Privacy Policy

Interpretation and Definitions#

Interpretation#

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions#

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.
Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to DevInfra Inc., 200 1st Ave W, Suite 250, Seattle, WA 98119.
Consumer, for the purpose of the CCPA, means a natural person who is a California resident.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Country refers to: Washington, United States.
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
Personal Data is any information that relates to an identified or identifiable individual.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data on behalf of the Company.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
Website refers to DevZero, accessible from https://devzero.io.
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data#

Types of Data Collected#

Personal Data#

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Email address
First name and last name
Bank account information (for payment processing)
Usage Data

Usage Data#

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

Tracking Technologies and Cookies#

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

The technologies We use may include:

Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent.
Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service.
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons that permit the Company, for example, to count users who have visited those pages or opened an email.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies — Type: Session Cookies. These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts.
Cookies Policy / Notice Acceptance Cookies — Type: Persistent Cookies. These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies — Type: Persistent Cookies. These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference.
Tracking and Performance Cookies — Type: Persistent Cookies. These Cookies are used to track information about traffic to the Website and how users use the Website.

Use of Your Personal Data#

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication.
To provide You with news, special offers and general information about other goods, services and events which we offer.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns.

We may share Your personal information in the following situations:

With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data#

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service.

Transfer of Your Personal Data#

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

For personal data transferred from the European Union, United Kingdom, or Switzerland, DevZero relies on the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

Data Privacy Framework Compliance#

DevInfra Inc. ("DevZero") complies with the EU-U.S. Data Privacy Framework (DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF (collectively, the "DPF Principles").

We have certified to the Department of Commerce that we adhere to the DPF Principles for all personal data received from the European Union, the United Kingdom, and Switzerland in reliance on the DPF.

To learn more about the Data Privacy Framework program, please visit https://www.dataprivacyframework.gov/.

Independent Dispute Resolution#

In compliance with the DPF Principles, DevZero commits to resolving complaints about our handling of your personal data. EU, UK, and Swiss individuals with inquiries or complaints regarding this policy should first contact us at privacy@devzero.io.

DevZero has further committed to refer unresolved DPF complaints to an independent dispute resolution provider. We use BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers to file a complaint. This service is provided at no cost to you.

Arbitration#

Under certain conditions, you may be entitled to invoke binding arbitration for complaints regarding DevZero's DPF compliance that are not resolved by any of the other DPF mechanisms. For additional information, see https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction.

Onward Transfers#

When DevZero transfers personal data received under the DPF to a third-party acting as our agent, we remain responsible under the DPF Principles if that agent processes the personal data in a manner inconsistent with the DPF Principles, unless we prove we are not responsible for the event giving rise to the damage.

Your Rights Under the DPF#

Individuals from the EU, UK, and Switzerland have the right to access the personal data DevZero holds about them and may request correction, amendment, or deletion of that data where it is inaccurate or has been processed in violation of the DPF Principles. To submit a request, contact us at privacy@devzero.io.

FTC Jurisdiction#

DevZero is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC) with respect to our compliance with the DPF Principles.

Disclosure of Your Personal Data#

Business Transactions#

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement#

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements#

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of Your Personal Data#

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data#

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics#

We may use third-party Service providers to monitor and analyze the use of our Service.

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.

Email Marketing#

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send.

We may use Email Marketing Service Providers to manage and send emails to You.

HubSpot — Their Privacy Policy can be viewed at https://legal.hubspot.com/privacy-policy.

Payments#

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council.

CCPA Privacy#

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected#

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device.

The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months:

Category	Examples	Collected
A: Identifiers	Real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name	Yes
B: California Customer Records	Name, signature, address, telephone number, bank account number, credit/debit card number, financial information	Yes
C: Protected classification characteristics	Age, race, color, ancestry, national origin, citizenship, religion, marital status, disability, sex, gender identity, veteran status	No
D: Commercial information	Records of products or services purchased or considered	Yes
E: Biometric information	Genetic, physiological, behavioral, and biological characteristics	No
F: Internet or network activity	Interaction with our Service or advertisement	Yes
G: Geolocation data	Approximate physical location	No
H: Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information	No
I: Professional or employment-related information	Current or past job history or performance evaluations	No
J: Non-public education information	Education records directly related to a student	No
K: Inferences drawn from other personal information	Profile reflecting a person's preferences, characteristics, psychological trends	No

Sources of Personal Information#

We obtain the categories of personal information listed above from the following categories of sources:

Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service.
Indirectly from You. For example, from observing Your activity on our Service.
Automatically from You. For example, through Cookies We or our Service Providers set on Your Device as You navigate through our Service.
From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information for Business Purposes#

We may use or disclose personal information We collect for business purposes or commercial purposes (as defined under the CCPA), which may include:

To operate our Service and provide You with Our Service.
To provide You with support and to respond to Your inquiries.
To fulfill or meet the reason You provided the information.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
For internal administrative and auditing purposes.
To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity.

Your Rights Under the CCPA#

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information.
The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information.
The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions.
The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights.

Exercising Your CCPA Data Protection Rights#

In order to exercise any of Your rights under the CCPA, please contact us at privacy@devzero.io.

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

We cannot respond to Your request or provide You with the required information if We cannot verify Your identity or authority to make the request and confirm that the personal information relates to You.

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Do Not Sell My Personal Information#

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

The NAI's opt-out platform: http://www.networkadvertising.org/choices/
The EDAA's opt-out platform: http://www.youronlinechoices.com/
The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

"Do Not Track" Policy as Required by CalOPPA#

Our Service does not respond to Do Not Track signals. However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked.

Children's Privacy#

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Your California Privacy Rights (Shine the Light Law)#

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (Under 18)#

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites#

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy#

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us#

If you have any questions about this Privacy Policy or questions related to our Data Privacy Framework compliance, you can contact us:

By email: privacy@devzero.io