Privacy Policy
At Development Capital, LLC (“Development Capital”, the “Company”, “we”, “us” or “our”) we consider privacy to be fundamental to our relationship with you. This Website Privacy Notice describes how we collect, use, share and otherwise process personal information we collect through our website at www.devcapital.com (the “Site”), as well as information that we may collect via other means, as described below.
This Privacy Notice does not apply to information we collect from our employees, contractors, job applicants or business contacts.
I. Information We Collect
“Personal information” is any kind of information that allows us to identify you, directly or indirectly, such as your name, contact details, or address. We may collect and process the following personal information about you:
· Identifiers, such as your name, address, email address and telephone numbers;
· Professional or employment information, such as your job title and place of work;
· Internet or other electronic network activity information, such as your internet protocol (IP) address, login data, unique device identifiers, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, mobile device carrier and other technology on the devices you use to access the Site; as well as usage information, such as information about how you use the Site and our products and services, referring/exit web pages, date/time stamps, error logs, and the frequency of your use of the Site; and
· Marketing and communications information, such as your preferences in receiving marketing communications from us.
We also collect, use and share aggregated information such as statistical or demographic data for any purpose. This information could be derived from your personal information but will not directly or indirectly reveal your identity. For example, we may aggregate your usage information to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect information with your personal information so that it can directly or indirectly identify you, we treat the combined information as personal information which will be used in accordance with this Website Privacy Notice.
II. How We Collect Your Personal Information
We collect personal information from you via the following:
1. Personal information you provide to us
· Forms you complete (or which are completed by your authorized representatives on your behalf) on the Site or otherwise; and
· Your correspondence and interactions with us, including by letter, email and telephone.
2. Information collected automatically
We may automatically collect certain information about the devices you use to access the Site, as well as information on how you interact with the Site, through web server logs as well as cookies and other similar tracking technologies. Information gathered through cookies and web server logs may include information such as the date and time of visits to the Site, the pages viewed, time spent at the Site, and the websites visited just before and just after the Site.
a) Cookies and other data collection technologies
We may collect information about your use of the Site through cookies and other similar tracking technologies. “Cookies” are a feature of web browser software that allows web servers to recognize the computer used to access a website. They are small text files that are stored by a user’s web browser on the user’s hard drive. Cookies can help identify what information a user accesses on one website to simplify subsequent interactions with that site by the same user or to use the information to streamline the user’s transactions on related websites. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies last longer and are used to recognize your computer when you return to the Site.
We use cookies to manage your login session, help you move between websites in a smooth and secure manner, and to gather information about the browsing activities of users of the Site in order to continually improve it and better serve the needs of its users.
You can change your browser settings to notify you of the cookies being set or updated, and to block cookies. Please note that if you have turned off all cookies, some features of the Site may not be available to you or otherwise function as intended.
We also may include tracking pixels and web beacons in email messages, newsletters, and other electronic communication. They help us to determine whether a message has been opened and to analyze and personalize our interactions with you. Instructions on how to unsubscribe are included in each email.
We use the following categories of cookies on the Site:
· Essential cookies: These cookies are necessary to provide you with the services available through our Site and to use its some of its features. Without these cookies, the use of the Site is impacted and certain functions might not be available.
· Performance, functionality and customization cookies: These cookies improve the performance and functionality of the Site, but are not essential to its use. Without these cookies, the Site and its functions might be more cumbersome to load or navigate, but are still available.
· Analytics cookies: These cookies collect information that helps us understand how you use our services, and to customize the Site and our services for you. The functionality of the Site is not impacted by the rejection of such cookies.
b) Cookie management
Most web browsers automatically accept cookies. You can, however, change your browser to prevent this or to notify you each time a cookie is set. To learn more about how to manage cookies on different types of browsers, you can visit the website www.allaboutcookies.org.
c) “Do Not Track” Browser Settings
We do not currently use technology that recognizes “do not track” signals from your web browser.
III. How We Use Your Personal Information
We will only use your personal information when the law allows us to. Any of the information we collect from you may be used in one of the following ways:
· Where the processing is necessary for us to enter into or to perform a contract with you, or to take steps at your request prior to entering into a contract – for example, to provide information you have requested or to respond to your questions;
· Where necessary for the purposes of the Company’s legitimate interests, including to operate and facilitate our business and services, communicate with you, undertake business management, planning, statistical analysis, market research and marketing activities, administer and maintain the Company’s core records, protect the Company’s rights and interests, ensure the security of the Company’s assets, systems and networks, prevent, detect and investigate fraud, unlawful or criminal activities in relation to our services, and enforce our terms and conditions;
· Where required by applicable laws and regulations, including laws relating to know-your-client requirements, tax, the prevention of money laundering, fraud, terrorist financing and sanctions; and
· Where the processing is necessary for the establishment, exercise or defense of legal claims.
In some circumstances, we may process your personal information where we have received your consent. For example, depending where you are located, in order to send you marketing materials or to place cookies or similar tracking technologies on your devices. Where processing is based on your consent, you have the right to withdraw that consent at any time.
IV. How We Protect Your Personal Information
We are committed to maintaining the confidentiality, integrity and security of your personal information and take precautions to protect such information. These precautions include the adoption of certain physical, electronic, and procedural safeguards and procedures designed to maintain and secure your personal information from inappropriate disclosure in accordance with applicable laws and regulations. However, no security measures are perfect, and we cannot assure you that personal information that we collect will never be accessed or used in in an unauthorized way.
V. When We Disclose Your Personal Information
We do not disclose personal information except as may be required or permitted by law, rule or regulation. We may disclose personal information to our affiliates, service providers and relevant counterparties, or as required by applicable law or regulation. We may also disclose personal information to the following:
· Any governmental agency, regulatory authority or self-regulatory organization having jurisdiction over the Company or its affiliates, if (i) the Company determines that such disclosure is necessary or advisable pursuant to or in connection with any U.S. federal, state or local, or non- U.S., law, rule, regulation, executive order or policy, including without limitation any anti-money laundering law and the USA PATRIOT Act and (ii) such disclosure is not otherwise prohibited by law, rule, regulation, executive order or policy;
· Persons acting in a fiduciary or representative capacity on behalf of an investor, such as an IRA custodian or Trustee of a grantor trust;
· A third party in connection with a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or capital, including in connection with any bankruptcy or similar proceedings; and
· Certain other persons to the extent authorized by you.
In addition, we may use or disclose your personal data as we deem necessary or appropriate: (1) under applicable law, including laws outside your country of residence; (2) to comply with subpoenas and other legal processes; (3) to pursue available remedies or limit damages we may sustain; (4) to protect our operations or those of any of our affiliates; (5) to protect the rights, privacy, safety or property of us, our affiliates, you and others; and (6) to enforce our terms and conditions.
We may disclose for a business purpose, and have disclosed in the preceding twelve (12) months, personal information, including identifiers, employment information, internet or other electronic activity information, and marketing or communications information, as listed above.
We have not sold any personal information in the twelve (12) months preceding the effective date of this policy.
VI. Third Party Links
The Site may contain links to third party websites, products and services. These third party websites and services have separate and independent privacy policies, which we encourage you to read. We have no responsibility or liability for the content and activities of such linked sites. However, we want to protect the integrity of our Site and thus welcome any feedback you may have about third-party sites we link to.
VII. Children’s Privacy
The Site is not directed toward children under the age of 13. We do not promote our products or services online to minors, and we do not intentionally collect any personally identifiable information from any person under 13. If we become aware of having collected personal information from children under the age of 13 without valid consent from their respective parents or guardians, we will delete is as soon as practicable.
VIII. Changes to this Website Privacy Notice
We may update this Website Privacy Notice periodically, without prior notice, so please review it frequently. If we decide to change our Website Privacy Notice, we will post those changes on the Site so that you are aware of what kinds of personal information we collect, use, share and otherwise process. If we make material changes to this Website Privacy Notice, we will update the effective date above.
IX. Privacy Rights
We are committed to providing individuals with reasonable and appropriate access to their personal information. If you believe that we are processing personal information about you and wish to have access to that information, we can provide you with that data or at least an explanation of why we cannot do so in the particular context, such as where the request is manifestly unfounded or excessive. We are happy to correct inaccurate data or delete information that is not appropriate to retain. Please also let us know if you have any questions, concerns, disputes, or issues.
Individuals in Andorra, Argentina, Australia, California, Canada, Europe, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, the United Kingdom, Uruguay, and certain other jurisdictions may have certain data subject rights. These rights vary, but they may include the right to: (i) request access to and rectification or erasure of their personal data; (ii) restrict or object to the processing of their personal data; and (iii) obtain a copy of their personal data in a portable format. Individuals may also have the right to lodge a complaint about the processing of personal data with a data protection authority. We are always open to dialogue to resolve issues short of formal disputes. If your concerns cannot be resolved, we can enter into appropriate third party neutral dispute resolution. If you need to reach us about a privacy or data protection issue, please contact us using the details below.
If you wish to exercise any of these rights please email info@devcapital.com or call us at +1 212 758 5822. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. Additionally, if we retain your personal data only in de-identified form, we will not attempt to re-identify your data in response to a Data Subject Rights request.
The California Consumer Privacy Act (“CCPA”) prohibits covered businesses from discriminating against you for exercising applicable CCPA rights.
If you make a request related to personal data about you, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the individual whose personal information is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. For requests related to particularly sensitive information, we may require additional proof of identification. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf. We will process your request within the time provided by applicable law.
X. Contact Us
If you have any questions or concerns about this Website Privacy Notice, please contact us at: info@devcapital.com