DevSM PRIVACY POLICY

This Policy describes how DevSM Inc. and its affiliates and subsidiaries (collectively referred to as “DevSM”) collects, uses, protects, and discloses your personal information. DevSM is committed to complying with the fair information principles set out in Canada’s Personal Information Protection and Electronic Documents Act, which are discussed in detail further below.

What is Personal Information?

Personal information is any information that identifies you as an individual. This can include, for example,

age, name, date of birth, telephone numbers, ID numbers, and marital status
opinions, comments, and reviews
income, employment records, credit records, and loan records

How Do We Collect Your Personal Information?

As a general policy, no personally identifiable information is automatically collected when you visit a web site owned or operated by DevSM. However, certain non-personal information is recorded by the standard operation of our internet servers. Information such as the type of browser being used, its operating system, and your IP address may be gathered to enhance your online experience.

In addition, we may ask for your name, address, and/or payment information if you wish to make a purchase and/or order items to be delivered to your home. We may also collect personal information if you

create an account or profile,
subscribe to our services,
participate in courses, events or promotions,
send questions or comments by email or live chat,
interact with our sales or customer support team,
apply for a job with us online,
fill out surveys, quizzes, or assessments, or
otherwise communicate with us or any other person through or about our services or course offerings.

Why Do We Collect Your Personal Information?

We only ask for your name, address, and/or payment information to complete and satisfy our rights and obligations with regard to transactions that you initiate, such as ordering online courses and/or paper materials. If you submit personal information for another purpose such as participating in a course or filling out a survey, we will only collect your information for that purpose or as otherwise required or permitted by law. We will inform you of the purposes for which we need the personal information, and we will only collect information that is relevant for the purpose of providing the products and services you request.

How Do We Protect Your Personal Information?

We use physical, organizational, and electronic safeguards to protect your personal information. For example, we restrict physical access to areas where information is collected, stored or processed to authorized employees. We also maintain electronic security measures such as firewalls, encryption, and password protection to prevent unauthorized access to our electronic records of personal information. We ensure employees understand our privacy policy and only use your information for the reasons you gave it to us.

We do not store your payment information on our servers but rather use secure third parties such as Stripe, PayPal, or Apple integrations to process secure payments.

How Long Do We Retain Your Personal Information?

We will only keep your personal information for as long as we need it for the reasons you gave it to us, unless there is a legal requirement to keep it longer such as where it relates to a court proceeding or a complaint.

With Whom Do We Share Your Personal Information?

We may share your personal information with third party service providers such as Stripe, PayPal, or Apple integrations if necessary to provide a product or service you requested. It may also be necessary to share your information with service providers we hire to assist with support services such as data processing. We only contract with suppliers that have a proven track record of securely handling personal information. However, if those service providers have servers located in foreign jurisdictions, they will be bound by the laws of those jurisdictions and will need to comply with any orders of government authorities to give them access to information on those servers.

We will not sell your personal information to any other parties unless we have your express permission to do so. There may be times we need to disclose your information to other parties without selling it, such as when we need to consult credit reporting agencies in order to provide a product or service you requested, or when we need to report a risk of criminal activity to legal authorities. We may also be required to disclose information to regulators for the purposes of an audit or investigation.

How Do We Comply with Canada’s Fair Information Principles?

This section of the Policy sets out more information about how we comply with the fair information principles set out in Canada’s Personal Information Protection and Electronic Documents Act. Each principle is discussed in turn below.

Accountability: Maintaining the security and confidentiality of your personal information is a top priority at DevSM. Employees, contractors, and suppliers are informed about and must comply with the policies and procedures we have established regarding the collection, use and storage of the personal information collected. We have designated individuals who are responsible for monitoring our ongoing compliance with the Privacy Principles.
Identifying purposes: Your information is collected in order to identify you as our customer and to provide you with products and services. Your information helps us determine your needs, what products and services would suit you, and your eligibility, as well as to provide you with information on other products and services you might be interested in (provided by us or by our affiliates). We also collect your information to comply with laws and regulations and to maintain both your interests and our own.
Consent: Your consent is required for the collection, use and disclosure of your personal information, subject to certain exceptions (such as medical emergencies or government investigations). Your consent may be given verbally, electronically, in a written format or through authorized representatives.
Limiting collection: We collect your personal information directly from you (or your authorized representative) for the purposes previously mentioned. We may also collect information from external sources such as credit bureaus or employers.
Limiting use, disclosure, and retention: We will only use or disclose your personal information for the purposes for which it was collected, other purposes you consent to, or as required or permitted by law. We will only keep it as long as is necessary to satisfy the purposes for which it was collected, or as required or permitted by law.
Accuracy: We will strive to maintain the accuracy and relevance of your personal information. If there is any change to your information, please notify us at the contact information below and we will update our files. You can also ask our Compliance Officer at any time for a copy of all of your personal information that we have on file, and if you identify any inaccuracies, we will work with you to correct them.
Safeguards: The security of your personal information involves physical, organizational, and electronic methods. We only contract with suppliers that have a proven track record of securely handling personal information. We restrict physical access to areas where information is collected, stored or processed to authorized employees. We also maintain electronic security measures such as password protection to prevent unauthorized access to our electronic records of personal information.
Openness: We will make information about our privacy policies and practices for managing your personal information available to you upon request. For inquiries regarding our policies and procedures, please contact our Compliance Officer at the address listed further below.
Individual access: When you request it, we will tell you what personal information we have, what it is being used for, from whom it was collected and to whom it has been disclosed. We will provide this information to you in a timely manner. We will provide you with access, upon request, to your own personal information, except in certain situations. We will explain the reason for this lack of access when you make your request. We will not provide certain information if it

Contains references to other persons
Is subject to solicitor-client or litigation privilege
Contains our own confidential information
Cannot be disclosed for legal reasons
Is used for the detection and prevention of criminal activity and dealings in proceeds of crime

We will not record in your file when personal information is disclosed to third parties for routine purposes, such as

Reporting to Canada Revenue Agency (T5 or other reports)
Updating of credit information to credit bureaus
Information provided to legal counsel for the purpose of collections

If it is discovered that the information that we have on file is incorrect or obsolete, we will update our records accordingly. We reserve the right to decline a requested correction, but we will append a notation to the records of your requested alternative information. Whenever possible we will correct any information which we may have given to an outside organization.

If a third party (such as a credit bureau or reporting agency) has given us information that you believe is incorrect, we will provide you with the name and address of that party so you can contact them to correct the information they maintain.

Provide recourse: You may contact us if you have any inquiries or concerns with respect to our privacy policies and practices. We will deal with your questions and concerns as quickly as possible. All inquiries should be sent to our Compliance Officer at the address listed below.

The security and confidentiality of your personal information is a high priority for DevSM. We hope that this Privacy Code is informative and useful to you. If you have any concerns regarding this Privacy Code or have any further questions, you may bring them to our attention as follows:

Compliance Officer

Aleida Dikland
DevSM Inc.
1791 Totem Ranch Rd East,
Oxford Station, Ont.
K0G 1T0

Email: [email protected]

Telephone: 613-889-7584