PRIVACY POLICY
Definitions
In the interest of clarity and precision, we use the following definitions throughout this Privacy Policy:
Privacy Policy: This Policy as fulfillment of our information obligations to you under Articles 13 and 14 of the GDPR.
Data: Personal data, i.e., any information about an identified or identifiable person to whom the Data relates. Concerning the above-mentioned individual, the obligation to provide information is fulfilled by making the information contained in the Privacy Policy available on an ongoing basis.
You: You, and therefore the person whose Data we process in accordance with the Privacy Policy.
We/Controller: TravelConfirm, Inc. d/b/a Dev.Pro, registered at 7260 W. Azure Dr Suite 140-829 Las Vegas, NV 89130 USA. You can contact us by post at the address above, emailing contact@dev.pro, or calling 1-310-362-0206.
Inquiries about personal data use of your data should be addressed to the contact details above or privacy@dev.pro.
GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of data and the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
Customer: An entity with whom the Controller has entered into or is negotiating an agreement under which the Controller will provide it with its services.
Potential Customer: An entity that may be interested in our services and is approached by our marketing team to provide information regarding our services and process.
Representative: A person who contacts the Controller on behalf of the Customer or Potential Customer or another entity with whom the Controller cooperates or communicates.
Data and effects of refusal to provide data
This Policy applies to the processing of Data collected from:
- Customers (if they are natural persons) or their Representatives in connection with the services we provide, such as entering into a contract or during the performance of a contracted project. [In this context, providing Data may be a condition of entering into a contract, and a failure to do so may prevent the performance of the contract.]
- Potential Customers (if they are natural persons) or their Representatives in connection with marketing activities which may result in collecting data from publicly available and legitimate sources. [If you don’t wish to be approached by us, please object.]
- People contacting Us, in particular by telephone, e-mail, or the contact form at Dev.Pro. [Failure to provide data may result in not receiving a response to the message.]
- People accessing the website https://dev.pro Data may be collected via cookies. [Consent for cookies is voluntary.] For information regarding Cookies Policy, please check https://dev.pro/cookies-policy/.
Categories of Data
- a) name
- b) email addresses
- c) telephone number
- d) social media account and data disclosed there
- e) occupation
- f) job title
- g) country
Purposes, legal basis and duration of processing of Data
We process your personal data for the purposes set out below. For each purpose, we specified the legal basis for the processing and the criteria for the duration of processing for that purpose.
| PURPOSE | LEGAL BASIS | PROCESSING PERIOD CRITERIA |
| Processing data to provide services and ongoing contact with Customers. Providing resources and services to Customers | Article 6 (1) (b) (f) of the GDPR – conducting a binding contract and legitimate interest of the Controller, which is the delivery of resources and services to Customers as well as providing communication. | Until the termination of cooperation with a given Customer and the statute of limitations for claims. |
| Direct marketing | Article 6 (1) (a) (f) of the GDPR – consent for marketing activities or prior to consent legitimate interest of the Controller, which is a right to develop business opportunities which do not overdrive data subjects rights and freedoms. | One year since collecting data unless the data subject withdraws consent or object to processing or there is another legal ground for the processing. |
| Website usage statistics. Analysis of website utilization statistics | Article 6 (1) (a) (f) of the GDPR – the consent for analytical and third-party cookies or legitimate interest for necessary (functional) cookies – which are necessary for the proper functioning of our website and systems and enable you to navigate our website and use its features. | The cookies we use are installed for varying periods. Some expire when you close your browser, while others remain active for days, months, or even years, primarily so that your choices are not lost. After this period, they are deleted. |
| Administration of concluded contracts with service providers and clients. Protection of Controller’s rights and enforcement of claims | Article 6 (1) (f) of the GDPR – legitimate interest of the Controller. The legitimate interest of the Controller, in this case, is the proper implementation of contracts concluded with service providers or customers, as well as the defense of rights and enforcement of claims of the Controller. | Until the statute of limitations on claims. |
We only process Data for as long as it is necessary. Once the data has fulfilled the purpose for which it was processed, it will be deleted or anonymized, unless we are required or authorized by law to retain some or all of it.
Data recipients
In some situations, we transfer your Data to third parties. Their recipients may be:
- Entities to whom we outsource Data processing services will include our contractors, accounting entities, law firms, hosting, CRM, tools, and other entities necessary to fulfill our obligations;
- Public authorities, including the Police, the National Tax Administration, and other law enforcement agencies, in connection with their proceedings under the relevant provisions of law.
We ensure that our processors are fulfilling all obligations and requirements stemming from art. 28 GDPR.
Cross border
While Dev.Pro is a company with its headquarters in the US Information we collect from You and on Your behalf will be processed in the United States. Dev.Pro ensures that has been implemented along with SCCs adequate safeguards. Data processed for marketing purposes to the US we will ask for your explicit consent.
Your rights
● Access
You have a right to be informed about your personal data processing, including the source of your data collection, the purpose of its processing, and how long it will be stored;
● Rectification
You have a right to access and change your personal data;
● Erasure (“right to be forgotten”)
You have a right to demand to erase your data. However, we reserve the right to refuse permanent deletion for a legitimate reason, in particular, but not limited to unfinished current business affairs;
● Restriction on processing
You have a right to demand ceasing processing of your data or restrict its processing with respect to the exceptions set forth in the art. 18 GDPR;
● Portability
If you need to export/import data, we will help you;
● Right to withdraw consent
You can always withdraw your consent for processing your data for marketing by sending us an email;
- Right to object
In case you don’t want us to reach out for your consent for further processing, please object by sending us an email;
● Lodge a complaint
You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal data.
Automated Decision Making
We do not make decisions by automated means, including profiling.
Information Update
This Privacy Policy is up-to-date information about the processing of your personal data. Its content may change to be consistent with the facts regarding our processing of your Data.
Dev.Pro Team
Updated 12/8/2022