INTERPRETATION OF THE TERMS
- “Personal data” is any information relating to you and that alone or in combination with other pieces of information allows a person that collects and processes such information to identify you as an individual.
- “Processing of the personal data” means any operation with your personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- “Data subject” is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing; it means you as a Customer of the Website.
- “Consent of the data subject/user” is any freely given, specific, informed, and unambiguous indication of the data subject/user's wishes by which they, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to them.
- “Website” refers to a mobile website, and mobile application owned and operated by Devellux Inc, incorporated under the laws of Delaware, the USA, located at 8 THE GREEN, STE A, DOVER, Kent, DE, 19901, the USA.
Some other terms like Customer, Expert, Company, etc., are defined in our Terms and Conditions.
Whenever you access the Website, we collect log information and put cookies on your device, by which we track your activity on the Website. You can always opt-out of cookies except those without which the Website cannot work.
When you are a registered Customer, we may collect from you and process Cookie identifiers and data you specifically provide us with upon registration, including first name, last name, email, phone number, or social network ID (if assigned through Facebook or Google), time zone, IP address, and device type.
Specifically, if you are an Expert, we may also collect and process, besides the aforementioned information, the other data provided by you, including zip code, gender, year of birth, city of residence, and education experience.
We process your personal data only when we have lawful bases.
DATA WE COLLECT: SCOPE
The Company collects from you only the following information and only for the stated the below purposes:
- Account for Customer
The Company collects and processes personal data submitted by you upon registration and further editing of settings in your account.
For registration purposes, you are obliged to submit the following necessary information: your email and password. The remaining information (first name and last name, phone number, date of birth, links to social accounts) is additional. You may edit your Account anytime with additional information. At the same time, you are not required to provide additional information not specifically necessary for the registration, it is your choice.
We are not responsible for any consequences caused by sharing your personal information with the Experts.
- Account for Experts
The Company collects and processes personal data submitted by Experts upon registration on the Website. For registration purposes, Experts submit their email and password, passport data (including its scanned copy), CV, documents that confirm education and payment data, and in some cases, billing address.
- Order Details
The Company collects and processes your order details, including all the information you mention when you fill out the order form. The same applies to the information shared with the Expert via Messaging System and the instructions for the assignment.
- Posting of Information
We process personal data freely submitted to you on the Website. This may be a survey you fill in on the Website or feedback you provide us with. The details of our communication include any information you provide us with when you contact our customer support team to ask questions and solve any possible problems.
The Company may also process information provided by you (including content and messages) that you post on/through our Website, including personally identifiable information. By doing so, you acknowledge that any information you share through the Services will be available to the Website and to the Experts. You also acknowledge that parts of your content cannot be deleted as it may be connected to the Services received by you and used by the Experts.
Unless you opt-out, we retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.
- Service Use, Cookies, and Other Similar Technologies
All Customers can choose to be notified by their browsers about each time a cookie file is sent. Also, they can turn off the cookies via browser settings. Please note that disabling cookies may affect or limit some features and functions on our Website. You will be able to place orders regardless of the cookies policies’ settings.
If you have already agreed to cookies on our website and want to change or disable them, please use the following instructions for your browser.
- Google Chrome
- Internet Explorer
- Billing Information
When you pay for a service on our Website, you provide us with payment and other information about you. Please note that we do not collect, process, or store your payment card details or other payment-related information on our Website. We just send it to third-party payment providers. Without this data, the Company would not be able to bill and provide you with the Service you have selected.
At the same time, for tax and financial reporting purposes, we store for a certain period of time only the following information: the Customer's first name and last name, the last four digits of the card, the transaction number, and in some cases mobile phone.
- Sensitive Data
Unless you explicitly agree, the Company does not process your sensitive data.
- Pages on Social Networks
We maintain the Company's official pages on social networks, such as Facebook. When you make interactions with our social network pages, such as subscribe to the pages, leave comments or preferences (e.g., ‘like’ our posts), we can analyze this data to measure our efficiency and conduct an analysis of our social media marketing in our legitimate interests.
- Information Required for Submitting Tax Documentation
To comply with the applicable tax and accounting legislation, we may be required to submit various tax documentation containing your personal data. For submitting tax documentation, we may process your personal data, including but not limited to your full name, country of citizenship, permanent residence address, mailing address, date of birth, U.S. taxpayer identification number, or foreign tax identifying number.
DATA WE COLLECT: PURPOSES
We may process the personal data you provided us voluntarily for the purposes defined below. From our perspective, we process your personal data to personalize the use of the Website to the fullest extent possible and to provide you with high-quality Services under the Terms and Conditions.
- Provision of Services
We process your personal data to authorize access to our Services and to fulfill our obligations under the Terms and Conditions for Services provision. Specifically, we use your personal data upon registration to help the Experts find your account or profile in order to provide you the Services.Please note that without the information provided by you under our Terms and Conditions, we will be unable to provide you with the functionality of our Website and connect you with the Experts.
- Payment Services
In order for you to use the Services, you will need to provide payment (e.g., credit card details) and billing information through our partners – third-party payment providers, which process your personal data by applying encryption and other security measures. Please see our Refund Policy for more information.
We use third-party payment providers to bill you through an online account payment in lieu of directly processing your credit/debit card information. Correspondingly all transactions are secured as our partners-payment providers use encryption protection. We do not store your payment information on our servers.
We may also use your payment card transaction data as shared by third-party service providers to confirm a specific transaction occurred and that you qualify for a promotional offer; for example, the date and amount of your purchase and the last four digits of your card number so that we can verify your purchase with our records.
We may contact you via email and other ways, including through publicly available notices, for Services-related purposes (welcome letter, security and legal notices, announcements, Website updates, reminders, suggestions, etc.). We may also use your data to enable you to communicate with the Experts.
Your contact data (including email, phone number, etc.) may also be used for gathering feedback. We may contact you to participate in research to improve the user experience of our product. The research will be used for internal purposes only, including:
- Feature development and product updates;
- Marketing activities;
- Support updates;
- Other service updates for improving your experience.
Having received the communications from us, you are always able to opt-out of such communications in each message, excluding legal notices or changes to user settings on the Website.
- Marketing and Promotion
We may process your personal data in order to analyze, personalize and improve our marketing practices unless our actions in this regard require your specific consent. We can also send you direct marketing emails and special offers unless our actions in this regard require your specific consent. But you may always opt-out of our marketing messages, using the mechanisms described under the respective link in each message and through the user settings.
- Analytics and Development
In order to establish new ways to improve the Website, find the points of interest in our Services and for the purposes of analytics, we monitor and analyze the personal data you provide us with, including information you provide upon the registration, the web traffic, cookies and usage data, such as the date and duration of your visit, your location, type of the device you used during your visit and other relevant data on the use of the Website.
The purpose of such analytics is to understand Customer engagement and satisfaction with certain features in order to improve the Customer experience, develop new useful features, and streamline our Services.
We may also carry out polls and surveys through the Website using external compliant services. You are not obliged to respond to them, and you may opt-out of such polls and surveys through user settings. In order to inform, optimize and serve you relevant advertising based on your past use of our Services, we may process your Customer data and cookies.
In case of any disputes on the Website, we may use data (including communications) to resolve such matters, supervise Customer and Expert behavior on the Website, and respond to any complaints or requests.
- Compliance with Legal Requirements
We process certain payment information to comply with applicable legal requirements in the field of finances and/or accounting. We also may process the data collected on the platform in connection with legal requests we receive from you or any other competent person and/or body, and we may use this information to exercise, defend and/or establish our legal rights.
- Fraud Prevention
Certain information, such as your log information, payment information, and your behavior on the Website are subject to our supervision to prevent fraudulent activities on the Website and assist you with your needs.
If the Website decides to change the purposes of processing specified above, we will inform you about such changes prior to the use of your personal data within the newly set purposes. The notification of such changes will be sent to your email, and you will have to provide your consent for the amended purposes unless the additional purpose of processing is compatible with those listed above.In case you do not want to provide us with the requested personal data for the purposes specified above, you may not have access to certain functions of the Services.
- Archival Purposes
We may archive your information in the event of a legal need to prove certain events (e.g., in the establishment, pursuit, or defense of claims), which is our legitimate interest.
- Responding to Contact Initiated by You
When you contact us (e.g., via contact forms, email, or chatbots), you may provide us with your contact info, which we may use to respond to you. Providing information about the Company is our legitimate interest.
- Combating Inappropriate Behavior and Promoting Safety
We examine information about the operation and use of our Website to verify Customers and accounts, enhance security and combat inappropriate behavior, spam, or fraud. In doing so, we ensure our Website is used in accordance with our Terms and Conditions and remains free of harmful and inappropriate content. Securing our Website and keeping it a safe place for our users is our legitimate interest.
- Aggregate/De-Identify/Anonymize Data
We may aggregate, de-identify, and/or anonymize any information collected through our Website and our services so that such information is no longer linked to your personally identifiable information (such as your name or email address). We may use aggregated and anonymized information for any purpose, including for research and marketing purposes, and we may also share such information with third parties at our discretion.
WHAT ARE THE LEGAL BASES FOR DATA PROCESSING?
As explained above, we use personal data in various ways depending on your use of our Website and/or participation in our services. We may process your personal data in reliance upon one or more of the following legal bases, depending on the circumstances:
- Processing is based on the consent you have given;
- Processing is necessary to provide our Services to you according to our Terms and Conditions;
- Processing is necessary for the purposes of our legitimate interests. Those legitimate interests are:
- Compliance with financial and accounting legislation;
- The assessment of the Company’s business efficiency by analyzing website traffic and financial performance indicators;
- Promotion of the Website through social media networks, media outlets, and affiliates, such as bloggers or influencers;
- Fraud prevention, ensuring the appropriate protection of personal data;
- Experts' verification.
- Where necessary, compliance with applicable legislation (e.g., data subject request processing);
- In exceptional cases, to protect your vital interests or vital interests of another person or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
In all cases, we will notify you about the applied legal basis for processing and other relevant details before we start the processing of your personal data on a specific legal basis unless we are not able to do so in accordance with our obligations under any applicable legislation.
WITH WHOM DOES THE COMPANY SHARE YOUR PERSONAL DATA
The Company never shares, sells, or transfers your personal information to outside parties. However, this does not include the third parties we cooperate with to run our Website and provide you with the Services or Products you order online. Please note that such cooperation is possible only if those parties also agree to never share, sell, or transfer any information about our customers and visitors that they receive from us.For example, we may share your personal data with the following parties:
We engage subcontractors to help process personal data. These may include hosting service providers, IT specialists and technicians managing our technical infrastructure, service providers that ensure the functionalities of our Website, claims adjusters (including insurers), advertising and marketing companies, accounting and bookkeeping offices, and legal advisors. All subcontractors process data under contracts with the Company and only in accordance with our instructions.
- Advertisers, Advertising Agencies, and Intermediaries
Based on the information contained in cookies or other online identifiers (if they contain personal data), advertisers, advertising agencies, and intermediaries participate in the process of selecting the content of advertisements that are displayed to you on our website.
- Payment Intermediaries
When you pay for Services, we will provide your payment data to our payment intermediaries.
- Legal Compliance and Protection of the Company and Others
- To comply with the legal process;
- To respond to claims that any content on our Website violates the rights of a third party;
- To respond to your requests for customer service;
- To protect the rights, property, or personal safety of the Company, our agents and associates, and the public. This includes exchanging information with other companies and organizations for fraud prevention, spam/malware prevention, and other similar purposes.
FOR HOW LONG DOES THE COMPANY STORE YOUR PERSONAL DATA
We retain your personal data for different periods of time depending on the purpose for which it is processed:
- In Order to Perform the Services
We store your data as long as you have a user account on our Website. If you delete your user account or if we have to delete your account (e.g., due to your violation of the Terms and Conditions of our Website or violation of the law), we will delete or anonymize your personal data. However, we may retain some data for a longer time to comply with legal, tax, and accounting requirements (e.g. until the expiration of statutory limitation periods for contractual claims or limitation periods for tax liabilities arising from the fact that you purchased our services) or if the data is necessary for ongoing or anticipated legal proceedings. We make every effort to limit the retained data to the necessary minimum and to retain it for no longer than required.
- On the Basis of a Legitimate Interest (Ours or that of a Third Party)
We keep it until you object to the processing or until we determine that the data is no longer relevant or we have already fulfilled our purpose for using it.
- As Required by Law
We use the data for the time in accordance with applicable laws.
- Based on Your Consent:
Until the earlier of (i) withdrawal of your consent or (ii) fulfillment of the purpose for which the data was collected.
YOUR RIGHTS AS DATA SUBJECT REGARDING YOUR PERSONAL DATA THE COMPANY PROCESSES
- Right of Confirmation
You can obtain confirmation from the Company as to whether personal data concerning you is being processed.
- Right of Access
You can access your personal data processed by the Company.
- Right to Rectification
You can ask the Company to have incomplete personal data requiring corrections completed.
- Right to Erasure (Right to Be Forgotten)
You can request the Company to erase personal data. In most cases, the Company will erase it unless otherwise required by legislation. To delete your personal data, you can:
- Contact us via chat. We will respond to your request to delete your information within five days and notify you of the outcome. In the request, you must state your full legal name, address, phone number, and email that you used to sign up to the website to identify your account. You must also provide a reason why you want your data deleted and list the information that you are specifically aware of as being processed and retained by the Company. If you wish for all the data to be deleted from the system, please state so in the official letter as well.
- Delete specific items from your account (such as your payment method, etc.).
- Delete your entire account.
- Right of Restriction of Processing
You can contest the accuracy of your personal data, or in case the Company is not interested in processing your personal data any longer, but you want the Company to do this for different reasons, for example, to bring a claim against somebody and, instead of the erasure of information, its processing will be restricted.
- Right to Data Portability
You can have your personal data transmitted directly from one controller to another, where technically feasible, and when doing so does not adversely affect the rights and freedoms of others.
- Right to Object to Processing of Your Personal Data by the Company
You can object to our processing of your personal data when the processing is related to the performance of our task carried in the public interest or the exercise of official authority vested in us. The other case is if we process your data for the purposes of the legitimate interests pursued by us or by a third party, and you believe that such interests are overridden by your interests or fundamental rights and freedoms. If you make a request with an objection to processing, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing.
- Right to Withdraw Consent at any Time by Contacting Us
- Right to Request a Copy of Your Personal Data
As a registered user, you can also check the data you have provided in your Account.
- Right to Request the Company to Correct Any Information About You
If you believe that it is incorrect, outdated, or incomplete, do not hesitate to contact us if you make a mistake during registration or when completing your user profile.We may ask you questions regarding your user account in an effort to verify your identity. We will make every effort to allow you to exercise your rights as soon as possible and no later than as required by applicable law. If we need to extend the processing period for your application in accordance with applicable law, we will inform you of the extension period and explain the reasons for the delay.Ensuring a high level of personal data protection is a priority for the Company.
- Additional Information for California Residents
- Exercising CCPA Rights
If you are a California resident, California law may permit you to request that we provide you with:
- The categories of Personal Information we have collected or disclosed about you in the last twelve months;
- The categories of sources of such information;
- The business or commercial purpose for collecting or selling your Personal Information; and
- The categories of third parties with whom we shared Personal Information.Access to and/or a copy of certain information we hold about you.
- An option to delete certain information we have about you.
Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide services to you. If you ask us to delete it, you may no longer be able to access or use our Website.
We reserve the right to verify your identity to our satisfaction before responding to your request, which may include, depending on the type of request you are making, the sensitivity of any data you are requesting, and the nature of your relationship with us: verifying your name, asking you to click on a link that we send to your email address, or requesting that you provide us with information about our relationship that only you are likely to have.
- Shine the Light Disclosure
California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
OTHER PRIVACY COMMITMENTS
- Cross-Border Transfers
We process your personal data both within the United States and outside the United States. Although countries where we process data may have different laws, we take measures to ensure high privacy compliance.
- Time for Reply and Reaction
The Company will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months if the Company is overwhelmed by the number of requests or the request at issue is complicated and requires a lot of action. The Company will inform you of any such extension within one month of receipt of the request, together with the reasons for such delay.
The Company takes technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage.
- Accessing Account to Provide Support
In exceptional circumstances, such as required customer support, our support specialists may need to access your account. When such an occasion occurs, they will be able to see the personal data submitted to your account.
We undertake to always ask for your permission to access your account before we start troubleshooting. Please note that if you do not want to grant your permission to access your account, it may affect the time and quality of the provision of customer support.
- Children’s Privacy
The privacy of children is one of our concerns. The Services are not intended for use by children under the age of 16 without the express permission of their parent or legal guardian.
If you are under the age of 16, you will need to get your parent’s/legal guardian’s permission before submitting any personal data to the Company. We may process the personal data of children under the age of 16, provided that data has been consensually provided by parents/legal guardians for the express purpose of using Services.
- Breach Notifications
If any of your personal data is in breach, we would inform you and the respective data protection agencies as to the accidents without undue delay if there are high risks of violation of your rights as the data subject. We would also do our best to minimize any such risks.
- “DoNotTrack” Requests
The Company does not share personal data with third parties for their direct marketing purposes. Also, our Services do not support “Do Not Track” requests.
PROVIDING DATA IS VOLUNTARY
Providing any personal data to the Company is entirely voluntary, which means you have no obligation to do it. However, providing personal data is necessary to create a user account and use our Website. If you do not provide the Company with your personal data, you will not be able to use all of the features on our Website.
Personal data controller
Devellux Inc, incorporated under the laws of Delaware, the USA, located at 8 THE GREEN, STE A, DOVER, Kent, DE, 19901, the USA will be the controller of your personal data.
UPDATING THIS POLICY
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