What we do with your data
Last updated at: February 11, 2020
DevClass (“DevClass”, “our”, “we”) is owned and operated by Situation Publishing Limited.
Situation Publishing Limited
Portland Street Trading Estate
14 Portland Street
The Website is not intended for children (those aged 13 and under) and we do not knowingly collect data relating to children.
- What information do we collect?
- How we use your personal data?
- Disclosure of your personal information
- International Transfers
- Third Party Websites
- How long do we keep your information for?
- Your Rights
- Your Rights
- Your California Privacy Rights
What information do we collect?
What is personal data?
Data we collect from you
DevClass may collect, process and use your personal data (including your name, postal address, email address, telephone number, mobile number and technical data including your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website (“Technical Data”).
We collect this data in a number of ways, including through:
- Direct interactions. You may give us your identity, and contact details] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- create an account on our Website;
- subscribe to our headlines-by-email service;
- subscribe to our publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Third parties. We may receive personal data about your from various third parties, for example, Technical Data from analytics providers such as Google based outside the EU.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by changing your account settings or by contacting us.
We have set out below more specifics on how we use such data.
DevClass will collect your IP address to produce a server log – as all web servers do – and other data derived from your IP address including your country or region, your ISP, and in some cases your organisation. This information is used to monitor the volume of traffic the site receives, the number of readers and their location. We do not use this information to track the activity of individual visitors to the website.
DevClass runs advertising for a wide variety of organisations. These adverts are served from our advertising servers as well as from third-party advertising servers managed by the advertiser. Recent third-party ad servers include Google Ad Manager (formerly DoubleClick), SizMek and FlashTalking.
These ad servers may attempt to set cookies on your computer. All these sites stress that information gathered through these cookies is used purely for the purpose of advert delivery, recording and segmentation. They do not use information gathered through their cookies for their own use, and they do not collect any personally identifiable information.
The respective privacy policies of these ad servers can be found here:
If you encounter any problems with advertising please email email@example.com.
Email and Online Forms
As previously stated, if you choose to subscribe to our headlines-by-email service, or complete any of our online forms, you may be asked to supply personal data. If you choose to do so, that information is recorded and used for broad demographic information, which may be used to target advertising. If permission is granted, this information may be used to target specific users with occasional emails informing you about commercial services provided by DevClass; and offers from our partners.
DevClass will never use your data for anything beyond the reason stated and the permissions you grant us. To alter the emails which you receive from us, including unsubscribing from all email communications, please follow the links on any email communication.
Register journalists may use their email address to reply to comments that you have posted on our Website.
If you enter DevClass competitions, you will be asked for some personal information, but only to allow us to judge the validity of your applications and to contact you should you be declared a competition winner.
If permission is granted, this information may be used to target specific users with occasional emails informing you about commercial services provided by DevClass, and offers from our partners.
DevClass will never use your data for anything beyond the reason stated and the permissions you grant us.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosure of your personal data
Depending on how and why you provide us with your personal data. We may share it in the following ways:
- if required to do so by law or if we believe that such action is necessary to protect and defend the rights, property or personal safety of the Website or its visitors.
- if we have first obtained your consent to do so, DevClass may share your information with our trusted partners so that they can provide information to you about products and services that may interest you by email. If at any time you do not wish us to share your information in this way, then you can opt out any time by contacting us.
- With our service providers. We will use third party service providers to undertake processing operations on our behalf, and this may require us to share your personal data with them. These service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. For example, if you use a credit or debit card to make a payment to us, we will send your details to PayPal, who we employ to do our online payment processing. DevClass will not keep your card details, other than the type of card used. However, details may be stored by our payment providers (i.e. PayPal) for the purposes of processing further payments you have instructed us to collect.
We reserve the right to publish emails and letters sent to DevClass. If you ask not to have your identity revealed, that information won’t be published. We never publish a private email address unless specifically asked to do so by you.
We may transfer your personal data outside the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Links to third party sites
How long do we keep your information for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirement.
In some circumstances you can ask us to delete your data: see ‘Your Rights‘ below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Data storage and security
DevClass takes the protection of your information very seriously. We use encryption (SSL) to protect your personal data when appropriate, and all the information provided to DevClass is stored securely once we receive it.
DevClass may store your personal data on secure servers either on our premises or in secure third party data centres.
Aptum Technologies Ltd, whose servers are located in the EEA and the USA, hosts DevClass’s Website
As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.
Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).
Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).
Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
Your Right to Restrict Processing
You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.
Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
Your Right to Portability
Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
Because of the kind of work that we do and the systems that we use, we do not envisage this right being relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we will consider such requests.
Your Right to stop receiving communications
For details on your rights to ask us to stop sending you various kinds of communications, please contact us.
Your Right to object to automated decision making and profiling
You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
Exercising your rights
When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).
Your California Privacy Rights
The California Consumer Privacy Act (“CCPA) provides certain rights for California consumers. If you are a consumer residing in California you may ask us about the information we release to other organisations for their marketing purposes. For a complete statement of these rights under the California Consumer Privacy Act (CCPA), including the right to opt out of the selling of your personal data and how you can exercise them please visit Your California Privacy Rights.
Head of Data Protection
Situation Publishing Limited
Unit 1 Portland Street Trading Estate
14 Portland Street
Reader Services: firstname.lastname@example.org