Privacy Policy
Collection of information
Privacy of children
We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Website and Services. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Website and Services, please contact us to request that we delete that child’s Personal Information from our Services.
We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission. We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their permission.
Use and processing of collected information
We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Website and Services. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Website and Services, please contact us to request that we delete that child’s Personal Information from our Services.
We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission. We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their permission.
In order to make the Website and Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes:
Send product and service updates;
Send marketing and promotional communications, notices or announcements;
Request user feedback;
Run and operate the Website and Services;
Conduct internal operations, including troubleshooting data analysis, testing, research and statistical purposes;
Comply with our legal obligations and in order to be able to protect our rights and legitimate interests, including in order to improve the Site
Processing your Personal Information depends on how you interact with the Website and Services, where you are located in the world and if one of the following applies: (i) you have given your consent for one or more specic purposes; this, however, does not apply, whenever the processing of Personal Information is subject to European data protection law; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of ocial authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party. We may also combine or aggregate some of your Personal Information in order to better serve you and to improve and update our Website and Services.
We rely on user’s consent and compliance with the law and legal obligations as legal bases as dened in the GDPR upon which we collect and process your Personal Information.
Note that under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases above. In any case, we will be happy to clarify the specic legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Disclosure of information
Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, we may share your information with our aliates, contracted companies, and service providers (collectively, “Service Providers”) we rely upon to assist in the operation of the Website and Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. We will not share any personally identiable information with third parties and will not share any information with unaliated third parties.
Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorize them to use or disclose any of the provided information for their own marketing or other purposes.
We may also disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
Retention of information
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, to enforce our agreements, resolve disputes, and unless a longer retention period is required or permitted by law.
We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectication, and the right to data portability cannot be enforced after the expiration of the retention period.
Transfer of information
Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. However, this will not include countries outside the European Union and European Economic Area. If any such transfer takes place, you can nd out more by checking the relevant sections of this Policy or inquire with us using the information provided in the contact section.
Data protection rights under the GDPR
If you are a resident of the European Economic Area (“EEA”), you have certain data protection rights and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:
(i) You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information. To the extent that the legal basis for our processing of your Personal Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
(ii) You have the right to learn if your Personal Information is being processed by us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of your Personal Information undergoing processing.
(iii) You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You also have the right to request us to complete the Personal Information you believe is incomplete.
(iv) You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent. Where Personal Information is processed for the public interest, in the exercise of an ocial authority vested in us, or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection.
(v) You have the right, under certain circumstances, to restrict the processing of your Personal Information. These circumstances include: the accuracy of your Personal Information is contested by you and we must verify its accuracy; the processing is unlawful, but you oppose the erasure of your Personal Information and request the restriction of its use instead; we no longer need your Personal Information for the purposes of processing, but you require it to establish, exercise or defend your legal claims; you have objected to processing pending the verication of whether our legitimate grounds override your legitimate grounds. Where processing has been restricted, such Personal Information will be marked accordingly and, with the exception of storage, will be processed only with your consent or for the establishment, to exercise or defense of legal claims, for the protection of the rights of another natural, or legal person or for reasons of important public interest.
(vi) You have the right, under certain circumstances, to obtain the erasure of your Personal Information from us. These circumstances include: the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure such as where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, to exercise or defense of legal claims.
(vii) You have the right to receive your Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance from us, provided that such transmission does not adversely affect the rights and freedoms of others.
(viii) You have the right to complain to a data protection authority about our collection and use of your Personal Information. If you are not satised with the outcome of your complaint directly with us, you have the right to lodge a complaint with your local data protection authority. For more information, please contact your local data protection authority in the EEA. This provision is applicable provided that your Personal Information is processed by automated means and that the processing is based on your consent, on a contract which you are part of, or on pre-contractual obligations thereof.
Data protection rights under the GDPR
If you are a resident of the European Economic Area (“EEA”), you have certain data protection rights and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:
(i) You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information. To the extent that the legal basis for our processing of your Personal Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
(ii) You have the right to learn if your Personal Information is being processed by us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of your Personal Information undergoing processing.
(iii) You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You also have the right to request us to complete the Personal Information you believe is incomplete.
(iv) You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent. Where Personal Information is processed for the public interest, in the exercise of an ocial authority vested in us, or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection.
(v) You have the right, under certain circumstances, to restrict the processing of your Personal Information. These circumstances include: the accuracy of your Personal Information is contested by you and we must verify its accuracy; the processing is unlawful, but you oppose the erasure of your Personal Information and request the restriction of its use instead; we no longer need your Personal Information for the purposes of processing, but you require it to establish, exercise or defend your legal claims; you have objected to processing pending the verication of whether our legitimate grounds override your legitimate grounds. Where processing has been restricted, such Personal Information will be marked accordingly and, with the exception of storage, will be processed only with your consent or for the establishment, to exercise or defense of legal claims, for the protection of the rights of another natural, or legal person or for reasons of important public interest.
(vi) You have the right, under certain circumstances, to obtain the erasure of your Personal Information from us. These circumstances include: the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure such as where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, to exercise or defense of legal claims.
(vii) You have the right to receive your Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance from us, provided that such transmission does not adversely affect the rights and freedoms of others.
(viii) You have the right to complain to a data protection authority about our collection and use of your Personal Information. If you are not satised with the outcome of your complaint directly with us, you have the right to lodge a complaint with your local data protection authority. For more information, please contact your local data protection authority in the EEA. This provision is applicable provided that your Personal Information is processed by automated means and that the processing is based on your consent, on a contract which you are part of, or on pre-contractual obligations thereof.
How to exercise your rights
Any requests to exercise your rights can be directed to us through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sucient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. If we receive your request from an authorized representative, we may request evidence that you have provided such an authorized representative with power of attorney or that the authorized representative otherwise has valid written authority to submit requests on your behalf.
You must include sucient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we rst verify your identity or authority to make such a request and conrm that the Personal Information relates to you.
Do Not Track signals
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identiable information from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Website and Services are not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Information. For a description of Do Not Track protocols for browsers and mobile devices or to learn more about the choices available to you, visit internetcookies.com.
Social media features
Our Website and Services may include social media features, such as the Facebook and Twitter buttons, Share This buttons, etc (collectively, “Social Media Features”). These Social Media Features may collect your IP address, what page you are visiting on our Website and Services, and may set a cookie to enable Social Media Features to function properly. Social Media Features are hosted either by their respective providers or directly on our Website and Services. Your interactions with these Social Media Features are governed by the privacy policy of their respective providers.
Email marketing
We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third-party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.
In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e- mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us.
Links to other resources
The Website and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Website and Services and to read the privacy statements of each and every resource that may collect Personal Information.
Personal information you disclose to us
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
names;
email addresses;
your risk tolerance and ability to sustain losses;
your investment horizon;
We do not process sensitive information. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Do California residents have speci c privacy rights?
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations denes a "resident" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose All other individuals are denied as "non-residents." If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information. What categories of personal information do we collect? Please see the section "personal information you disclose to us" for more information. How do we use and share your personal information? More information about our data collection and sharing practices can be found in this privacy notice. You may contact us by email at contact@davensi.com, or by referring to the contact details at the bottom of this document. If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-prot entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
Your rights with respect to your personal data
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the ex ercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell or share personal information to third parties;
the categories of personal information that we sold, shared, or disclosed for a business purpose;
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identied in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verication efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on le, or we may contact you through a communication method (e.g., phone or email) that y ou have previously provided to us. We may also use other verication methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verication. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud- prevention purposes. We will delete such additionally provided information as soon as we nish verifying you.
To exercise these rights, you can contact us by email at contact@davensi.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
Do Virginia residents have specific privacy rights?
Virginia CDPA Privacy Notice
Under the Virginia Consumer Data Protection Act (CDPA):
"Consumer" means a natural person who is a resident of the Commonwealth acting only in household context. It does not include a natural person acting in a commercial or employment context.
"Personal data" means any information that is linked or reasonably linkable to an identied or identiable natural person.
"Personal data" does not include de-identied data or publicly available information.
"Sale of personal data" means the exchange of personal data for monetary consideration.
If this denition "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.
The information we collect, use, and disclose about you will vary depending on how you interact with us and our Services.
Your rights with respect to your personal data:
Right to be informed whether or not we are processing your personal data Right to access your personal data Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or proling in furtherance of decisions that produce legal or similarly signicant effects ("proling")
We have not sold any personal data to third parties for business or commercial purposes. We will not sell personal data in the future belonging to website visitors, users, and other consumers.
Exercise your rights provided under the Virginia CDPA
More information about our data collection and sharing practices can be found in this privacy notice. You may contact us by email at contact@davensi.com, by submitting a data subject access request, or by referring to the contact details at the bottom of this document. If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Verication process
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-ve (45) da ys of receipt. The response period may be extended once by forty-ve (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at contact@davensi.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
Information security
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modication, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
Data breach
In the event we become aware that the security of the Website and Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notication to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website, send you an email.
Changes and amendments
We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will send you an email to notify you. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.
An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specied. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specied at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.
Contacting us
If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the details below:
contact@davensi.com
We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.
