Privacy Policy

When you use these services, you’ll share some information with us. So we want to be upfront about the information we collect, how we use it, how it’s shared, and the controls you have.

Unless you opt-out, we may retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

There are three basic categories of information we collect:

  • Information you provide.
  • Information we get from third parties.
  • Information we get when you use our services.

‍

‍

1. INFORMATION YOU PROVIDE

When you interact with our services, we collect information that you provide to us. For example, our services require you to set up an account, so we’ll need to collect a few important details about you, such as your name, username, password, email address, order details, billing information. We may also ask you to provide us with some additional information.

Please note that we don’t process all your billing information but we might need the first 6 digits and last 4 digits of your card to identify you between various customers for the transaction.

2. INFORMATION WE GET FROM THIRD PARTIES

We may collect information about you from third parties. We may receive information from third parties, including website publishers, social network providers, law enforcement, and others

3. INFORMATION WE GET WHEN YOU USE OUR SERVICES

Usage information. We collect information about your activity through our services. For example, we may collect information about how you interact with our services.

Cookies and other similar technologies. Like most online services and mobile applications, we may use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device. We may also use these technologies to collect information when you interact with services we offer through one of our partners, such as advertising and commerce features.

Log information. We may also collect log information when you use our Site, such as: details about how you’ve used our services; device information, such as your web browser type and language; access times; pages viewed; IP address; identifiers associated with cookies or other technologies that may uniquely identify your device or browser; and pages you visited before or after navigating to our Site.

Posting of information. We process personal data you freely submitted. This may be a survey you fill in or feedback you provide.

4. HOW WE USE YOUR INFORMATION

What do we do with the information we collect? The short answer is: provide you with products and services that we relentlessly improve. 

Provision of services. We process your personal data to fulfill our obligations under the Terms and Conditions. Specifically, we use your personal data to help the Experts find your account in order to provide you the Services.

Communications. We may contact you for Services-related purposes (welcome letter, security and legal notices, announcements, updates, reminders, suggestions, etc.). We may also use your data to enable you to communicate with the Experts.

‍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 Site, 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 Site.

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 Site 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.

Support. In case of any disputes on the Site, we may use data (including communications) to resolve such matters, supervise Customer and Expert behavior on the Site, and respond to any complaints or requests.

Compliance. 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 Site are subject to our supervision to prevent fraudulent activities on the Site and assist you with your needs.

Changes. If the Site 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.

5. HOW WE SHARE YOUR INFORMATION

Why do we share the information we collect? Most of the time, it’s because you ask us to. Sometimes we share it because we need to. Here are the ways we may share information about you:

‍Subcontractors. 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 Site, 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. 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 Site.

Payment intermediaries. When you pay for Services, we will provide your payment data to our payment intermediaries.

Non-personal information. We may also share with third parties that provide services to us or perform business purposes for us aggregated, non-personally identifiable, or de-identified information.

6. HOW LONG WE KEEP YOUR INFORMATION

We retain your personal information 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 Site. 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 Site 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. 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.

7. 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. 

‍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. After we receive a withdrawal request from you, we will process it in a timely manner, and we will no longer process your personal data unless otherwise set by law.

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, please contact us. 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.

8. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

The California Consumer Protection Act (the “CCPA”) requires us to provide California residents with some additional information regarding how we collect, use and share personal information. This Section 13(B)(i) only applies to “Personal Information” of California residents, as that term is defined in the CCPA, and it supplements the information in the rest of this Privacy Policy above. Data about individuals who are not residents of California may be handled differently and is not subject to the same rights described in this Section. This Section applies only to the extent required by the CCPA, so some personal information about Californians is not covered by this Section.

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 Site.

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.

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.

9. INTERNATIONAL DATA TRANSFERS

We may collect your personal information from, transfer it to, and store and process it in different countries. Whenever we share information outside of where you live, when we are legally required to do so, we make sure an adequate transfer mechanism is in place. We also make sure any third parties we share information with have an adequate transfer mechanism in place, as well.

10. SECURITY

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.

11. 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.

12. 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.

13. “DO NOT TRACK” 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.

14. PERSONAL DATA CONTROLLER

Develux Limited, 8/F., China Hong Kong Tower, 8-12 Hennessy Road, Wan Chai, Hong Kong will be the controller of your personal data.

15. UPDATING THIS POLICY

We may update this Privacy Policy from time to time. We will post the changes or information about them on our Site.

16. CONTACT US

Please also feel free to contact us if you have any questions about this Policy:

hk.support@develux.com 

Updated: Jan 18, 2024