PRIVACY POLICY and CONSENT ON PROCESSING OF PERSONAL DATA
Privacy policy
Last updated as of 09/02/2023
We at career.dev.pro (“we,” “us,” or “our”) respect your privacy and therefore aim to equip you with the best understanding of our privacy practices and assure you that your data will remain secure. This Privacy Policy (“Policy”) describes, among other things, the categories of personal data we collect, how we use it, and which rights you have with respect to your personal data.
Please read this Policy carefully. This Policy applies to you when you visit our website at: [career.dev.pro] (“Site”) and subdomains in order to simply surf the Site or contact us by email at privacy@dev.pro.
Who Are We?
We are Dev.Pro, registered at 7260 W. Azure Dr Suite 140-829 Las Vegas, NV 89130 USA. You can contact us by post at the above address, by email at privacy@dev.pro or by telephone on 1-310-362-0206.
Inquiries about our use of your personal data should be addressed to the contact details above.
Definitions
We use the following definitions in this Policy:
“Customer” shall mean a person, an individual entrepreneur or legal entity who signs up to the Site to send a CV or/and receive other Services.
“Specialist” shall mean a person who is a specialist in a certain area.
“Visitor” shall mean a person who simply surfs the Site.
“Vacancy” shall mean an announcement on the search for service providers to participate in the Customer’s project, which contains requirements to a Specialist.
“Account” shall mean a unique account registered by you to enable access and use of the Site and its Services.
“Services” shall mean providing access to the functionality of the Site such as:
- getting acquainted with the Site content that is available without signing up;
- creating a Customer account;
- registration for events;
- getting access to materials published on the Site.
“data controller” shall mean the natural or legal person who (either alone or jointly with others) determines the purposes and means of the processing of personal data.
“data processor” shall mean the natural or legal person who processes personal data on behalf of the data controller.
“data subject” shall mean any living individual who uses our Site.
“personal data” shall mean any information relating to you and helping identify you (directly or indirectly) such as your name, last name, email, location data, etc.
“processing” shall mean any operation or set of operations which is performed on personal data or on sets of 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.
“third party” shall mean a natural or legal person, public authority, agency or body other than the data subject, data controller, data processor and persons who, under the direct authority of the data controller or data processor, are authorized to process personal data.
General
We act as a data controller in relation to the personal data you provide to us while using the Site.
When you submit the personal data through our Site, we may ask for your consent to some kind of processing of the personal data you provide, as described in this Policy, to enable us to provide you with the requested information or services, if no other legal ground can be used.
We do not aim to and do not knowingly collect nor process data of persons under the age of 16 without consent given or authorised by the holder of parental responsibility over the child. If we become aware that we have inadvertently collected data of persons under the age of 16 without consent given or authorised by the holder of parental responsibility over the child, we will take reasonable steps to delete it as soon as possible, unless we obtain the parental or legal guardian’s permission. If you are a parent or legal guardian and you learn that your child is using our Site and you do not want it to, please contact us by email at privacy@dev.pro.
What Personal Data Do We Collect, and How?
We collect personal data you provide to us directly, such as the information you enter yourself, and personal data we obtain automatically, such as information about your device and what parts of our Site you interact with.
We use your personal data collected through the Site only for the purposes listed in this Policy. We may share your personal data with third parties solely as defined herein. We do not use automated decision-making and profiling.
We collect the following data from the Customer:
| Type of Personal Data | Purposes | Legal basis |
|---|---|---|
|
| Your consent |
| To record the processing activities under Art. 30 of the General Data Protection Regulation (the “GDPR”) and comply with other applicable laws | Legal obligation | |
| To respond to your questions and requests submitted to us via the means of communication available on the Site | Your consent |
| To record the processing activities under Art. 30 of the GDPR and comply with other applicable laws | Legal obligation | |
| To help us develop and improve the functionality of the Site. | Your consent |
| To ensure the functionality of the Site and to prevent any fraudulent actions or intervention of the malware | Our legitimate interest | |
| To record the processing activities under Art. 30 of the GDPR and comply with other applicable laws | Legal obligation |
We collect the following data of the Visitors:
- Automatically created data (as defined above);
- Message information (as defined above) in case such Visitors contact us.
We aim to minimize the data we collect about you to the extent strictly necessary to enable you to use our Site or provide you with special features when you give us your consent.
Cookies and Access
When you visit our website some data listed above (namely, identifiers and usage data) is collected by us using cookies and other tracking technologies.
Cookies are small pieces of data that websites send to your browser. They are stored on your device, which might be a personal computer, a mobile phone, a tablet or any other device. Cookies help us enhance your user experience and remember your choices and other information, namely as follows:
- to recognize your device and settings;
- to define you as a unique user to personalize your user experience (e.g. keep the language preference);
- to store your preferences and settings;
- to analyse your usage of the Site to improve our Site and services;
- to ensure the functionality of the Site;
- to prevent fraud;
- for marketing purposes.
We use the following types of cookies:
- essential cookies;
- marketing cookies (analytics);
- marketing cookies (advertisement targeting).
You may opt-out the cookies
If you still don’t want your behavior to be tracked, you may disable cookies in your browser through the browser settings. You can also install the Google Analytics opt-out in your browser to prohibit Google Analytics JavaScript from sending information to Google Analytics.
However, some website and app features or services may not function properly without cookies, and you will need to reset your preferences each time you log in. Please follow the links to further educate yourself on how to manage cookies: Chrome, Firefox, Edge, Internet Explorer, Safari.
Why Do We Collect This Information?
We will use your information to communicate with you in relation to your inquiry. We will also send you service-related communication via email and we may use your telephone number to contact you regarding your account. If you are not our client, but you give us your consent, we may contact you occasionally to provide you with information about our services in the long term, unless you retract that consent.
The legal basis for the processing of your personal data is:
- Your consent to process data for a specific purpose, such as an inquiry or a consent to provide you with information about our services
- Legal obligations to which we are subject
- Our legitimate interest to promote our business is balanced with your right to privacy.
We may use cookies to remember your preferences when you have visited our Site and pages you like to regularly visit and to ensure that you receive the most up-to-date information that is relevant to you and your experience with us. Also we need some data to enable our Site to run smoothly and give you a pleasant user experience. We also use cookies for internal management purposes of our website.
Our website access logs are only collected for tracking visits to our Site for statistical and performance optimization purposes and to assist should any visitor, including you, not be able to access websites. We process your personal data to prevent any fraudulent actions or security threats and to provide you with the desired information and services.
We do not use the information you provide to make any automated decisions that might affect you.
We process your personal data to fulfill the applicable legal obligations arising mainly from the GDPR or national law. If you send us the request to fulfill your rights, we may ask you for some personal data we already have to identify you and achieve compliance with the applicable law.
Where Do We Keep Your Information and What Security Measures Are in Place?
Your personal information is stored in our online processing system and company information systems that are based within the US and Ukraine.
We use industry-standard data security, technical and organizational measures to protect your data. Along with providing a safe work environment, we use an encryption procedure to prevent misuse of data by third parties. Our data security is in accordance with current technology. We make every reasonable effort to protect your personal information.
Recipients of Data. Data Sharing and Disclosure
We may share your personal data with our contractors, third-party service providers and other third parties. We always sign data processing agreements (DPAs) and Non-Disclosure Agreements (NDAs) with our third parties.
01 Within Dev.Pro
Your data will be shared with the appropriate contractors within Dev.Pro who need to access your data for the reasons of processing highlighted above. Appropriate agreements are in place with these contractors as requested by applicable laws such as the GDPR in order to ensure the security, confidentiality, and protection of your rights over your data.
02 Service Providers
We may disclose your data to selected third-party vendors, service providers, contractors or agents who perform functions on our behalf, such as website management, hosting, technical support, and marketing analytics who treat the data protectively by having their own privacy policies in place. They will have access to your personal data to the extent necessary to perform their function, but they are prohibited from using your information for other purposes unless you have specifically given them consent to do so.
Those service providers include, but are not limited, to:
- Content Management Systems (CMS) as necessary to serve website content
- Email and marketing automation provider as necessary for sending emails to our users
- Customer Relationship Management (CRM) platform as necessary for sales lead tracking
- Providers of research and analytics services, including Google Analytics (Google LLC, USA)
- Providers of Cloud computing infrastructure services
- Internet service providers
- Professional services providers necessary for technical support
We may share and disclose your personal data to other data controllers:
- Google Ads (Google LLC, USA): to deliver relevant online advertising to you on search results or other websites. You may familiarize yourself with Google privacy policy here.
International Transfers
We process your personal data within our company premises based in the USA and Ukraine, both of which are outside of the European Economic Area. We may also process your personal data in other countries if the appropriate safeguards were put in place as determined under Article 46 of the GDPR and if such countries are not subject to Article 45 of the GDPR on the adequate level of data protection.
The appropriate safeguard steps include implementing the Standard Contractual Clauses (SCC) approved by the European Commission. We put supplementary measures in place when transferring data outside the EU and the EEA, where appropriate.
In specific situations when we may not rely on the Articles 45 and 46 of the GDPR, we may transfer your personal data under Article 49 of the GDPR on the derogations for specific situations, namely:
- your consent;
- performance of the contract to which you and we are parties or you asked us to take steps to enter into an agreement;
- protection of your vital interests, if applicable.
Disclosure of personal data to other data controllers and/or data processors will be done in accordance with the applicable personal data laws and regulations.
How Long Do We Keep Your Information For?
We will only store and process your personal data for a reasonable period of time, which is based on the purpose for which we are using your data. Once that purpose has been fulfilled, we will securely delete or anonymize your data (so that we or anyone else, can no longer identify you based on it) unless we are required to retain the data longer to comply with our legal obligations or as expressly permitted by law. However, we may not delete or anonymize your data if we are compelled to keep it under Article 30 of the GDPR and (or) other applicable law.
We cannot foresee the precise amount of time we need to process your personal data. However, we write down the pointers and criteria to help you envisage the retention period:
| Method of collection | Retention Period |
|---|---|
| Contact information | As long as your Account is active, unless longer storage is required or expressly permitted by law. |
| Message information | As long as our message communication is active and for two further years after the last message was sent |
| Automatically created data | Up to 1 year |
You may request to delete your personal data by sending us a request via email at privacy.@dev.pro.
We have implemented appropriate organizational, technical, administrative, and physical security measures that are designed to protect your personal data from unauthorized access, disclosure, use, and modification. We regularly review our security procedures and policies to consider appropriate new technology and methods.
Your Rights Regarding Your Personal Data
You may enjoy the rights with respect to your personal data by submitting your request via privacy.@dev.pro.
When we act as a data processor with respect to a particular processing of personal data, you may exercise your rights under the GDPR in respect of and against a data controller of such personal data.
Please be aware that in some cases we may ask you to provide us with additional information in order to verify your identity and proceed with your request.
- Right of access. You may ask us to provide you with a copy of your personal data collected, along with information regarding the nature, processing and disclosure of that personal data.
- Right to rectification. You may ask us to update, correct or supplement the false, missing or incomplete personal data.
- Right to erasure (“right to be forgotten”). You may ask us to delete your personal data collected, except for the cases it is prohibited by appropriate laws.
- Right to restriction of processing. You may ask us to restrict further processing where: (1) your personal data is not correct or outdated; (2) the processing is unlawful.
- Right to data portability. You may ask us to transfer a copy of your personal data to another organization or to you.
- Right to object. Where the processing of your personal data is based on the necessity for the performance of a task carried out in the public interest or of our legitimate interests, or for direct marketing purposes, you may raise objections to such processing on grounds relating to your particular situation. This also applies to profiling based on these provisions, if any.
- Right to withdrawal of consent. You may withdraw the consent when your personal data is processed upon it.
- Right to lodge a complaint. You may lodge a complaint with the supervisory data protection authority pertaining to the processing of your personal data.
Please keep in mind that you can always withdraw your consent to process your personal data for marketing purposes by leaving us a clear note at privacy.@dev.pro at any time, or by clicking the Unsubscribe button at the footer of any email received from us.
Please also note that if you withdraw your consent for direct marketing by clicking the Unsubscribe button, we will not delete the rest of your data automatically but you may request that we do so by sending an email to the address above. Please remember that the withdrawal of consent does NOT automatically mean that the processing before the withdrawal is considered unlawful.
If you have a concern about our use of your information, you can contact your local data protection regulator, if you have one. A list of European data protection regulators can be found here.
Changes to the Privacy Policy
We may update or amend this Policy from time to time due to the implementation of new technologies, in accordance with best practices in our industry, law requirements or for other purposes. We will send a notice to you if these changes are major and we will obtain your consent where required by applicable laws. Such notification may be provided via your email address or announcement on the Site and/or by other means, consistent with applicable law.
In any case, we encourage you to regularly review this Policy to check for any changes.
Consent on Processing of Personal Data
I, as a subject of personal data (hereinafter referred to as “Subject”), registering on the site career.dev.pro and providing information about myself in the CV, under the conditions set out below, provide the company TravelConfirm, Inc. d/b/a Dev.Pro, a Nevada Corporation (hereinafter referred to as “Dev.Pro”), with location 7260 W. Azure Dr Suite 140-829, Las Vegas, NV 89130 (data controller) voluntary and informed permission to process (collect, register, store, use, etc.) my personal data and personal information provided by me in the CV, or specified during registration on the site career.dev.pro, as well as provide voluntary and informed permission to distribute (sell, transfer, etc.) my personal data and personal information to representatives and contractors of the data controller.
The purpose of personal data processing:
- Taking actions aimed at establishing business relationship with the Subject, in particular, but not limited to: determining the compliance of the Subject`s qualifications with the requirements established by the data controller and/or its contractors/representatives; sending invitations to the Subject to participate in negotiations on cooperation; sending test tasks (its results) to the Subject in order to assess the level of qualification training; sending the results of negotiations conducted with the Subject; preparation and conclusion of economic and legal agreements; entering information about the Subject in the database of potential Dev.Pro`s counterparties, etc.
- Carrying out marketing research: sending to the Subject advertising and/or information materials concerning special offers, events of the data controller and its contractors/representatives; study of demand, informing the Subject about new products, services of the data controller and its contractors/representatives, etc.
- Protection of information of the data controller and third parties: conducting a detailed verification of the Subject’s identity, if required by the terms of the business agreement, in particular, obtaining information from the Subject about no criminal record, in order to provide access to confidential information of the data controller and/or its contractors/representatives.
- Security: protection of the website career.dev.pro in order to prevent fraud, protection of intellectual property rights of the data controller, protection of personal data of the data controller and third parties; ensuring security while visiting the offices of the data controller and ust contractors/representatives and events they conduct; investigate any crimes, misdemeanors, accidents, etc.
Composition and content of the collected personal data and personal information of the Subject:
- Basic identification information about the Subject: name, surname, patronymic, sex, date of birth, passport data, identification number, citizenship, data on the presence / absence of a criminal record, photos of the Subject, recordings from video surveillance cameras (video recordings) , place of residence (including actual), etc.
- Contact information about the Subject: telephone number, e-mail, contacts in chats and other electronic resources (including Skype, Facebook, LinkedIn, etc.), information posted on social networks to which the Subject provided access , cookies, etc.
- Information on the Subject’s work experience: entered in the Subject’s employment record book (names of employers and their officials, positions held, periods of work, grounds for termination of employment contracts, information on incentives and rewards, periods of registration in employment centers, etc.), entered in the Certificate of State Registration of an Individual Entrepreneur, information on concluded (including termination) civil and business agreements (names of contractors, projects, responsibilities of the Subject under the agreements, validity period, scope of work performed/services provided, contact information regarding contractors (telephone numbers, location addresses, e-mail, data on officials, etc.), copies of relevant documents; any other information provided by the Subject regarding the terms of cooperation with the data controller and/or its contractors/representatives, etc.
- Information on the qualification and education of the Subject: information on education (including all information contained in educational documents, such as the name and address of the educational or scientific institution, details of the document on education (type, series, number, date issuance), period, type and form of study, date of graduation, faculty, qualification, direction and specialty), level of foreign language proficiency, information on certification, advanced training and retraining, details of supporting documents on scientific works and inventions, professional certificates, information on participation in professional associations, information on academic title and degree, etc.
- Other information provided by the Subject voluntarily and specified in the CV, copies of documents provided by the Subject, etc.
Personal data processing period:
- The processing of personal data is carried out throughout the period of consideration of the Subject’s application, as well as after the decision to refuse – in order to include Subject’s personal data in the database of potential contractors, but not longer than one year, unless there are other legal grounds for extending the term. The term for processing videos is 90 (ninety) calendar days from the date of receipt of this consent. The processing time may be shorter if a letter of withdrawal of consent is received from the Subject.
Subject`s rights:
- Subject confirms that prior to the signing of this consent, he/she was acquainted with the rights of the personal data subject, namely:
- to know about the sources of collection, location of my personal data, the purpose of their processing, location or place of residence of the data controller or to give an appropriate order to obtain this information to authorized persons, except as provided by law;
- to receive no later than thirty calendar days from the date of receipt of the request, except as provided by law, an answer as to whether my personal data is processed;
- to make a request to the data controller with an objection to the processing of my personal data;
- to make a request to change or destroy my personal data by any controller of personal data, if this data is processed illegally or is inaccurate;
- to protect my personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, non-provision or untimely provision, as well as to protect against the provision of information that is inaccurate or discredits my honor, dignity and my business reputation;
- to complain about the processing of my personal data to the Commissioner for Human Rights or to the court;
- to apply legal remedies in case of violation of the legislation on personal data protection;
- to make reservations regarding the restriction of the right to the processing of my personal data during the consent;
- to withdraw consent to the processing of personal data;
- to know the mechanism of automatic processing of personal data;
- to protect against an automated decision that has legal consequences for me.
Procedure for access to personal data of third parties:
- The data controller and/or its contractors/representatives have the right to disclose personal data of the Subject to the following categories of third parties:
- to clients of the data controller (including potential ones) – by providing access to the documents of the Subject (in particular, CV, certificate of presence/absence of criminal record), as well as to videos of negotiations on cooperation with the Subject – for business involvement and in order to confirm the qualification of the Subject directly by the client;
- legal entities and individual entrepreneurs with whom data controller has concluded business agreements – for internal corporate accounting of Subjects-potential contractors, inclusion of information in the personal database of the data controller – by providing access to documents provided by the Subject, e-mail correspondence, and also video recordings of negotiations on cooperation with the Subject;
- self-employed persons, accounting and legal agencies, auditors, recruiting agencies, security services providers, regulatory and law enforcement agencies, etc. – by providing access to information and documents, within the limits necessary for the data controller to perform personal data and/or its contractors/representatives of contractual obligations to the Subject, or in cases provided by applicable law.
Actions with personal data:
- By this consent the Subject gives voluntary and unconditional consent to the data controller and its contractors/representatives to automated, non-automated and mixed processing of personal data in paper and electronic form by:
- collection and registration of personal data, including selection and organization of information about the Subject, obtaining information about the Subject from any sources;
- accumulation of personal data by combining and systematizing information about the Subject or entering this data into the personal data base;
- storage (including on servers), adaptation, changes, updating of personal data;
- using and dissemination (distribution, sale, transfer) of personal data;
- depersonalization, destruction of personal data, including with the use of information (automated) systems.
Final provisions:
- By signing this consent the Subject acknowledges receipt of a notice of inclusion of information about himself/herself in the personal database of the Dev.Pro company, for the purpose of its processing, storage and use for the purposes provided by the legislation.
- In case of questions about personal information about the Subject, in order to exercise their rights, in particular, update information about the Subject, withdraw consent to the processing of personal data, send complaints, etc.,the Subject has the opportunity to contact the data controller by sending appropriate email to privacy@dev.pro. Destruction of personal data of the Subject in case of withdrawal of consent is carried out not later than the next business day from the moment of receipt of the relevant letter.
- The Subject is notified and gives its unconditional voluntary consent to the possible receipt by the data controller and its contractors/representatives of personal data about the Subject from third parties, in particular from former employees, other individuals, legal entities, former employers and clients, contractors, state and law enforcement agencies, organizations, institutions, by sending a request to these persons, as well as through the Internet.
The Subject is warned that the refusal to provide such consent may result in the termination of negotiations on cooperation, giving preference to other potential counterparties.
- Recognition of certain provisions of this consent as invalid or inconsistent with the law does not entail recognition of this consent as a whole as invalid.
- This consent, in accordance with applicable law, is given by the Subject during registration on the site career.dev.pro by marking the permission to process his/her personal data after reviewing its content. The career.dev.pro site, which is owned by the data controller, does not create opportunities for the processing of personal data about the Subject until it is marked accordingly.
- This consent shall take effect from the moment of its signing by the Subject and shall be valid until the expiration of the term of personal data processing or until the moment of its withdrawal by the Subject, whichever is the earlier.
Contact Us
If you have any privacy-related questions or unresolved issues, please do not hesitate to contact us by email at privacy@dev.pro.