A few points to consider before using the Services:
- Throughout this document, “we”, “us” and “our” refer to the Devlight LLC., the company incorporated under the law of Ukraine, and a data controller unless otherwise stated below;
- As a data controller, we define what personal information (personal data) to collect, how long to process it and why
- This document applies insofar you use the Services. In all such cases, we presume that you should reasonably expect that the use of the Services requires processing your personal data. Should you disagree, you are free to stop using the Services or object to personal data processing;
- We never collect your personal data in secrecy. We never request more than reasonably required for the respective purpose. For example, see our section “Contact us” (here ), where we require your e-mail only to respond to you without obliging you to reveal your identity;
- What information do we collect, on which grounds, why?
- With whom do we share your data?
- How long do we retain your data?
- Your rights
- How do we protect your personal data?
- Contact information
What Information Do We Collect, on Which Grounds and Why?
Data you provide us with
Scope. We may collect or obtain personal data from you when you use the Services. As a rule, this occurs when you expressly provide us with your information via “Contact us” form on the Website. The personal data that we collect or obtain includes your name; e-mail address; your phone number; project budget and the description.
In addition, we may receive your personal data when you send us an application to become a member of our team via the “Career” form on the Website. In this case, we require you to disclose your name, email address, phone number, position, level and your CV or message as well as job application details. You are also free to share with us your website, blog, portfolio, LinkedIn profile, and/or College/University, which we may use during selection of applicants.
In both cases, other data, such as your company name, private account on any social media or any personal data you disclose in your message body are unnecessary for us, but you can share them with us at your sole discretion. We may use them in order to better evaluate your request and prepare an appropriate response. We kindly ask you not to provide us with any excessive personal data, including sensitive data.
Purpose and use of data. We collect such data because you provide us with them through the forms on the Website and you reasonably expect us to collect and use such data. We process the data you provided us through the “Contact us” form to provide the Services you requested, including to provide customer care and support, detect, prevent and address technical issues, or simply to answer to your requests. We also process the data you provided us via the “Career” form to provide you with all needed information, as well as to be aware of our potential employee, and to contact you.
Legal grounds. We mostly use your personal data for the purposes, defined above, either to perform contract or enter into the contract with you (to provide you with our Services), or upon your consent. We could also use some personal data in view of our legitimate interests. Legitimate interests are a possibility to lawfully use your personal data without your explicit consent. This is possible insofar such interests are not outweighed by your interests. In our case, we have legitimate interests, for instance, in the effective delivery of the Services or in building the relationship with potential employees and contractors/subcontractors and communicating with them regarding possible cooperation with us. We believe that our legitimate interests correspond to your interest in obtaining the Services and enter into possible cooperation.
In all such cases, we ensure your right to object against our use of your personal data for such purposes.
Newsletters and similar communication
Scope. When you subscribe to our newsletters on our Blog page, you give us your email address.
Purpose and use of data. We may use this data, as well as your data that you previously provided us through the Website forms, which is your email and name and relevant business information, in order to send you messages with some useful information about software development or with some information of promotional nature.
Legal grounds. We send you relevant useful information based on the legitimate interests pursued by the Devlight LLC – e.g. to propose our Services, develop our brand and public image and set up relationships with potential clients. You may always opt-out from our newsletters by clicking the respective link in each message.
We consider that you’re interested in receiving our emails until you unsubscribe from the mailing list.
Automatic collection (cookies and similar web technologies)
Scope. We may also collect or obtain personal data from you because we observe that data about you from the way you interact with the Website. We use analytical web technologies to collect the cookies identifiers in the manner explained below. In such cases, we collect the details of how you like to interact with us and other similar information.
Purpose. We collect such data to improve your experience when you use the Website and ensure that the Website is functioning effectively.
Legal grounds. We process such data based on your explicit consent, enabling us to collect the cookies identifiers.
Use of data. We use such data to assess the Website performance, customize our Website to provide you with a more personalized experience and draw your attention to information regarding the Services.
- In both cases, we may process your personal data to comply with the legal requirements, particularly to respond to the requests from competent authorities, as well as to send you details about our Services that may be of interest to you, ensuring your right to object
We understand the importance of protecting children’s privacy. Our Services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children.
Note that we may process any of your personal data not only on the bases indicated above, but also when the processing is necessary:
- to protect your vital interests or vital interests of another natural person;
- for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;
- for the purposes of the legitimate interests pursued by Devlight or by a third party (e.g. to prevent or investigate possible wrongdoing in connection with the Website or to protect ourselves, our sub-contractors, partners and affiliates against liability).
If we decide to change the purposes of processing specified above, we will inform you on such changes prior to the use of your personal data within the newly set purposes. Where applicable, you will have to provide your consent for the amended purposes (unless additional purpose of processing is compatible with those listed above).
Please note that we do not sell your data or make any decision based solely on automated processing that may produce legal effects or similarly significant effects.
With Whom Do We Share Your Data?
Access by our employees and contractors
We may share your personal data with the people we hired or with whom we entered into services agreements. For the purposes stated above, we may share your personal data with such individuals. We secure such processing by taking the necessary security and organizational precautions. We engage both companies and individual entrepreneurs from the EU and other countries such as the US, Ukraine and Poland.
Some of the recipients of your personal information may be in the countries, outside of the European Union. Laws of such countries may not provide the same level of data protection. In such cases, we will ensure that there are adequate safeguards in place to protect your personal information that comply with our legal obligations – a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for transfers of personal information to third countries.
We may use certain external services, including cloud storage and analytical services, in the course of the Services provision. As a rule, we share non-personal, de-identified and aggregated information with third parties, including data analytics services. The list of the external services which we use could change from time to time.
If you want us to provide you with the complete list of such external services, please contact us via email@example.com.
You also have to know that Devlight may disclose your personal data to enforce and comply with the laws. In other words, Devlight may disclose information necessary for the investigation or legal process on official request or the official bodies acting within their powers.
How Long Do We Retain Your Data?
We store data until it is no longer necessary to provide our Services. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. In any case, we would not retain your data more than it is necessary for the purpose for which they were collected.
We mayl anonymize the personal data in certain cases. The anonymization means that we delete parts of your data (such as your name, contact details or CV) from the data set so you no longer can be identified as an individual. From that point on, the data we keep is not considered as personal data anymore.
We can use the anonymized data for the purposes of data integrity within our internal systems, which is essential for their proper work, as well as for statistical purposes.
You have various rights in relation to your personal data, including a right to:
- obtain confirmation that we process your personal data and request a copy of the personal data we hold about you;
- ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
- ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data;
- object to our processing of your personal data, and withdraw the consent (if the consent is the legal ground for such processing).
To exercise any of your rights, or if you have any other questions about our use of your personal information, please contact us via the contracts indicated below.
If you are dissatisfied with the manner of data processing or our response, you have a right to complain to the EU Data Protection Authority in your jurisdiction.
How Do We Protect Your Personal Data?
We take strict measures to safeguard one’s privacy. Among others, we take measures to ensure physical and electronic control. We also would attempt to inform any client and respective agencies of personal data breaches should there be high risks of violation of your rights as data subjects. We would also do our best to minimize any such risks.
Devlight LLC, registered under the law of Ukraine
Contact e-mail: firstname.lastname@example.org