For Denovo Technology and Services
Managed Squared, Inc. owns and operates this https://denovo.io website and sells monthly service subscriptions to access the website and its Denovo Technology and Services (as Defined in the Software as a Service Agreement, found here). Denovo is a product of Managed Squared, Inc. All references to "we", "us", or this "website" shall be construed to mean Managed Squared Inc.
We comply with the EU General Data Protection Regulation (GDPR) in all respects, but do not obtain affirmative consent to collect any Personal Data (defined below), which is allowed to be collected without consent under GDPR Chapter 2 Article 6(1) as follows:
(b) Personal Data that is “necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;” and
(f) Personal Data that is “necessary for the purpose of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.”
OUR COMMITMENT TO PRIVACY
Your privacy is important to us. To better protect your privacy, we provide this policy explaining our online information practices and the choices you can make about the way your information is collected and used. To make this policy easy to find, we make it available on our homepage and at every point where personally identifiable information may be requested. We also send Privacy Notices to our users when the privacy notice is materially altered.
1.2 Personal Data. Regarding Personal Data, if any revisions are made to How We Use Your Information (Section 4 below) that permit a wider scope of our use of your personal data, we will obtain your consent before implementing such revisions. If the revisions made narrow the scope of our use of your personal data, you will be notified of the changes by Privacy Notice.
2. THE TYPES OF INFORMATION WE COLLECT
2.1 Personal Data. "Personal Data" as defined in the GDPR means: “any information relating to an identified or identifiable natural person 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.. Personal Data that we collect may vary with each separate purpose for which you provide it, and it may include one or more of the following: name, physical address, an email address, phone number, credit card information including credit card number, expiration date, and billing address, and location data.”
2.2 Usage Data. We reserve the right to collect anonymous information based on your usage of this website automatically, either by this website or third-party services employed in this website (Usage Data).
3. HOW AND WHEN WE COLLECT INFORMATION
3.1 Personal Data You Provide to Us. We collect Personal Data only at the time you provide it to us. We collect Personal Data through sign-up forms and as part of your registration for an account, product or service, promotion, information request, or contest from this website. Personal Data that we collect may vary with each sign-up or registration. In addition, we collect Personal Data from all communications from website visitors including without limitation, text messages, faxes, telephone calls, and regular "snail mail."
3.2 Your Communications With Us. We collect Personal Data that we receive from you as you communicate with us. If you complete a signup form subscribing to information from our website or to participate in our mailing list activities, we will receive your Personal Data from our email services and/or autoresponder service.
3.3 Information from Other Sources. We may receive personal information about you from individuals or corporate entities which are subscribers to the Denovo service (Subscribers) where you are to be designated a user of the service. We may receive personal information about you if you use any of the other websites we operate or the other services we provide from time to time. We also work closely with third parties (including, for example, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them, subject to your agreements with them.
3.4 Usage Data. We reserve the right to monitor your use of this website. As you navigate through this website, Usage Data may be passively collected (that is, gathered without your actively providing the information) using various analytics and reporting technologies, such as Cookies and Web Beacons (defined in Section 6). Usage Data that contains Personal Data is anonymized to protect your information when collected. We may link or combine the personal information we collect and/or receive about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.
4. HOW WE USE YOUR INFORMATION
4.1 Use of Data. We may use your Personal Data for the performance of the Services or transaction for which it was given, our private, internal reporting for this website, and security assessments for this website. Such usage includes for purposes of conducting business through the website, analytics, credit references, payment processing, or other services connected to the website.
4.2 Reservation of Rights. We reserve the right to make full use of Usage Data. For example, we may use Usage Data to provide better service to website visitors, customize the website based on your preferences, compile and analyze statistics and trends about the use of this website, and otherwise administer and improve the usability of this website.
4.3 Testimonials. With consent, we may display personal testimonials of satisfied customers on our site, along with other endorsements. If you wish to update or delete your testimonial, please contact us.
5. INFORMATION SHARING AND DISCLOSURE
5.1 General Disclosure Policy. We reserve the right to disclose your Personal Data only as described below. We reserve the right to disclose Usage Data without restriction.
5.2 Affiliated Entities. We reserve the right to provide your Personal Data and Usage Data to any affiliated entities we may have, including our subsidiaries in the regular conduct of business and only for the purposes for which you provided the Personal Data. Affiliated entities are entities that we legally control (by voting rights) or that control us.
5.3 Service Providers. We reserve the right to provide access to your Personal Data and Usage Data to our trusted service providers that assist us with the operation and maintenance of this website. For example, we may contract with third parties to process payments, host our servers, provide security, and provide production, fulfillment, optimization, analytics, and reporting services. Our service providers will be given access to your Usage Data only as is reasonably necessary to provide the services for which they are contracted and will only be given access to your Personal Data as it is necessary to provide the service for which you originally provided the Personal Data.
5.5 Legal Process, Enforcement and Security Notice. We reserve the right to disclose your Personal Data and Usage Data if we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to: (1) Satisfy any applicable law, regulation, legal process or enforceable governmental request (such as for example, to comply with a subpoena or court order); (2) Detect, prevent, and address fraud or other illegal activity; and (3) Investigate, respond to, or enforce violations of our rights or the security of this website.
5.6 Disclosures of Personal Data In Our Discretion. We do not sell your Personal Data to third parties - ever. Although we may disclose information about the use of our websites, that information does not contain Personal Data. Generally, we do not disclose Personal Data to third parties. However, we may share Personal Data with our contractors and service providers in order to provide the service for which you originally provided the Personal Data. Any information provided to our contractors and service providers used to maintain, enhance, or add to the functionality of the websites will be provided as anonymized or aggregate data to protect the privacy of your Personal Data.
5.7 Your California Privacy Rights. Under California Law S.B. 27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of Personal Data shared. To make such a request, please send an email to the email address provided in our contact information below and include the phrase "California Privacy Request" in the subject line, as well as the domain name of the website you are inquiring about, along with your name, address and email address in the body of the email. We will respond to you within thirty days of receiving such a request.
6. SPECIFIC INFORMATION ABOUT COOKIES AND WEB BEACONS
6.2 Cookies. "Cookies" are tiny pieces of information stored by your browser on your computer's hard drive. Cookies are also used to customize content based on your browser. Most browsers are initially set to accept cookies. If you want to disable cookies, there is a simple procedure in most browsers that allows you to turn off cookies. Please remember, however, that cookies may be required to allow you to use certain features of our website.
6.3 Flash Cookies. “Flash Cookies” are third party cookies that use an Adobe Flash Media Player local shared object (LSO) - may be used along with other third-party cookies for purposes of crediting any purchase you may make on this website to one of our joint venture marketing partners that may have referred you to us. These cookies will be used for purposes of crediting sales to the referring joint venture marketing partner. Flash cookies are not the same as "browser cookies". The Adobe Flash Media Player is software that enables users to view content on their computers. Flash cookies are also accompanied by a browser cookie. If you delete the browser cookie, the Flash cookie may automatically create (or re-spawn) a replacement for the browser cookie.
6.4 Web Beacons. “Web Beacons,” sometimes called single-pixel gifs or clear gifs - are used to assist in delivering cookies, and they allow us to count users who have visited pages of our website. We may include Web Beacons in promotional e-mail messages or our newsletters in order to determine whether messages have been opened and acted upon.
7.1 Participation in Analytics Services. We reserve the right to participate with third-party analytics partners to monitor and analyze Web traffic and can be used to keep track of user behavior on this website. Below are two examples of software utilized for analytics, and we reserve the right to use others that are not specifically listed. Any analytics services we use will only gather Usage Data or anonymized Personal Data in order to protect your privacy.
8. SOCIAL MEDIA INTERACTIONS
We invite you to socialize and share your participation with this website and purchases. If you choose to use social media platforms such as Facebook, Twitter, LinkedIn, and Google Plus, you will be allowing interaction with these platforms or other external platforms directly from this website, and in the process, you may share elements of your social media profile (such as comments, profile pictures and usernames). Such sharing is subject to each social media program’s privacy policies.
9. POSTINGS TO OUR WEBSITE (BLOG, FORUM, CHAT ROOM)
9.1 Posts. We will not treat information that you post to areas of this website that are viewable by others (for example, to a blog, forum or chat-room) as proprietary, private, or confidential. We have no obligation to monitor posts to this website or to exercise any editorial control over such posts; however, we reserve the right to review such posts and to remove any material that, in our judgment, is not appropriate. Posting, transmitting, promoting, using, distributing or storing content that could subject us to any legal liability, whether in tort or otherwise, or that is in violation of any applicable law or regulation, or otherwise contrary to commonly accepted community standards, is prohibited, including without limitation information and material protected by copyright, trademark, trade secret, nondisclosure or confidentiality agreements, or other intellectual property rights, and material that violates export control laws.
9.2 Right to Modify Posted Material. We, in our sole discretion and without notice, reserve the right, but undertake no duty, to review, edit, remove or delete any material submitted as a comment to blog, forum or chat-room provided for display or placed on this website. Specifically, we reserve the right to delete or decline to post content that contains profanity; sexual content; overly graphic, disturbing or offensive material; vulgar or abusive language; hate speech, defamatory comments, or offensive language targeting any specific demographic; personal attacks of any kind; spam; promotions for commercial products or services.
9.3 Release from You. By submitting a comment for posting, you agree that we are not responsible, and shall have no liability to you, with respect to any information or materials posted by others, including defamatory, offensive or illicit material, even material that violates this Agreement.
10. DO NOT TRACK REQUESTS
Some Web browsers incorporate a "Do Not Track" feature that signals to websites that you visit that you do not want to have your online activity tracked. Each browser communicates "Do Not Track" signals to websites differently, making it unworkable to honor each and every request correctly. In order to alleviate any communication error between browsers and our website, we do not respond to "Do Not Track" signals at this time. As the technology and communication between browsers and websites improve, we will reevaluate the ability to honor "Do Not Track" signals and may make changes to our policy. Any specific inquiries related to our Do No Track Policy may be directed to the address below.
11. DATA SECURITY
11.1 Transmission. We will implement reasonable and appropriate security procedures consistent with prevailing industry standards and the European Union General Data Protection Regulations to protect data from unauthorized access by physical and electronic intrusion. Unfortunately, no data transmission over the Internet or method of data storage can be guaranteed 100% secure. Therefore, while we strive to protect your Personal Data by following generally accepted industry standards, we cannot ensure or warrant the absolute security of any information you transmit to us or archive at this website.
11.2 Breach. In the event that breach of Personal Data occurs, or a potential breach has been identified, all affected, or potentially affected users will be notified within 72 hours of the identification of the breach,
11.2 Encryption. When you transmit Personal Data through our registration process or if you purchase products or services, we encrypt that information in transit using secure socket layer technology (SSL).
11.3 Storage. The personal information we collect may be transferred to and stored in countries outside of your country to third-party service providers that store our data. When possible, we strive to store our data in the United States. After the secure transfer of your Personal Data, the information is maintained and stored with 128-bit encryption. We do not store any Data in Russia.
12. ONWARD TRANSFER OUTSIDE YOUR COUNTRY OF RESIDENCE
Any Personal Data which we may collect on this website may be stored and processed in our servers located in the United States or in any other country in which we, or our affiliates, subsidiaries, or agents may maintain facilities. By using this website, you consent to any such transfer of Personal Data outside your country of residence to any such location.
13. UPDATING PERSONAL DATA
Upon request, we will permit you to request information on, make changes or updates to, or cause to be removed from our databases your Personal Data for legitimate purposes. We request identification prior to approving such requests. We reserve the right to decline any requests that undermine the privacy rights of others. We reserve the right to permit you to access your Personal Data in any account you establish with this website for purposes of making your own changes or updates, and in such case, instructions for making such changes or updates will be provided where necessary.
14. LINKS TO JOINT VENTURE MARKETING PARTNER WEBSITES
This website may contain links to other websites operated by our joint venture marketing partners. If you do click on any of the links to their websites or accept any of their promotional offers, your click-through information and any information that you provide in the process of registration or purchase will be transferred to these websites. We have no responsibility or liability for the policies and practices of these websites. You should be careful to review any privacy policies posted on any of these websites before providing information to them.
15. CHILDREN'S ONLINE POLICY
We are committed to preserving online privacy for all of its website visitors, including children. This website is a general audience website. Consistent with the Children's Online Privacy Protection Act
(COPPA), we will not knowingly collect any information from, or sell to, children under the age of 13. If you are a parent or guardian who has discovered that your child under the age of 13 has submitted his or her personally identifiable information without your permission or consent, we will remove the information from our active list, at your request. To request the removal of your child's information, please contact our website as provided below under "Contact Us,” and be sure to include in your message the same login information that your child submitted.