Privacy Policy
1. Introduction
1.1 This notice applies to companies that are part of Two Brothers Air and Heat, Inc d/b/a Dvs Smart Mortgage, (including "Dvs" "we", "us" or "our") includes the companies mentioned above and all relevant group subsidiaries.
1.2 This policy applies to information we collect about: a) visitors to our website; and b) people who do business with us or register for our service.
1.3 Please read this Privacy Notice carefully to understand our views and practices regarding your personal data, how we use it, and how we will treat it. If you do not agree with this Privacy Notice, please do not use our services.
2. Information about you
2.1 The information we collect about you When you do business with us or register for our service, we may collect the following personal information about you: a) your full name, residential address, email address, residence, nationality, IP address, number mobile phone , date of birth and bank or payment card details and any proof of your identity and / or address that we may request; b) details of any transaction you carry out through our website and / or mobile application of the fulfillment of your requests; c) details of any bank account (including but not limited to: account holder, account name, account number, sort code, online banking PIN, "TAN" transaction authentication number and password, available balance and transaction history of your bank account, ); d) details of any credit, debit or other card used by you for transactions; e) your participation in any promotion sponsored by us; f) correspondence that you send to us; g) calls that we make to you or that you make to us; h) surveys you complete; i) information collected through cookies; see Section 6 below for more details; and j) your IP address, login times, operating system and browser type.
2.2 In order to comply with our legal obligations to prevent fraud and money laundering, we will obtain information about you from third party agencies, including your financial history, bankruptcy and county court judgments, from credit reference and credit prevention agencies. fraud when you open an account with Dvs and at any time when we consider it necessary to prevent fraud and minimize our financial risks.
3. Information about other people
3.1 If you appoint a representative to act on your behalf, we will require the representative to:
a) Proof that you have given your representative authority to exercise your data protection rights or file a complaint on your behalf (such as a letter granting them your authority); and
b) Proof of identity of the representative.
You confirm that the Designated Representative can:
3.1.1 receive on your behalf any data protection notice; and
3.1.2 give your consent for the transfer of your personal data abroad.
4. How We Will Use Information About You
4.1 We use the information we hold about you in the following ways: a) to operate and manage your account and to provide the services you have requested; b) to carry out your instructions for making and receiving payments and transacting using our services, including verifying that you have sufficient funds in your designated bank account to make such payments; c) to allow you to participate in the interactive features of our website; d) to notify you of changes to our service (s) / this website; e) improve the training of our internal customers; f) to comply with financial services regulations, including the retention of financial information and transactions; g) for financial and identity controls, fraud detection and prevention controls, credit controls and anti-money laundering; h) for customer service, including answering questions and responding to comments and complaints; i) to improve the security of our services; j) to ensure that the content of our website is presented in the most effective way for you and your computer; and k) for research, statistical analysis and behavior analysis.
5. Marketing
5.1 We may also want to provide you with information about the special features of our website or any other service that we think may be of interest to you. If you prefer not to receive this information, please send an email to contact@dvfinancing.com If you have agreed to Neo providing you with marketing information and now you want to opt out or decide not to participate at a later date, you can do so by sending an email to contact@dvsmortgage.com
6. Cookies and other information collection technologies
6.1 Our website uses third-party cookies. Cookies are text files that are placed on your computer to collect standard Internet log information and information about visitor behavior. These cookies allow us to distinguish you from other website users, which helps us to provide you with a good experience when you browse our website and allows us to improve our site.
7. How we protect your information
7.1 We have implemented the following security procedures and technical and organizational measures to protect your personal information: a) access to your account is controlled by a password unique to you; b) we store your personal data on secure servers; and c) we automatically encrypt your confidential information in transit from your computer to ours.
7.2 We have implemented measures designed to protect your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. The security and protection of your information also depends on you. If we have provided you (or if you have chosen) a password or access code to access certain parts of our website / portal or mobile applications and the like, you are responsible for keeping this password and / or access code confidential. You must not share your password and / or access code with anyone. You must ensure that there is no unauthorized use of your password and access code. Dvs will act on the instructions and information received from anyone who enters their user ID and password and you understand that you are fully responsible for all use and any actions that may take place while using your account.
7.3 You must immediately notify Dvs of any information that you have provided to us that has changed.
7.4 The transmission of information over the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our site, unless you are communicating with us through a secure channel that we have provided to you. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
7.5 If you are concerned that any of your login details have been compromised, you can change them at any time once you are logged in, but you should always contact Dvs Customer Services immediately. and tell us why you think your login details have been compromised.
8. Information retention
8.1 The periods for which we retain your personal information are determined based on the nature and type of information, the Neo Service and the country in which it is provided, as well as applicable local legal or regulatory requirements.
8.2 If you use the Dvs Services, we will retain your personal information for as long as necessary to provide you with the services of your choice and any linked legitimate business purposes. That would generally mean that we retain your personal information for as long as you are our customer and for a period thereafter.
8.3 When our relationship with you ends, we still need to retain certain elements of your personal information for no longer than 5 years.
8.4 We may also continue to market and send you direct marketing, subject to local laws and where you have not objected to such marketing.
9. Disclosure of information
9.1 We may disclose your personal information to our associated companies, which means our subsidiaries and any subsidiaries of our shareholder (s) and / or any company that provides outsourced services to us, which are based in different countries within.
9.2 Disclosure of your personal information may be necessary to, among other things, fulfill your request, process your payment details, provide support services, and monitor fraudulent activities.
9.3 When sending money to a person you want to pay to, we will pass on certain details to the recipient. Depending on the requirements of that other person and the type of payment involved, we may send other personal data such as your name, address and country of residence if the recipients request this information from us in order to improve the payment process, to reconcile payments. . with the commercial transaction or to carry out your own controls against fraud and money laundering.
9.4 When you open an Account, at intervals of up to every 3 months and at any other time that we deem necessary to do so to protect our financial interests and prevent money laundering or fraud, we share certain information about you and your account with Dvs, which may include financial history and transactions as part of our normal business operations with our banks, payment facilitating partners, credit / debit card processing services, identity verification service providers and credit reference agencies to limit our exposure to fraud and others criminal activities and to manage our financial risk. When conducting fraud prevention or identification checks, relevant parties may retain a record of our inquiry along with their information and may share this information with other fraud prevention agencies.
9.5 We will share your personal information with third parties only in the ways that are described in this Privacy Notice. We do not sell your personal information to third parties. We may also disclose your personal information to:
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a potential buyer of our business or a buyer of a substantial number of shares in our business, if Dvs participates in a merger, acquisition or sale of all or part of its assets, you will be notified by email and / or a prominent notice on our website of any change in ownership or use of your personal data, as well as any choices you may have regarding your personal data; b) Law enforcement, and any other law enforcement body, regulatory body or court if we have an obligation or the law requires us to disclose or share your personal data. , or to protect the rights, property or safety of ourselves or our group companies, our clients or others; and c) third parties that we may occasionally use to provide you with the services you have requested. These third parties will not use your personal information for any other purpose than the one for which it was designed.
10. Transfers abroad
10.1 The information you provide may be transferred to countries that do not have similar protections in place regarding your data and restrictions on its use as set out in this policy. However, we will take steps to ensure that adequate safeguards are in place to ensure the security of your information.
11. Your rights
11.1 Access to your personal data: You have the right to request a copy of the information we hold about you. If you would like a copy of some or all of your personal information, please send an email to contact@dvsmortgage.com or We may charge a small fee for this service.
11.2 Correction of personal data: We want to ensure that your personal information is accurate and up to date. If any of the information you have provided to Neo changes, for example if you change your email address or name, please let us know the correct details by sending an email to contact@dvsmortgage.com You can ask us to correct and / or remove information that you think is inaccurate.
11.3 Right to withdraw consent: where we have relied on your consent to process your personal data, you have the right to withdraw that consent. It is important to know that when you withdraw your consent Neo may have to end the relationship because we trust your data to be able to provide you with a service.
11.4 Right to erasure (also known as 'right to be forgotten'): you can request verbally through our Customer Services or in writing to contact@dvsmortgage.com that we erase your personal data when there is no compelling reason to continue with the prosecution. This right only applies in certain circumstances; it is not absolutely correct.
11.5 Right to data portability: This right allows you to obtain your personal data that you have provided us with your consent or that were necessary for us to provide you with our products and services in a format that allows you to transfer that personal data to other organization. You may have the right to have your personal data transferred directly to the other organization, if this is technically feasible.
11.6 Right to restrict the processing of personal data: In certain circumstances, you have the right to request that we suspend the processing of your personal data. When we suspend the processing of your personal data, we will still be allowed to store it, but any further processing of this information will require your consent, subject to certain exemptions.
11.7 Right to object to the processing of personal data: You have the right to object to our use of your personal data, which is processed on the basis of our legitimate interests. However, we may continue to process your personal data, despite your objection, when there are compelling legitimate reasons to do so or when we need to process your personal data in connection with any legal claim.
12. Follow-up
12.1 We may monitor and record communications with you (such as telephone conversations and emails) in order to ensure quality, training, fraud prevention and compliance.
13. Communicate with you
13.1 We may contact you by email at the primary email address registered in your account with Dvs or by telephone at the contact numbers you provided when registering for your account with Dvs. You can change your primary email address and / or contact number at any time.
13.2 You may also receive transactional emails generated by the system, such as confirmation of charges, notification of receipt of payments, notification of password changes, etc., which are necessary for the proper functioning and administration of your account.
13.3 Phishing is the name given to attempts to steal personal and financial account data from a website user. Phishers use deceptive or "fake" emails to lead users to spoofed websites where the user is tricked into entering their personal information, such as credit card numbers, user names and passwords. WE WILL NEVER EMAIL YOU ASKING FOR SUCH DETAILS AND OUR STAFF WILL NEVER ASK YOU FOR YOUR PASSWORD. If you receive such an email or someone claiming to work for us asks for your password, please forward the email or report the incident to our Data Protection Officer at contact@dvsmortgage.com
14. Your consent
14.1 By submitting your personal information, you agree to the use of that information as set out in this policy.
15. Changes to the Privacy Notice
15.1 We periodically review our Privacy Notice. If we change our Privacy Notice, we will post the changes on this page and place notices on other pages of the website, so that you are aware of the information we collect and how we use it at all times. We reserve the right to make changes to our Privacy Notice at any time, without prior notice, when such change is required by applicable law.
16. Links to other websites
16.1 Our website contains links to other websites. This Privacy Notice applies to this website and our mobile applications, so when you access links to other websites, you should read their own privacy policies.
17. File a compliance
17.1 If you are not satisfied with the way we manage your personal data, you have the right to complain. Email your complaint to the Data Protection Officer at contact@dvsmortgage.com If you believe that your complaint has not been satisfactorily addressed, you can contact your local data protection authority depending on your location.