Version 1.1 | Rev 25 May 2018
1.0 HOW INFORMATION IS COLLECTED
Devereaux Unlimited typically collects personal information directly from the individual to whom it relates, except where that individual has consented to Devereaux Unlimited collecting the personal information from a third-party or the law otherwise permits Devereaux Unlimited to do so.
Devereaux Unlimited will collect and store your personal information when you interact with DevereauxUnlimited.com. We collect information, some of which may contain personal information, by online applications as follows: (i) limited information is automatically collected about you when you visit DevereauxUnlimited.com through the use of Google Analytics or Log Data (as discussed below); or (ii) you may voluntarily provide information, including personal information, to us by: (a) emailing Devereaux Unlimited about our services, employment or internship opportunities, marketing, media requests, and other business matters; (b) by registering online to attend an Devereaux Unlimited-sponsored event; or (c) downloading one of our online publications.
Google Analytics is a free third-party service that uses “cookies” to measure, collect, analyze and report web data for purposes of optimizing the experience of users of DevereauxUnlimited.com. Cookies are files with small amounts of data, that are sent to your browser from a website and stored on your computer’s hard drive. You can opt-out and prevent your data from being used by Google Analytics with the Google Analytics Opt-Out Browser Add-on.
Log Data is information your browser sends us whenever you visit DevereauxUnlimited.com. Log Data may include information such as your computer’s browser type, the browser version, the pages of our site that you visit, the time and date of your visit, the time spent on those pages, and other statistics.
Devereaux Unlimited does not make any attempt to use Google Analytics or Log Data to find out the identities of those visiting DevereauxUnlimited.com. It is your responsibility to adjust your browser settings to accommodate your personal privacy preferences and by your use of DevereauxUnlimited.com you have consented to Devereaux Unlimited’s collection of information as discussed above.
Devereaux Unlimited uses World-Check by Thomson Reuters® to obtain risk intelligence data associated with new business relationships. Risk intelligence data may include sensitive personal information on companies and individuals such as political activities, criminal allegations or convictions, regulatory inquiries or penalties, precise geolocation information, financial and banking information, reputational information, government issued identification numbers, relationships to sanctioned or otherwise politically exposed persons and organizations, and other similar information.
2.0 TYPES OF PERSONAL INFORMATION COLLECTED
Personal information means any information relating to a person that enables them to be identified either directly or indirectly. Personal information that we hold about you may include your contact details (e.g. name, phone number, address and email address), IP address, language, gender and geolocation.
If you are a client, vendor or subconsultant, personal information that we hold about you may include the same information listed above, along with your date of birth, social media/network accounts, business address, email address, phone number and fax number, function/job title, company, types of services provided, and financial compensation. Devereaux Unlimited may request that you provide additional information such as your company’s legal status, date of incorporation, place of incorporation, your company’s related entities, your company’s shareholding details, your relationship to any government official, your company’s tax identification numbers, country of origin, business and professional licenses, your company’s insurer, broker and insurance policies, and other information you consent to provide us for purposes of performing contracts or services.
We will take reasonable steps to ensure the personal information that we store is accurate, complete and up-to-date.
3.0 HOW PERSONAL INFORMATION IS USED
We will use your personal information, and may share your personal information with other parties acting on our behalf, for one or more of the following: (i) to conduct research about the use of our website; (ii) to improve services provided by Devereaux Unlimited; (iii) to assess and respond to a complaint you might make to us; (iv) for our own administrative purposes, including training our staff, conducting internal audits, improving our services or transferring assets as part of a sale, purchase or investment in the business; (v) if you are a client, vendor or subconsultant, to perform services or carry out our contract with you; (vi) for market research purposes; (vii) to make informed decisions about business relationships and to prevent inadvertent engagement in illegal or corrupt practices; (ix) to conduct investigations of suspicious or harmful activity; (x) to comply with Devereaux Unlimited’s regulatory and legal obligations; (xi) to manage risks related to Devereaux Unlimited’s contracts and services; and (xii) for marketing purposes. If we wish to use your personal information for a purpose beyond that for which it was originally provided, we will ask for your consent or seek to rely on another valid legal ground to process your personal information in accordance with the applicable law. Devereaux Unlimited does not sell personal information to others.
4.0 INFORMATION FOR MARKETING PURPOSES
Where you have consented to us using your personal data for marketing purposes, we may use your information to conduct marketing and data analysis or to send you updates and news concerning Devereaux Unlimited and its business partners.
5.0 GROUNDS FOR PROCESSING
To process your data lawfully we need to rely on one or more valid legal grounds. The grounds we may rely upon include:
Your consent to particular processing activities. For example, where you have consented to us using your information for marketing purposes;
Our legitimate interests as a business (except where your interests or fundamental rights override these). For example, it is within our legitimate interests to use your information to prevent or detect fraud or abuses of our website;
Our compliance with a legal obligation to which Devereaux Unlimited is subject. For example, we have a duty to investigate and respond to complaints made against us and may need to process your personal information as part of such investigation; or
If you are a client, vendor or subconsultant, because processing your personal information is necessary for the performance of a contract or services.
6.0 DISCLOSURE OF YOUR PERSONAL INFORMATION
There are circumstances where we may wish to disclose or are compelled to disclose your personal information to third-parties. This will only take place in accordance with the applicable law, for the purposes listed above, and pursuant to Devereaux Unlimited’s Third-Party Data Privacy Addendum. These scenarios include disclosure to: (i) Devereaux Unlimited’s subsidiaries, branches or associated offices; (ii) outsourced vendors or subconsultants to facilitate the provision of our services (including other professional service providers); (iii) third-party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons (including cloud service providers); (iv) another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganization, change of legal form, dissolution or similar event; (v) attorneys in connection with negotiation of a contract, dispute resolution, and other legal advice; (vi) tax advisors for purposes of tax filings, obtaining tax credits, negotiating tax liabilities, and other tax advice; (vii) public authorities where we are required by law to do so; and (viii) any other third party where you have provided your consent. Further, we may disclose your information to any person as required by law and specifically to any government agency if we believe in good faith that we must do so to comply with the law or that doing so is required to prevent, detect, investigate or remedy improper conduct potentially affecting Devereaux Unlimited.
7.0 INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
Participating organizations are deemed to have “adequate” privacy protection for the transfer of personal information outside of the EU under the General Data Protection Regulation (“GDPR”). For Privacy Shield purposes, Devereaux Unlimited refers to Devereaux UnlimitedGroup, Inc. and “Other Covered Entities” refers to each of the following:
As a result, EU member state requirements for prior approval of international data transfers to Devereaux Unlimited and its Other Covered Entities are waived. In cases of onward transfers of data, received pursuant to the EU-U.S. Privacy Shield, Devereaux Unlimited is potentially liable under the GDPR.
If Devereaux Unlimited does not timely acknowledge a complaint, or if we have not satisfactorily addressed a complaint, EU residents may: (i) submit their complaint to their local data protection authority for referral to the U.S. Department of Commerce; or (ii) seek a non-monetary remedy through binding arbitration administered by the International Centre for Dispute Resolution® - American Arbitration Association® (“ICDR-AAA”) in accordance with the Privacy Shield Principles. The services of ICDR-AAA are provided at no cost to EU residents. To learn more about the independent recourse mechanism provided by the ICDR-AAA, please visit go.adr.org/privacyshield.html.
8.0 RETENTION OF PERSONAL INFORMATION
9.0 CONFIDENTIALITY AND SECURITY
10.0 EU RESIDENT RIGHTS
Devereaux Unlimited will respond within a reasonable time period, in any event, within any time period specified by law. Persons exercising these rights will be required to submit a proof of identity. If you are an EU resident, you have the right to:
Obtain a copy of your personal information. You have the right to obtain a copy of the personal information we hold about you by contacting us as directed above.
Correct your personal information. You may request that we rectify any inaccurate and/or complete any incomplete personal information by contacting us as directed above. If we disagree and believe the information to be accurate and complete, we will advise you and include a notation on the record that you dispute the information’s accuracy.
Withdraw your consent to processing. You may, as permitted by law, withdraw your consent to the processing of your personal information at any time by contacting us as directed above. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential.
Object to processing. You may, as permitted by law, request that we stop processing your personal information by contacting us as directed above.
Erasure. You may request that we erase your personal information by contacting us as directed above. We will comply, unless there is a lawful reason for not doing so.
Lodge a complaint. We suggest that you first contact us as directed above regarding any questions or complaints in relation to your rights or how we process your personal information. However, this does not limit your right to contact your local data protection authority directly.
Our website may provide hyperlinks to websites owned and controlled by others. Devereaux Unlimited is not responsible for the privacy practices of any website that it does not own or otherwise control.
12.0 THIRD PARTIES
Where you submit information on behalf of another person, you confirm that you have made that person aware of how we may collect, use and disclose their information, the reason you have provided it, how they can contact us, the terms of this policy and that they have consented to such collection, use and disclosure.
13.0 COMPLIANCE WITH PRIVACY LAWS
14.0 CHANGES TO THIS POLICY