Privacy Policy for Devtiro.com

Last updated: 2026-03-26

Your Privacy Rights: See the UK & EU Data Protection Rights and US Privacy Rights sections below for important information about your rights under applicable laws.

This Privacy Policy describes how Devtiro Ltd (company number 12822863) ("Devtiro," "we", "us" or "our") processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, online learning platform, and social media pages) as well as our marketing activities, live events and other activities described in this Privacy Policy (collectively, the "Service")).

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, company name, and phone number.
Demographic data, such as your city, state, country of residence, postal code, and age.
Profile data, such as the username and password that you may set to establish an online account on the Service, redemption code, biographical details, avatar or picture, program content you have accessed, links to your profiles on social networks, interests, preferences, and any other information that you add to your account profile.
Learning progress data, such as completed modules, coaching exercises submitted, and learning pathways initiated.
Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Payment data needed to complete transactions, including payment card information or bank account number.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

Service providers that provide services on our behalf or help us operate the Service or our business.
Social media platforms, where you interact with our public content or contact us via those channels.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

Device data, such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 5G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Learning behaviour data, such as video playback events (pause, play, skip), time spent on program materials, and interaction with coaching exercises.
Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

For more information concerning our automatic collection of data, please see the Tracking technologies section below.

Data about others. We may offer features that help users refer friends or contacts to the Service, and we may collect contact details about these referrals so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

Tracking & other technologies

Cookies and other technologies. Some of the automatic collection described above is facilitated by the following technologies:

Cookies, which are small text files that websites store on user devices and that allow web servers to record users' web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both "session cookies" that are deleted when a session ends, "persistent cookies" that remain longer, "first party" cookies that we place and "third party" cookies that our third-party business partners and service providers place.
Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

For information concerning your choices with respect to the use of tracking technologies, see the Your choices section below.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Legal basis for processing. We process your personal data for the following legal bases:

Consent: We process your data based on your consent when you sign up for our mailing list or agree to certain data collection practices.
Contractual necessity: When necessary to fulfil our contractual obligations to you.
Legitimate interests: When we have a legitimate business interest in processing your data.
Legal obligation: When we need to comply with a legal or regulatory obligation.

Service delivery and operations. We may use your personal information to:

provide the Service;
enable security features of the Service;
establish and maintain your user profile on the Service;
track and personalise your learning journey;
facilitate your invitations to friends or contacts who you want to invite to join the Service;
communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
communicate with you about events or contests in which you participate; and
provide support for the Service, and respond to your requests, questions and feedback.

Service personalization, which may include using your personal information to:

understand your needs and interests;
personalise your learning experience based on your skill level and progress;
recommend relevant program materials and resources;
personalise your experience with the Service and our Service-related communications; and
remember your selections and preferences as you navigate webpages.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Marketing and advertising. We may use your personal information to send you direct marketing communications and may personalise these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Compliance and protection. We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorised, unethical or illegal activity, including cyberattacks and identity theft.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you and we will not attempt to reidentify any such data. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

Retention

We generally retain personal information to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

How we share your personal information

We may share your personal information with the following parties (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection).

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, and website analytics).

Platform providers. Third-party platforms that host and deliver the Service, including Circle.so. These providers may process your personal information as both processors (on our behalf) and controllers (for their own platform operations) as described in their respective privacy policies.

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with their privacy policy, available at https://stripe.com/privacy.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Business transferees. We may disclose personal information in the context of a sale, transfer, or merger of all or part of our business or assets, or in the event of insolvency or receivership.

We make commercially reasonable efforts to verify that third parties with whom we share personal information provide a level of protection consistent with the practices described in this Privacy Policy. Third parties other than service providers may use personal information as described in their own privacy policies.

Third-Party Platform Providers

The Service is provided through Circle.so, a third-party community platform. Circle.so acts as both a processor (for data we control) and a controller (for certain platform operations) of your personal information.

Circle.so's data practices: Circle.so collects and processes certain personal information as described in their Privacy Policy (available at https://circle.so/privacy). This includes:

Account authentication and management data
Platform usage and analytics data
Data necessary for platform functionality

Our responsibilities: Devtiro remains responsible for the coaching content and your learning data. We have contractual agreements with Circle.so requiring them to protect your data, but Circle.so's privacy practices are governed by their own privacy policy.

Infrastructure providers: We also use Amazon Web Services (AWS) for certain infrastructure services. AWS processes data on our behalf as described in their privacy policy.

Your choices

In this section, we describe the rights and choices available to all users. Users who are residents of the UK, EU, or US can find additional information about their rights below.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies and other technologies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.

Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us. Please note that our ability to delete or export your data may be limited by our third-party platform provider's capabilities. We will make reasonable efforts to fulfil deletion requests, but some data may be retained in backups or as required by our platform provider's data retention policies.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organisational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United Kingdom. Our Services are provided through third-party infrastructure including Circle.so and Amazon Web Services (AWS), with servers located in the United States and United Kingdom. Your personal information may be transferred to, stored, and processed in these locations where privacy laws may not be as protective as those in your state, province, or country.

For transfers from the UK/EEA to countries not considered adequate by the European Commission, we rely on appropriate safeguards such as Standard Contractual Clauses implemented by us and our infrastructure providers (including Circle.so) to protect your personal information. For more information about these safeguards, please contact us as set forth below.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

Email: contact@devtiro.com
Mail: Devtiro Ltd 124 City Road London England EC1V 2NX

UK & EU Data Protection Rights

Your rights. Under the UK and EU data protection laws, you have the following rights:

Access. You have the right to request access to your personal information, which includes asking for a copy of the personal information we hold about you.
Rectification. You have the right to request that we correct inaccurate or incomplete personal information about you.
Erasure. You have the right, in certain cases, to ask us to delete your personal information.
Restriction. You have the right to request that we temporarily or permanently stop processing some of your personal information.
Object. You have the right to object to our processing of your personal information when we are processing it on the basis of our legitimate interest.
Data portability. You have the right to request a copy of your personal information in a machine-readable format and the right to transmit that information to another controller. Please note that the format and completeness of exported data may be limited by our third-party platform provider's export capabilities.
Withdraw consent. If we rely on your consent to process your personal information, you have the right to withdraw that consent at any time.

To exercise these rights, please contact us at contact@devtiro.com. If you are unhappy with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) in the UK.

ICO Registration. Devtiro Ltd is registered with the Information Commissioner's Office (ICO) under registration number ZB139679.

Data Protection queries. If you have any questions or concerns about our privacy practices, please contact us at contact@devtiro.com.

US Privacy Rights

California Residents (CCPA/CPRA)

If you are a resident of California, you have specific rights regarding your personal information under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

Your rights include:

Right to Know. You have the right to request information about the categories and specific pieces of personal information we have collected about you, the sources from which it was collected, the purposes for which it is used, and the categories of third parties with whom it has been shared.
Right to Delete. You have the right to request deletion of personal information we have collected from you, subject to certain exceptions permitted by law.
Right to Correct. You have the right to request that we correct inaccurate personal information we hold about you.
Right to Opt-Out of Sale or Sharing. We do not sell your personal information, nor do we share it for cross-context behavioural advertising purposes. No action is required on your part to opt out.
Right to Non-Discrimination. We will not discriminate against you for exercising any of your rights under the CCPA/CPRA.
Right to Limit Use of Sensitive Personal Information. We do not use sensitive personal information beyond what is necessary to provide the Services.

To exercise any of these rights, please contact us at contact@devtiro.com. We will respond to verifiable requests within the timeframes required by applicable law.

Other US States

Residents of other US states with applicable privacy laws (including Virginia, Colorado, Connecticut, and Texas) may have similar rights regarding their personal information. Please contact us at contact@devtiro.com to exercise any such rights and we will respond in accordance with applicable law.

Terms

Privacy