1. Introduction
1.1 With this privacy policy, we are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.
1.4 Our website incorporates privacy preferences which affect how we will process your personal data. By using the privacy preferences, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can unsubscribe from certain cookies in Section 10.
1.5 In this policy, “we”, “us” and “our” refer to DevCom Consulting LLC. For more information about us, see Section 13.
2. Credit
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency, and pattern of your service use. The sources of the usage data are our analytics tracking systems (Google Analytics, Google Tag Manager & Hotjar). This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is your explicit consent (if you provide one).
3.3 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include your name and surname, corporate email, job title, corporate phone number and corporate geographical location. The source of the service data is either you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our NDA agreement (https://devcom.com/content/2018/05/NDA-Template.pdf) you are offered to sign before receiving services from us.
3.4 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is your consent.
3.5 We may process information contained in any inquiry you submit to us regarding goods and/or services (“inquiry data“). The inquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is your consent.
3.6 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent.
3.7 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms and links to other communication tools including email, phone, Skype and live chat tool. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.8 We may process any of your personal data identified in this policy, where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.9 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1 We may disclose your service data to our subcontractors insofar as reasonably necessary for providing our services. The legal basis for this processing is our NDA agreement (https://devcom.com/content/2018/05/NDA-Template.pdf) you are offered to sign before receiving services from us.
4.2 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 We use Hubspot. This CRM service stores your personal data you provide for our marketing and communication purposes. You can view the DevCom data processing agreement with this service provider at https://devcom.com/content/2018/05/HubSpot-Data-Processing-Agreement-Signed-Copy-v.-12April2018.pdf. The relevant cookies are authentication cookies.
4.4 We use Contact Form 7 and Flamingo. These contact form services store and transmit your personal data to our CRM system. You can view the privacy policy of Contact Form 7 at https://contactform7.com/privacy-policy/, and the privacy policy of Flamingo at https://flamingogroup.com/privacy/. The relevant cookies are authentication cookies.
5. Retaining and deleting personal data
5.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) All types of your personal data will be retained for a minimum period of 1 year following the date you provided it to us, and for a maximum period of 2 years following the date you provided it to us.
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a)the period of retention of your service data will be determined based on the duration of the period when we provide you services.
5.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. Amendments
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy by email.
7. Your rights
7.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 10); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
7.2 We may withhold personal information that you request to the extent permitted by law.
7.3 You may instruct us at any time not to process your personal information for marketing purposes.
7.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
8. About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies that we use
9.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website;
(b) security – we use cookies as an element of the security measures used to protect user accounts, including protecting our website and services ;
(c) analysis – we use cookies to help us to analyze the use and performance of our website and services;
(d) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally
10. Cookies used by our service providers
10.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
10.2 We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy and the way to opt out is available at https://www.google.com/policies/privacy/. The relevant cookies are analysis cookies.
10.3 We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link. The relevant cookies are analysis cookies.
You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.
10.4 We use Tidio Chat to provide you with a live chat service. This service uses cookies for identifying user information such as IP address and browser type. Also, we can ask you via Tidio Chat to provide us with your email so that we reply to your inquiry. You can view the privacy policy and the way to opt out of this service provider at https://www.tidiochat.com/en/privacy-policy. The relevant cookies are authentication cookies.
10.5 We use iThemes Security to ensure our website security This service uses cookies for identifying user information such as IP address. You can view the privacy policy and the way to opt out of this service provider at https://ithemes.com/privacy-policy/. The relevant cookies are security cookies.
10.5 We use heatmap to analyze the use of our website. heatmap gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. heatmap’s privacy policy, terms and conditions, and a data processing agreement are available at https://heatmap.com/terms. The relevant cookies are analysis cookies.
10.6 We use Jetpack to analyze the use of our website. heatmap gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. heatmap’s privacy policy agreement is available at https://automattic.com/privacy/ and the way to opt out at https://jetpack.com/support/privacy/. The relevant cookies are analysis cookies.
