Privacy Policy
For DEVAID LIMITED (“the Company” or “the Controller”), a company registered in Cyprus on 28/08/2014 as a Limited Company. The Company’s Registration Number, as held by the Cyprus Registrar of Companies, is HE335309, personal data protection is of utmost importance. Data processing is conducted lawfully, fairly, and transparently, ensuring adequate data security, including protection against unauthorized or unlawful processing, and against accidental loss, destruction, or damage. The staff at the Company strictly adheres to legal requirements regarding data protection and ensures that all processing operations are carried out solely in your best interests.
This commitment to confidentiality explains all aspects of personal data processing and ensures compliance with all processing principles established by the relevant Cyprus data protection laws and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”)
The company is not responsible for the privacy policy practices of any third party accessible via links, regardless of their nature, outside of this website.
For any processing carried out entirely or partly by automated means, as well as processing by means other than automated for personal data that are part of, or intended to be part of, a data record system, we assure you that your data are:
• processed lawfully, fairly, and transparently;
• collected for specified, explicit, and legitimate purposes and not further processed in a way incompatible with those purposes; further processing for public interest archiving, scientific or historical research, or statistical purposes is not considered incompatible with the initial purposes;
• adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
• accurate and, where necessary, kept up-to-date; we will take all necessary measures to ensure that inaccurate personal data, considering the purposes for which they are processed, are erased or rectified without delay;
• retained in a form that allows your identification for no longer than is necessary for fulfilling the purposes for which the data are processed; personal data will be stored for longer periods only to the extent they will be processed solely for public interest archiving, scientific or historical research, or statistical purposes;
• processed in a manner that ensures adequate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, by taking appropriate technical or organizational measures.
Our services are dynamic, and we frequently introduce new features, which may require the collection of additional information. If we collect personal data with material differences or make significant changes to how we use your data, we will notify you and may update this Privacy Policy accordingly.
The Company’s website uses cookies or similar technologies to ensure the best user experience, analyze trends, administer the website, track user activities within the site, and gather demographic information about our user base as a whole. Cookies are small text files placed on your device to track usage patterns and record preferences. Our cookies do not contain personally identifiable information. Certain information is collected automatically through cookies and tracking technologies, such as Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, the pages viewed on our site (e.g., HTML pages, graphics), operating system, date/time stamp, and/or clickstream data. This data is used to analyze trends in aggregate and manage the website.
Website users can control the use of cookies at the browser level, but disabling cookies may limit certain features and functionalities on our website and services. For more information, please see our Cookie Policy.
This Privacy Policy applies to various categories of individuals (Data Subjects) whose personal data may be processed by the Company. Below are the defined categories:
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Data Subject
Under the GDPR, a Data Subject refers to any identified or identifiable natural person whose personal data is processed by a controller or processor. An identifiable natural person is one who can be identified, directly or indirectly, by reference to identifiers such as a name, an identification number, location data, or online identifiers, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
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Website Visitor
A Website Visitor is an individual who browses or surfs the Company’s website without actively engaging in any form of communication or providing personal data beyond what is automatically collected via cookies or similar technologies. These individuals interact passively with the website and do not submit forms or contact the Company.
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Candidates
Candidates are individuals who, after visiting the Company’s website, actively engage by completing forms, contacting the Company, or sending emails. They provide personal data with the intention of pursuing employment or contractor opportunities with the Company’s clients. These individuals are considered for potential job placements or other recruitment services facilitated by the Company.
This Privacy Policy applies to all the aforementioned categories of individuals in the context of the relationship established between the Company and each Data Subject. Specifically:
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For Website Visitors: The Policy governs the automatic collection and use of data via cookies and similar technologies during their browsing session.
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For Candidates: The Policy covers the collection, processing, and sharing of personal data provided to the Company for recruitment purposes, ensuring compliance with GDPR and other applicable data protection laws.
In general, all individuals described above—whether Website Visitors, Candidates, or otherwise — will be collectively referred to as Data Subjects throughout this Privacy Policy. This ensures consistent reference and clarity regarding their rights and the Company’s obligations under GDPR.
Retention of Personal Data
Your personal data will be retained in a form that allows identification for no longer than necessary to fulfill the purposes for which it was processed. In the context of the Company’s recruitment activities, personal data of data subject may be retained for longer periods if required for compliance with legal obligations, ongoing recruitment processes, or as necessary for the establishment, exercise, or defense of legal claims.
PURPOSE OF PROCESSING PERSONAL DATA
The main purpose of processing your personal data is to enable you to benefit from our recruitment services, which connect job seekers with companies seeking to hire or contract personnel. This ensures a seamless and efficient relationship while complying with legal obligations, addressing disputes, and upholding our contractual agreements.
The Company collects personal data on its website, http://www.developmentpeople.com, only with the Client’s consent, for the following purposes:
DevelopmentPeople collects personal data on the website pages at http://www.developmentpeople.com only with the Client's consent, for the following purposes:
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Direct marketing: Electronic newsletters, surveys, advertising, promotional lotteries;
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Marketing and promotion: Communication via media channels and social networks;
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Research and statistical purposes;
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Sending communications, evaluating online behavior, testing, development, and usage;
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Creating Candidates records and maintaining databases.
The Data Subject may withdraw their consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
If the Company intends to process personal data for a purpose other than that for which it was collected, the Data Subject will be informed in advance of the new purpose and provided with any relevant additional information, including:
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The period for which personal data will be stored or the criteria used to determine this period;
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The existence of rights to request access to, rectification, or erasure of personal data, or restriction of its processing, as well as the right to object to processing and data portability;
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Where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal;
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The right to lodge a complaint with a supervisory authority;
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Whether the provision of personal data is a legal or contractual requirement or necessary for entering into a contract, and the consequences of not providing such data;
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The existence of automated decision-making, including profiling, and relevant information about the logic involved and the significance and potential consequences for the Data Subject.
WHAT TYPES OF DATA DO WE COLLECT?
In general, the Company collects data to operate efficiently and provide the best experience related to its services. Should the Data Subject choose not to provide data necessary for a service or feature, they may not be able to benefit from that service or feature.
For situations specifically related to Candidates, the Company may collect and process the following types of data:
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Personal identification information: Name, email address, postal address, and phone number;
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Professional information: CVs, employment history, qualifications, and references;
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Device data and interaction details: Information about devices and how Candidates interact with the Company’s services and website.
In all other instances, we collect information about the device you use to access our services (such as hardware model, operating system version, unique device identifiers, and mobile network information, including phone number).
Log Information
When you use our services, we automatically collect and store certain information in server logs. This may include:
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Details about how you use our service, such as search queries;
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Telephony log information, such as your phone number, caller number, forwarding numbers, time and date of calls, call duration, SMS routing information, and call types;
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IP address;
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Device event information, such as system errors, system activity, hardware settings, browser type and language, the date and time of your request, and referral URLs;
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Cookies that uniquely identify your browser.
Location Information
We may collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS signals, and other sensors that provide information on nearby devices, Wi-Fi access points, and cell towers.
CONDITIONS FOR PROCESSING YOUR PERSONAL DATA
Your personal data will only be processed when:
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You have given consent for the processing of your personal data for one or more specific purposes;
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Processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract;
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Processing is necessary for compliance with a legal obligation to which the Company is subject;
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Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party, except where such interests are overridden by your fundamental rights and freedoms that require the protection of personal data, particularly when the data subject is a child or the processing involves direct marketing.
The principles of data protection do not apply to anonymous information—data that cannot be linked to an identified or identifiable natural person. This includes personal data that has been anonymized to the extent that you can no longer be identified. Consequently, this Privacy Policy does not apply to the processing of such anonymous data, including when used for statistical, research, or other purposes.
USE OF PERSONAL DATA
We will use personal data solely for the purposes for which it was collected and retain it only as long as necessary for those purposes.
If processing is necessary for the performance of a contract or to take steps prior to entering into a contract, the data will be used throughout the contract duration and for a period of 3 years following its termination.
If processing is based on consent for one or more specific purposes, the data will be retained for 5 years unless consent is withdrawn sooner.
STORAGE AND RETENTION OF PERSONAL DATA
We retain personal data for as long as necessary to provide the requested products and services, complete transactions, and fulfill essential purposes such as legal obligations, dispute resolution, and enforcement of our agreements.
Retention periods may vary depending on the type of data and context. The criteria for determining retention periods include:
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Maintaining and improving product performance, ensuring system security, and keeping appropriate business and financial records as required by applicable law;
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The duration of consent provided by the Data Subject or until the Data Subject withdraws consent as outlined in this policy;
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Legal requirements mandating data retention, particularly for investigations or potential legal proceedings.
RIGHTS OF THE DATA SUBJECT
As a Data Subject, you have the following rights regarding your personal data:
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Right to be informed: You have the right to receive clear and transparent information about how your personal data is processed.
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Right of access: You can request confirmation as to whether your personal data is being processed and, if so, access the data and understand how it is used.
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Right to data portability: You can receive your personal data in a structured, commonly used, and machine-readable format and have the right to transmit this data to another controller.
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Right to object: You may object to the processing of your personal data if it is being processed in the public interest or for the Company’s legitimate interests.
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Right to rectification: You can request the correction of inaccurate personal data without undue delay.
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Right to erasure (“right to be forgotten”): You may request the deletion of your personal data without undue delay if:
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The data is no longer necessary for the purposes for which it was collected;
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You withdraw your consent;
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You object to the processing;
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The data was unlawfully processed;
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The data must be deleted to comply with a legal obligation;
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The data was collected in connection with the provision of information society services.
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Right to restrict processing: You can request the restriction of your personal data’s processing if:
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The accuracy of the data is contested, for a period allowing verification;
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The processing is unlawful but you oppose erasure and request restriction instead;
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The Company no longer needs the data, but you require it for legal claims;
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You object to the processing pending verification of whether the legitimate grounds of the Company override your rights.
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Right not to be subject to automated decision-making, including profiling: You have the right to request human intervention in decision-making processes that rely solely on automated data processing, including profiling.
These rights can be exercised by contacting the Company using the contact details provided in this policy.
COMPLAINTS
If you believe that your personal data is not being processed lawfully, you have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection in Cyprus.
Contact Details of the Supervisory Authority in Cyprus:
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Office of the Commissioner for Personal Data Protection
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Address: kypranoros 15, Nicosia 1061 , Cyprus
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Phone: +357 22818456
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Website: www.dataprotection.gov.cy
For further assistance, feel free to reach out to us directly.