks, tablets, PDAs and mobile
telephones) provided by the Company should always be transported securely and
handled with care. In circumstances where such mobile devices are to be left
unattended they should be placed inside a lockable case or other suitable
container. Users should make all reasonable efforts to avoid such mobile
devices from being left unattended at any location other than their private
homes or Company premises. If any such mobile device is to be left in a
vehicle it must be stored out of sight.
·
The IT Department shall
maintain a complete asset register of all IT Systems. All IT Systems shall be
labelled and the corresponding data shall be kept on the asset register.
8.
Access Security
·
All IT Systems (and in
particular mobile devices including, but not limited to, laptops, netbooks,
tablets, PDAs and mobile telephones) shall be protected with a secure password
or such other form of secure log-in system as the IT Department may deem
appropriate. Such alternative forms of secure log-in may include fingerprint
identification and facial recognition.
·
Logical access controls
designed to manage electronic access to data and IT System functionality based
on authority levels and job functions, (e.g. granting access on a need-to-know
and least privilege basis, use of unique IDs and passwords for all Users,
periodic review and revoking/changing access promptly when employment terminates
or changes in job functions occur).
·
All passwords must,
where the software, computer or device allows:
·
be at least 16 characters
long;
·
contain a combination
of [upper and lower case letter/numbers/spaces/symbols etc];
·
be changed at least
every 200 days;
·
be different from the
previous password;
·
not be obvious or easily
guessed (e.g. birthdays or other memorable dates, memorable names, events or
places etc.);
·
be created by individual
Users; and
·
newly issued passwords
must be changed after first use
·
Passwords should be kept
secret by each User. Under no circumstances should a User share their password
with anyone including the IT Manager and the IT Staff. No User will be
legitimately asked for their password by anyone at any time and any such
request should be refused. If a User has reason to believe that another
individual has obtained their password they should change their password
immediately [and report the suspected breach of security to the IT
Department].
·
If a User forgets their
password, this should be reported to the IT Department. The IT Department will
take the necessary steps to restore the User’s access to the IT Systems which
may include the issuing of a temporary password which may be fully or partially
known to the member of the IT Staff responsible for resolving the issue.
A new password must be set up by the User immediately upon the restoration of
access to the IT Systems.
·
All IT Systems with
displays and user input devices (e.g. mouse, keyboard, touchscreen etc.) shall
be protected, where possible, with a password protected screensaver that will
activate after one year of inactivity. This time period cannot
be changed by Users and Users may not disable the screensaver. Activation
of the screensaver will not interrupt or disrupt any other activities taking
place on the computer (e.g. data processing).
·
The IT Department shall
conduct regular system audits or event logging and related monitoring
procedures to proactively record User access and activity on the IT Systems for
routine review.
·
Users may not use any
software which may allow outside parties to access the IT Systems without the
express consent of the IT Manager. Any such software must be reasonably
required by the User for the performance of their job role and must be fully
inspected and cleared by the IT Manager.
·
[Users may connect their
own devices (including, but not limited to, mobile telephones, tablets and
laptops) to the Company network subject to the approval of the IT Department.
Any and all instructions and requirements provided by the IT Department
governing the use of Users’ own devices when connected to the Company network
must be followed at all times. Users’ use of their own devices shall be
subject to, and governed by, all relevant Company Policies (including, but not
limited to, this Policy) while those devices are connected to the Company
network or to any other part of the IT Systems. The IT Department shall
reserve the right to request the immediate disconnection of any such devices
without notice.]
9.
Data Protection
·
All personal data (as
defined in the General Data Protection Regulation (“GDPR”)) collected, held and
processed by the Company will be collected, held and processed strictly in
accordance with the GDPR and the Company’s Data Protection Policy.
·
The IT Department shall
ensure there are data security controls which include at a minimum, but may not
be limited to, logical segregation of data, restricted (e.g. role-based) access
and monitoring, and utilisation of commercially available and industry standard
encryption technologies for personal data that is:
1.
transmitted over public
networks (i.e. the Internet) or when transmitted wirelessly; or
2.
at rest or stored on
portable or removable media (i.e. laptop computers, CD/DVD, USB drives, back-up
tapes).
·
All emails containing
personal data must be encrypted Active Champaign encription
·
Personal data contained
in the body of an email, whether sent or received, should be copied from the
body of that email and stored securely. The email itself should be
deleted. All temporary files associated therewith should also be deleted.
·
Where personal data is
to be sent by facsimile transmission the recipient should be informed in
advance of the transmission and should be waiting by the fax machine to receive
the data.
·
If personal data is
being viewed on a computer screen and the computer in question is to be left
unattended for any period of time, the user must lock the computer and screen
before leaving it.
·
No personal data should
be transferred to any device personally belonging to an employee and personal
data may only be transferred to devices belonging to agents, contractors, or
other parties working on behalf of the Company where the party in question has
agreed to comply fully with the letter and spirit of this Policy and of GDPR
(which may include demonstrating to the Company that all suitable technical and
organisational measures have been taken).
·
The IT Department shall
ensure operational procedures and controls to provide to provide for the secure
disposal of any part of the IT Systems or any media to render all information
or data contained therein as undecipherable or unrecoverable prior to final
disposal or release from the Company’s possession.
·
Where any personal data
is to be erased or otherwise disposed of for any reason (including where copies
have been made and are no longer needed), it should be securely deleted and
disposed of. Hardcopies should be shredded, and electronic copies should be
deleted securely using Trend Micro
·
The IT Department shall
ensure that it has in place appropriate technical and, to protect against
unauthorised or unlawful processing of personal data and against accidental
loss or destruction of, or damage to, personal data, appropriate to the harm
that might result from the unauthorised or unlawful processing or accidental
loss, destruction or damage and the nature of the data to be protected, having
regard to the state of technological development and the cost of implementing
any measures (those measures may include, where appropriate, pseudonymising and
encrypting personal data, ensuring confidentiality, integrity, availability and
resilience of its systems and services, ensuring that availability of and
access to personal data can be restored in a timely manner after an incident,
and regularly assessing and evaluating the effectiveness of the technical and
organisational measures adopted by it).
·
All personal data stored
electronically should be backed up month with backups
stored [onsite] AND/OR [offsite]. All backups should be
encrypted using passwords
·
All electronic copies of
personal data should be stored securely using passwords and data encryption.
·
Where personal data held
by the Company is used for marketing purposes, it shall be the responsibility
of the Data Privacy Manager to ensure that no data subjects
have added their details to any marketing preference databases including, but
not limited to, the Telephone Preference Service, the Mail Preference Service,
the Email Preference Service, and the Fax Preference Service. Such details should
be checked at least once per year.
·
Only Users that need
access to, and use of, personal data in order to carry out their assigned
duties correctly shall have access to personal data held by the Company.
·
All Users handling
personal data for and on behalf of the Company shall be subject to, and must
comply with, the provisions of the Company’s Data Protection Policy.
10.
Internet and Email Use
·
All Users shall be
subject to, and must comply with, the provisions of the Company’s
Communications, Email and Internet Policy when using the IT Systems.
·
Where provisions in this
Policy require any additional steps to be taken to ensure IT security when
using the internet or email over and above the requirements imposed by the
Communications, Email and Internet Policy, Users must take such steps as
required.
11.
Reporting IT Security
Breaches
·
All concerns, questions,
suspected breaches or known breaches shall be referred immediately to the
IT Department OR the IT Manager]OR a member of the IT Staff.
·
Upon receiving a question
or notification of a breach, the IT Department shall, within 30 days assess
the issue including, but not limited to, the level of risk associated
therewith, and shall take any and all such steps as the IT Department deems
necessary to respond to the issue.
·
Under no circumstances
should a User attempt to resolve an IT security breach on their own without
first consulting the IT Department. Users may only attempt to resolve IT
security breaches under the instruction of, and with the express permission of,
the IT Department.
·
All IT security
breaches, whether remedied by the IT Department or by a User under the IT
Department’s direction, shall be fully documented.
12.
Business Continuity
The Company shall have
in place adequate business resiliency/continuity and disaster recovery
procedures designed to maintain any information and the supply of any service
and/or recovery from foreseeable emergency situations or disasters.
13.
Implementation of Policy
This Policy shall be
deemed effective as of [Insert Date]. No part of this Policy
shall have retroactive effect and shall thus apply only to matters occurring on
or after this date.
This Policy has been
approved and authorised by:
Name: |
DevWebSEO |
|
|
Date: |
4/11/2020 |
|
|
Data Retention Policy
Introduction
This data retention
policy sets out the obligations of DevWebSEO (“us/we/our”) and
the basis upon which we shall retain, review and destroy data held by us, or
within our custody or control.
This policy applies to
our entire organisation including our officers, employees, agents and
sub-contractors and sets out what the retention periods are and when any such
data may be deleted.
Objectives
It is necessary to
retain and process certain information to enable our business to operate. We
may store data in the following places:
·
our own servers;
·
any third party servers;
·
potential email
accounts;
·
desktops;
·
employee-owned devices
(BYOD);
·
potential backup
storage; and/or
·
our paper files.
This policy applies
equally to paper, electronic media and any other method used to store personal
data. The period of retention only commences when the record is closed.
We are bound by various
obligations under the law in relation to this and therefore, to comply with the
law, information must be collected and used fairly, stored safely and not
disclosed to any other person unlawfully in respect of their personal data
under the General Data Protection Regulation (“the Regulation”).
The Regulation defines
“personal data” as any information relating to an identified or identifiable
natural person (a data subject); an identifiable natural person is one who can
be identified, directly or indirectly, in particular by reference to an
identifier such as a name, an identification number, location data, an online
identifier, or to one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural, or social identity of that natural person.
This Policy sets out the
procedures that are to be followed when dealing with personal data and how we
aim to comply with the Regulation in so far as it is possible. In summary, the
Regulation states that all personal data shall be:
1.
processed lawfully,
fairly, and in a transparent manner in relation to the data subject;
1.
collected for specified,
explicit, and legitimate purposes and not further processed in a manner that is
incompatible with those purposes; further processing for archiving purposes in
the public interest, scientific or historical research purposes or statistical
purposes shall not be considered to be incompatible with the initial purposes;
2.
adequate, relevant and
limited to what is necessary in relation to the purposes for which it is
processed;
3.
accurate and, where
necessary, kept up to date; every reasonable step must be taken to ensure that
personal data that is inaccurate, having regard to the purposes for which they
are processed, is erased or rectified without delay;
4.
kept in a form which
permits identification of data subjects for no longer than is necessary for the
purposes for which the personal data is processed; personal data may be stored
for longer periods insofar as the personal data will be processed solely for
archiving purposes in the public interest, scientific or historical research
purposes or statistical purposes subject to implementation of the appropriate
technical and organisational measures required by the Regulation in order to
safeguard the rights and freedoms of the data subject;
5.
processed in a manner
that ensures appropriate security of the personal data, including protection
against unauthorised or unlawful processing and against accidental loss,
destruction or damage, using appropriate technical or organisational measures.
The Fourth and Fifth
Data Protection Principles require that any data should not be kept longer than
necessary for the purpose for which it is processed and when it is no longer
required, it shall be deleted and that the data should be adequate, relevant
and limited for the purpose in which it is processed.
With this in mind, this
policy should be read in conjunction with our other policies which are relevant
such as our data protection policy and IT security policy.
Security and Storage
All data and records are
stored securely to avoid misuse or loss. We will process all personal data we hold
in accordance with our IT Security Policy [OR take appropriate
security measures against unlawful or unauthorised processing of personal data,
and against the accidental loss of, or damage to, personal data].
We will put in place procedures and technologies
to maintain the security of all personal data from the point of collection to
the point of destruction. Personal data will only be transferred to a data
processor if there is agreement by them to comply with those procedures and
policies, or if there are adequate measures in place.
Examples of our storage facilities are
as follows:
Activechampaign.com
We will maintain data security by
protecting the confidentiality, integrity and availability of the personal
data, defined as follows:
(a) Confidentiality means
that only people who are authorised to use the data can access it.
(b) Integrity means
that personal data should be accurate and suitable for the purpose for which it
is processed.
(c) Availability means
that authorised users should be able to access the data if they need it for
authorised purposes. Personal data should therefore be stored on the
[COMPANY’S] central computer system instead of individual PCs.
Retention Policy
Data retention is
defined as the retention of data for a specific period of time and for back up
purposes.
We shall not keep any
personal data longer than necessary, but acknowledge that this will be
dependent on the different types of documents and data that we have
responsibility for. As such, our general data retention period shall be for a
period of 10 years. Our specific data retention periods
are set out below [Please Complete as Appropriate and Add Any
Additional Information and Categories of Personal Data That May Be Required]
Type of data |
Type of data
subject |
Type of processing |
Purpose of
processing |
Type of recipient
to whom personal data is transferred |
Retention period |
Data accuracy and
minimisation review date |
Customers |
Biometric and personal
data |
For business
purposes |
For business
purposes |
May be transferred
to some third-party applications for business purposes and to some companies
located in countries outside the EEA |
Possibly 10 years |
Data is made
accurate when the person enters it and SAR requests can be made above or by
using this link: https://app.gdprtracker.co.uk/sar/DevWebSEO |
Business contacts |
Biometric and
personal data |
For business
purposes |
For business
purposes |
May be transferred
to some third-party applications for business purposes and to some companies
located in countries outside the EEA |
Possibly 10 years |
Data is made
accurate when the person enters it and SAR requests can be made above or by
using this link: https://app.gdprtracker.co.uk/sar/DevWebSEO |
Employees |
Biometric and
personal data |
For business
purposes |
For business
purposes |
May be transferred
to some third-party applications for business purposes and to some companies
located in countries outside the EEA |
Possibly 10 years |
Data is made accurate
when the person enters it and SAR requests can be made above or by using this
link: https://app.gdprtracker.co.uk/sar/DevWebSEO |
Contractors |
Biometric and
personal data |
For business
purposes |
For business
purposes |
May be transferred
to some third-party applications for business purposes and to some companies
located in countries outside the EEA |
Possibly 10 years |
Data is made
accurate when the person enters it and SAR requests can be made above or by
using this link: https://app.gdprtracker.co.uk/sar/DevWebSEO |
Potential
employees |
Biometric and
personal data |
For business
purposes |
For business
purposes |
May be transferred
to some third-party applications for business purposes and to some companies
located in countries outside the EEA |
Possibly 10 years |
Data is made
accurate when the person enters it and SAR requests can be made above or by
using this link: https://app.gdprtracker.co.uk/sar/DevWebSEO |
Sensitive data |
Biometric and
personal data |
For business
purposes |
For business
purposes |
May be transferred
to some third-party applications for business purposes and to some companies
located in countries outside the EEA |
Possibly 10 years |
Data is made
accurate when the person enters it and SAR requests can be made above or by
using this link: https://app.gdprtracker.co.uk/sar/DevWebSEO |
|
|
|
|
|
|
|
From time to time, it
may be necessary to retain or access historic personal data under certain
circumstances such as if we have contractually agreed to do so or if we have
become involved in unforeseen events like litigation or business disaster
recoveries.
Destruction and Disposal
Upon expiry of our
retention periods, we shall delete confidential or sensitive records
categorised as requiring high protection and very high protection, and we shall
either delete or anonymise less important documents.
Our [Records
Management Officer/Other Officer/Manager] is responsible for the
continuing process of identifying the records that have met their required
retention period and supervising their destruction. The destruction of
confidential, financial, and personnel-related records shall be securely
destroyed electronically or by shredding if possible. Non-confidential records
may be destroyed by recycling.
DevWebSEO
Data Protection Policy
Table of Contents
Section A:
Overview……………………………………………………………………………………………………………2
Section B: Data
Protection Principles………………………………………………………………………………………5
Section C: Data Subject
Rights………………………………………………………………………………………………7
Section D: Our Other
Obligations………………………………………………………………………………………..12
Schedule 1: Our Use Of
Personal Data And Our Purpose………………………………………………………..15
Schedule 2: Our Specific
Data Protection Measures………………………………………………………………16
This Policy has been
approved and authorised by:
Name: |
DevWebSEO |
Date: |
4/12/2020 |
Section A: Overview
1.
The reason for this
policy
1.
You have legal rights
with regard to the way your personal data is handled.
2.
In the course of our
business activities we collect, store and process personal data about our
customers, suppliers and other third parties, and therefore in order to comply
with the law and to maintain confidence in our business, we acknowledge the
importance of correct and lawful treatment of this data.
3.
All people working in or
with our business are obliged to comply with this policy when processing
personal data.
·
Introduction
·
This policy and any
other documents referred to in it sets out the basis on which we will process
any personal data we collect from data subjects, for example, customers and
business contacts, or that is provided to us by data subjects or other sources.
·
It also sets out our
obligations in relation to data protection under the General Data Protection
Regulation (“the Regulation”).
·
This policy sets
out rules on data protection and the legal conditions that must be satisfied
when we obtain, handle, process, transfer and store personal data.
·
The procedures and
principles set out herein must be followed at all times by us and our
employees, agents, contractors, or other parties working on behalf of the
Company.
·
We aim to ensure the
correct, lawful, and fair handling of your personal data and to respect your
legal rights.
·
The meaning of key Data
Protection terms
·
Data is information which is stored electronically, on a
computer, or in certain paper-based filing systems.
·
Data subjects for the purpose of this policy include all living
individuals about whom we holds personal data. A data subject need not be a UK
national or resident. All data subjects have legal rights in relation to their
personal information.
·
Personal data means data relating to a living individual who can be
identified from that data (or from that data and other information in our
possession). Personal data can be factual (for example, a name, address or date
of birth) or it can be an opinion about that person, their actions and
behaviour.
·
Data controllers are the people who or organisations which determine
the purposes for which, and the manner in which, any personal data is
processed. They are responsible for establishing practices and policies in line
with the Act. We are the data controller of all personal data used in our
business for our own commercial purposes.
·
Processing is any activity that involves use of the data. It
includes obtaining, recording or holding the data, or carrying out any
operation or set of operations on the data including organising, amending,
retrieving, using, disclosing, erasing or destroying it. Processing also
includes transferring personal data to third parties.
·
Summary of the Data
Protection Principles
This Policy aims to
ensure compliance with the Regulation. The Regulation sets out the
following principles with which any party handling personal data must
comply. All personal data must be:
1.
(Processed fairly and
lawfully) processed lawfully,
fairly, and in a transparent manner in relation to the data subject;
1.
(Processed for limited
purposes and in an appropriate way) collected
for specified, explicit, and legitimate purposes and not further processed in a
manner that is incompatible with those purposes; further processing for
archiving purposes in the public interest, scientific or historical research
purposes or statistical purposes shall not be considered to be incompatible
with the initial purposes;
2.
(Adequate, relevant and
not excessive for the purpose) adequate,
relevant and limited to what is necessary in relation to the purposes for which
it is processed;
3.
(Accurate) accurate and, where necessary, kept up to date; every
reasonable step must be taken to ensure that personal data that is inaccurate,
having regard to the purposes for which they are processed, is erased or
rectified without delay;
4.
(Not kept longer than
necessary for the purpose) kept in a form
which permits identification of data subjects for no longer than is necessary
for the purposes for which the personal data is processed; personal data may be
stored for longer periods insofar as the personal data will be processed solely
for archiving purposes in the public interest, scientific or historical
research purposes or statistical purposes subject to implementation of the
appropriate technical and organisational measures required by the Regulation in
order to safeguard the rights and freedoms of the data subject;
5.
(Processing in line with
data subject’s rights) personal data must
be processed in line with data subjects’ rights, in particular your right to:
1.
request access to any
data held about them by a Data Controller (see also clause 15).
2.
prevent the processing
of their data for direct-marketing purposes.
3.
ask to have inaccurate
data amended (see also clause 9).
4.
prevent processing that
is likely to cause damage or distress to themselves or anyone else.
6.
(Security) processed in a manner that ensures appropriate security of
the personal data, including protection against unauthorised or unlawful
processing and against accidental loss, destruction or damage, using
appropriate technical or organisational measures.
7.
(Transfers outside EEA) not transferred to people or organisations situated
in countries without adequate protection.
·
Our use of personal data
and our purpose
We collect, hold, and
process the personal data referred to in Schedule 1 (and the purpose for which
we process that personal data is also set out in Schedule 1).
·
Our data protection
measures
When we are working with
personal data we take the measures set out in Schedule 2.
Section B: Data
Protection Principles
·
Lawful, Fair, and
Transparent Data Processing
The Regulation is not
intended to prevent the processing of personal data, but to ensure that it is done
fairly and without adversely affecting the rights of the data subject.
The processing of personal data is lawful if one (or more) of the following
applies:
1.
(consent) the data subject has given consent to the processing of his
or her personal data for one or more specific purposes;
1.
(contract) processing is necessary for the performance of a contract
to which the data subject is a party or in order to take steps at the request
of the data subject prior to entering into a contract;
2.
(legal obligation) processing is necessary for compliance with a legal
obligation to which the Data Controller is subject;
3.
(protection) processing is necessary to protect the vital interests of
the data subject or of another natural person;
4.
(public interest) processing is necessary for the performance of a task
carried out in the public interest or in the exercise of official authority
vested in the Data Controller;
5.
(legitimate
interests) processing is necessary
for the purposes of the legitimate interests pursued by the Data Controller or
by a third party, except where such interests are overridden by the fundamental
rights and freedoms of the data subject which require protection of personal
data, in particular where the data subject is a child.
·
Processed for Specified,
Explicit and Legitimate Purposes
·
The Company collects and
processes the personal data set out in Schedule 1 of this Policy. This
may include personal data received directly from data subjects (for example,
contact details used when a data subject communicates with us) and can include
data received from third parties.
·
The Company only
processes personal data for the specific purposes set out in Schedule 1 of this
Policy (or for other purposes expressly permitted by the Regulation). The
purposes for which we process personal data will be informed to data subjects
at the time that their personal data is collected, where it is collected
directly from them, or as soon as possible (not more than one calendar month)
after collection where it is obtained from a third party.
·
Adequate, Relevant and
Limited Data Processing
The Company will only
collect and process personal data for and to the extent necessary for the
specific purpose(s) informed to data subjects as under Part 5, above.
1.
Accuracy of Data and
Keeping Data Up To Date
The Company shall ensure
that all personal data collected and processed is kept accurate and up to
date. The accuracy of data shall be checked when it is collected and
at [regular] intervals thereafter. Where any inaccurate
or out-of-date data is found, all reasonable steps will be taken without delay
to amend or erase that data, as appropriate.
1.
Timely Processing
The Company shall not
keep personal data for any longer than is necessary in light of the purposes
for which that data was originally collected and processed. When the data
is no longer required, all reasonable steps will be taken to erase it without
delay.
1.
Secure Processing
The Company shall ensure
that all personal data collected and processed is kept secure and protected
against unauthorised or unlawful processing and against accidental loss,
destruction or damage. Further details of the data protection and
organisational measures which shall be taken are provided in Parts 22 and 23 of
this Policy.
1.
An assessment of the
risks posed to individual data subjects; and
1.
Details of the measures
in place to minimise and handle risks including safeguards, data security, and
other measures and mechanisms to ensure the protection of personal data,
sufficient to demonstrate compliance with the Regulation.
Section C: Data Subject
Rights
1.
The Rights of Data
Subjects
The Regulation sets out
the following rights applicable to data subjects:
1.
The right to be
informed;
1.
The right of access;
2.
The right to
rectification;
3.
The right to erasure
(also known as the ‘right to be forgotten’);
4.
The right to restrict
processing;
5.
The right to data
portability;
6.
The right to object;
7.
Rights with respect to
automated decision-making and profiling.
1.
Keeping Data Subjects
Informed
1.
The Company shall ensure
that the following information is provided to every data subject when personal
data is collected:
1.
Details of the Company
including, but not limited to its Data Protection Officer;
2.
The purpose(s) for which
the personal data is being collected and will be processed (as detailed in
Schedule 1 of this Policy) and the legal basis justifying that collection and
processing.
3.
Where applicable, the
legitimate interests upon which the Company is justifying its collection and
processing of the personal data;
4.
Where the personal data
is not obtained directly from the data subject, the categories of personal data
collected and processed;
5.
Where the personal data
is to be transferred to one or more third parties, details of those parties;
6.
Where the personal data
is to be transferred to a third party that is located outside of the European
Economic Area (the “EEA”), details of that transfer, including but not limited
to the safeguards in place (see Part 26 of this Policy for further details
concerning such third country data transfers);
7.
Details of the length of
time the personal data will be held by the Company (or, where there is no
predetermined period, details of how that length of time will be determined);
8.
Details of the data
subject’s rights under the Regulation;
9.
Details of the data
subject’s right to withdraw their consent to the Company’s processing of their
personal data at any time;
10.
Details of the data
subject’s right to complain to the Information Commissioner’s Office (the
‘supervisory authority’ under the Regulation);
11.
Where applicable,
details of any legal or contractual requirement or obligation necessitating the
collection and processing of the personal data and details of any consequences
of failing to provide it;
12.
Details of any automated
decision-making that will take place using the personal data (including but not
limited to profiling), including information on how decisions will be made, the
significance of those decisions and any consequences.
2.
The information set out
above in Part 14.1 shall be provided to the data subject at the following
applicable time:
1.
Where the personal data
is obtained from the data subject directly, at the time of collection;
2.
Where the personal data
is not obtained from the data subject directly (i.e. from another party):
1.
If the personal data is
used to communicate with the data subject, at the time of the first
communication; or
2.
If the personal data is
to be disclosed to another party, before the personal data is disclosed; or
3.
In any event, not more
than one month after the time at which the Company obtains the personal data.
1.
Data Subject Access
1.
A data subject may make
a subject access request (“SAR”) at any time to find out more about the
personal data which the Company holds about them. The Company is normally
required to respond to SARs within one month of receipt (this can be extended
by up to two months in the case of complex and/or numerous requests, and in
such cases the data subject shall be informed of the need for the extension).
2.
All subject access
requests received must be forwarded to the DPO, the Company’s data
protection officer. support@DevWebSEO.com
3.
The Company does not
charge a fee for the handling of normal SARs. The Company reserves the
right to charge reasonable fees for additional copies of information that has
already been supplied to a data subject, and for requests that are manifestly
unfounded or excessive, particularly where such requests are repetitive.
1.
Rectification of
Personal Data
1.
If a data subject
informs the Company that personal data held by the Company is inaccurate or
incomplete, requesting that it be rectified, the personal data in question
shall be rectified, and the data subject informed of that rectification, within
one month of receipt the data subject’s notice (this can be extended by up to
two months in the case of complex requests, and in such cases the data subject
shall be informed of the need for the extension).
2.
In the event that any
affected personal data has been disclosed to third parties, those parties shall
be informed of any rectification of that personal data.
1.
Erasure of Personal Data
1.
Data subjects may
request that the Company erases the personal data it holds about them in the
following circumstances:
1.
It is no longer
necessary for the Company to hold that personal data with respect to the purpose
for which it was originally collected or processed;
2.
The data subject wishes
to withdraw their consent to the Company holding and processing their personal
data;
3.
The data subject objects
to the Company holding and processing their personal data (and there is no
overriding legitimate interest to allow the Company to continue doing so) (see
Part 20 of this Policy for further details concerning data subjects’ rights to
object);
4.
The personal data has
been processed unlawfully;
5.
The personal data needs
to be erased in order for the Company to comply with a particular legal
obligation.
2.
Unless the Company has
reasonable grounds to refuse to erase personal data, all requests for erasure
shall be complied with, and the data subject informed of the erasure, within
one month of receipt of the data subject’s request (this can be extended by up
to two months in the case of complex requests, and in such cases the data
subject shall be informed of the need for the extension).
3.
In the event that any
personal data that is to be erased in response to a data subject request has
been disclosed to third parties, those parties shall be informed of the erasure
(unless it is impossible or would require disproportionate effort to do so).
1.
Restriction of Personal
Data Processing
1.
Data subjects may
request that the Company ceases processing the personal data it holds about
them. If a data subject makes such a request, the Company shall retain
only the amount of personal data pertaining to that data subject that is necessary
to ensure that no further processing of their personal data takes place.
2.
In the event that any
affected personal data has been disclosed to third parties, those parties shall
be informed of the applicable restrictions on processing it (unless it is impossible
or would require disproportionate effort to do so).
1.
Data Portability
1.
[The Company processes
personal data using automated means. Activechampaign.com, thrivethemes.com,
Infusionsoft.com, and clickfunnels.com
2.
Where data subjects have
given their consent to the Company to process their personal data in such a
manner or the processing is otherwise required for the performance of a
contract between the Company and the data subject, data subjects have the legal
right under the Regulation to receive a copy of their personal data and to use
it for other purposes (namely transmitting it to other Data Controllers, e.g.
other organisations).
3.
To facilitate the right
of data portability, the Company shall make available all applicable personal
data to data subjects in the following format[s]:
1.
All SAR reuqests
can be made here at this link: https://app.gdprtracker.co.uk/sar/DevWebSEO
4.
Where technically
feasible, if requested by a data subject, personal data shall be sent directly
to another Data Controller.
5.
All requests for copies
of personal data shall be complied with within one month of the data subject’s
request (this can be extended by up to two months in the case of complex
requests in the case of complex or numerous requests, and in such cases the
data subject shall be informed of the need for the extension).
·
Objections to Personal
Data Processing
·
Data subjects have the
right to object to the Company processing their personal data based on
legitimate interests (including profiling), direct marketing (including
profiling), [and processing for scientific and/or historical research
and statistics purposes].
·
Where a data subject
objects to the Company processing their personal data based on its legitimate
interests, the Company shall cease such processing forthwith, unless it can be
demonstrated that the Company’s legitimate grounds for such processing override
the data subject’s interests, rights and freedoms; or the processing is
necessary for the conduct of legal claims.
·
Where a data subject
objects to the Company processing their personal data for direct marketing
purposes, the Company shall cease such processing forthwith.
·
Where a data subject
objects to the Company processing their personal data for scientific and/or
historical research and statistics purposes, the data subject must, under the
Regulation, ‘demonstrate grounds relating to his or her particular
situation’. The Company is not required to comply if the research is
necessary for the performance of a task carried out for reasons of public interest.
·
Automated
Decision-Making
·
In the event that the
Company uses personal data for the purposes of automated decision-making and
those decisions have a legal (or similarly significant effect) on data
subjects, data subjects have the right to challenge to such decisions under the
Regulation, requesting human intervention, expressing their own point of view,
and obtaining an explanation of the decision from the Company.
·
The right described in
Part 21.1 does not apply in the following circumstances:
·
The decision is
necessary for the entry into, or performance of, a contract between the Company
and the data subject;
·
The decision is
authorised by law; or
·
The data subject has
given their explicit consent.
·
Profiling
Where the Company uses
personal data for profiling purposes, the following shall apply:
1.
Clear information
explaining the profiling will be provided, including its significance and the
likely consequences;
1.
Appropriate mathematical
or statistical procedures will be used;
2.
Technical and
organisational measures necessary to minimise the risk of errors and to enable
such errors to be easily corrected shall be implemented; and
3.
All personal data
processed for profiling purposes shall be secured in order to prevent
discriminatory effects arising out of profiling (see Parts 22 and 23 of this
Policy for more details on data security).
Section D: Our Other
Obligations
·
Accountability
·
The Company’s data
protection officer can be contacted at support@DevWebSEO.com
·
The Company shall keep
written internal records of all personal data collection, holding, and
processing, which shall incorporate the following information:
·
The name and details of
the Company, its data protection officer, and any applicable third party Data
Controllers;
·
The purposes for which
the Company processes personal data;
·
Details of the
categories of personal data collected, held, and processed by the Company; and
the categories of data subject to which that personal data relates;
·
Details (and categories)
of any third parties that will receive personal data from the Company;
·
Details of any transfers
of personal data to non-EEA countries including all mechanisms and security
safeguards;
·
Details of how long
personal data will be retained by the Company; and
·
Detailed descriptions of
all technical and organisational measures taken by the Company to ensure the
security of personal data.
·
Privacy Impact
Assessments
The Company shall carry
out Privacy Impact Assessments when and as required under the Regulation.
Privacy Impact Assessments shall be overseen by the Company’s data protection
officer and shall address the following areas of importance:
·
The purpose(s) for which
personal data is being processed and the processing operations to be carried
out on that data;
·
Details of the
legitimate interests being pursued by the Company;
·
An assessment of the
necessity and proportionality of the data processing with respect to the
purpose(s) for which it is being processed;
·
Organisational Measures
The Company shall ensure
that the following measures are taken with respect to the collection, holding,
and processing of personal data:
1.
All employees, agents,
contractors, or other parties working on behalf of the Company shall be made
fully aware of both their individual responsibilities and the Company’s
responsibilities under the Regulation and under this Policy, and shall be
provided with a copy of this Policy;
1.
Only employees, agents,
sub-contractors, or other parties working on behalf of the Company that need
access to, and use of, personal data in order to carry out their assigned
duties correctly shall have access to personal data held by the Company;
2.
All employees, agents,
contractors, or other parties working on behalf of the Company handling
personal data will be appropriately trained to do so;
3.
All employees, agents,
contractors, or other parties working on behalf of the Company handling
personal data will be appropriately supervised;
4.
Methods of collecting,
holding and processing personal data shall be regularly evaluated and reviewed;
5.
The performance of those
employees, agents, contractors, or other parties working on behalf of the
Company handling personal data shall be regularly evaluated and reviewed;
6.
All employees, agents,
contractors, or other parties working on behalf of the Company handling
personal data will be bound to do so in accordance with the principles of the
Regulation and this Policy by contract;
7.
All agents, contractors,
or other parties working on behalf of the Company handling personal data must
ensure that any and all of their employees who are involved in the processing
of personal data are held to the same conditions as those relevant employees of
the Company arising out of this Policy and the Regulation;
8.
Where any agent,
contractor or other party working on behalf of the Company handling personal
data fails in their obligations under this Policy that party shall indemnify
and hold harmless the Company against any costs, liability, damages, loss,
claims or proceedings which may arise out of that failure.
·
Transferring Personal
Data to a Country Outside the EEA
·
The Company may from
time to time transfer (‘transfer’ includes making available remotely) personal
data to countries outside of the EEA.
·
The transfer of personal
data to a country outside of the EEA shall take place only if one or more of
the following applies:
·
The transfer is to a
country, territory, or one or more specific sectors in that country (or an
international organisation), that the European Commission has determined
ensures an adequate level of protection for personal data;
·
The transfer is to a
country (or international organisation) which provides appropriate safeguards
in the form of a legally binding agreement between public authorities or
bodies; binding corporate rules; standard data protection clauses adopted by
the European Commission; compliance with an approved code of conduct approved
by a supervisory authority (e.g. the Information Commissioner’s Office);
certification under an approved certification mechanism (as provided for in the
Regulation); contractual clauses agreed and authorised by the competent
supervisory authority; or provisions inserted into administrative arrangements
between public authorities or bodies authorised by the competent supervisory
authority;
·
The transfer is made
with the informed consent of the relevant data subject(s);
·
The transfer is
necessary for the performance of a contract between the data subject and the
Company (or for pre-contractual steps taken at the request of the data
subject);
·
The transfer is
necessary for important public interest reasons;
·
The transfer is
necessary for the conduct of legal claims;
·
The transfer is
necessary to protect the vital interests of the data subject or other
individuals where the data subject is physically or legally unable to give
their consent; or
·
The transfer is made
from a register that, under UK or EU law, is intended to provide information to
the public and which is open for access by the public in general or otherwise
to those who are able to show a legitimate interest in accessing the register.
·
Data Breach Notification
·
All personal data
breaches must be reported immediately to the Company’s data protection officer.
·
If a personal data
breach occurs and that breach is likely to result in a risk to the rights and freedoms
of data subjects (e.g. financial loss, breach of confidentiality,
discrimination, reputational damage, or other significant social or economic
damage), the data protection officer must ensure that the Information
Commissioner’s Office is informed of the breach without delay, and in any
event, within 72 hours after having become aware of it.
·
In the event that a
personal data breach is likely to result in a high risk (that is, a higher risk
than that described under Part 27.2) to the rights and freedoms of data
subjects, the data protection officer must ensure that all affected data
subjects are informed of the breach directly and without undue delay.
·
Data breach
notifications shall include the following information:
·
The categories and
approximate number of data subjects concerned;
·
The categories and
approximate number of personal data records concerned;
·
The name and contact
details of the Company’s data protection officer (or other contact point where
more information can be obtained);
·
The likely consequences
of the breach;
·
Details of the measures
taken, or proposed to be taken, by the Company to address the breach including,
where appropriate, measures to mitigate its possible adverse effects.
·
Implementation of Policy
This Policy shall be
deemed effective as of [Insert Date]. No part of this Policy
shall have retroactive effect and shall thus apply only to matters occurring on
or after this date.
Schedule 1: Our Use Of
Personal Data And Our Purpose
The following personal
data may be collected, held, and processed by the Company:
1.
Biometric, Health, and
personal may be collected and processed for business purposes with the consent
given for use at the time the data was acquired.
Schedule 2: Our
Specific Data Protection Measures
These are the measures
we take when working with personal data:
·
All emails containing
personal data must be encrypted using Active Champaign software
·
Where any personal data
is to be erased or otherwise disposed of for any reason (including where copies
have been made and are no longer needed), it should be securely deleted and
disposed of. Hardcopies should be shredded, and electronic copies should
be deleted securely using Trend Micro Shredding.
·
Personal data may be
transmitted over secure networks only; transmission over unsecured networks is
not permitted in any circumstances.
·
Personal data may not be
transmitted over a wireless network if there is a wired alternative that is
reasonably practicable;
·
Personal data contained
in the body of an email, whether sent or received, should be copied from the
body of that email and stored securely. The email itself should be
deleted. All temporary files associated therewith should also be deleted;
·
Where Personal data is
to be sent by facsimile transmission the recipient should be informed in
advance of the transmission and should be waiting by the fax machine to receive
the data;
·
Where Personal data is
to be transferred in hardcopy form it should be passed directly to the
recipient or sent using a secure delivery service;
·
No personal data may be
shared informally and if an employee, agent, sub-contractor, or other party
working on behalf of the Company requires access to any personal data that they
do not already have access to, such access should be formally requested from
the Data Protection Officer at support@DevWebSEO.com
·
All hardcopies of
personal data, along with any electronic copies stored on physical, removable
media should be stored securely in a locked box, drawer, cabinet or similar;
·
No personal data may be
transferred to any employees, agents, contractors, or other parties, whether
such parties are working on behalf of the Company or not, without the
authorization of the Data Protection Officer at support@DevWebSEO.com;
·
Personal data must be
handled with care at all times and should not be left unattended or on view to
unauthorized employees, agents, sub-contractors or other parties at any time;
·
If personal data is
being viewed on a computer screen and the computer in question is to be left
unattended for any period of time, the user must lock the computer and screen
before leaving it;
·
No personal data should
be stored on any mobile device (including, but not limited to, laptops,
tablets, and smartphones), whether such device belongs to the Company or otherwise
[without the formal written approval of the Data Protection Officer at support@DevWebSEO.com
and, in the event of such approval, strictly in accordance with all
instructions and limitations described at the time the approval is given, and
for no longer than is absolutely necessary].
·
No personal data should
be transferred to any device personally belonging to an employee and personal
data may only be transferred to devices belonging to agents, contractors, or
other parties working on behalf of the Company where the party in question has
agreed to comply fully with the letter and spirit of this Policy and of the
Regulation (which may include demonstrating to the Company that all suitable
technical and organizational measures have been taken);
·
All personal data stored
electronically should be backed up the year with backups
stored [onsite] AND/OR [offsite]. All backups
should be encrypted using passwords.
·
All electronic copies of
personal data should be stored securely using passwords and data encryption;
·
All passwords used to
protect personal data should be changed regularly and should not use words or
phrases that can be easily guessed or otherwise compromised. All
passwords must contain a combination of uppercase and lowercase letters,
numbers, and symbols All software used by the Company is designed to
require such passwords;
·
Under no circumstances
should any passwords be written down or shared between any employees, agents,
contractors, or other parties working on behalf of the Company, irrespective of
seniority or department. If a password is forgotten, it must be reset
using the applicable method. IT staff do not have access to passwords;
·
Where personal data held
by the Company is used for marketing purposes, it shall be the responsibility
of the Data Protection Officer at support@DevWebSEO.com to
ensure that no data subjects have added their details to any marketing
preference databases including, but not limited to, the Telephone Preference
Service, the Mail Preference Service, the Email Preference Service, and the Fax
Preference Service. Such details should be checked at least once
per year.
Data Processing Clauses
Note to User
Ideally, we recommend
that you will have a separate data processing agreement that will set out the
terms on how data will be held and used. If this is not going to be possible,
the next step is to try and negotiate or revise existing agreements, terms etc.
to incorporate a clause which acknowledges GDRP and that you will aim to comply
with this. On this basis the clause below is recommended.