Privacy Policy

Effective Date: June 30, 20201.

Corporate Commitment to Privacy

At Devtropolis Ltd we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”),the DPA 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process andkeep your data safe. The Privacy Policy will tell you about your privacyrights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data caninclude:            
Business contacts            
Employees/Staff Members

and any other people that the organisation has a relationship with or may need to contact. This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2 Who is Your Data Controller

Devtropolis Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us on email at or sent in a letter to Devtropolis LTD, Spaces, Peter House, OxfordSt, Manchester M1 5AN

You have the right to make a complaint at any time to theInformation Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Wewould, however, appreciate the chance to deal with your concerns before youapproach the ICO so please contact us inthe first instance.

1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities describedbelow may be assigned to an individual, or may be taken to apply to theorganisation as a whole. The Data Controller and our Processors have the following responsibilities:      

Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);      
Ensure that Processors authorised to process Personal Data have committed      themselves to confidentiality or are underan appropriate statutory obligation of confidentiality;      
Implementappropriate technical and organisational measures to ensure a level of securityappropriate to the risk associated with the processing of Personal Data;      Obtainthe prior specific or general authorisation of the Controller before engaginganother Processor;      
Assistthe Controller in the fulfilment of the Controller's obligation to respond torequests for exercising the data subject's rights;      
Make available to the Controller all information necessary to demonstrate compliancewith the obligations laid down in the GDPR and allow for and contribute toaudits, including inspections, conducted by the Controller or another auditormandated by the Controller;            
Maintaina record of all categories of processing activities carried out on behalf of aController;            
Cooperate,on request, with the supervisory authority in the performance of its tasks;      Ensurethat any person acting under the authority of the Processor who has access toPersonal Data does not process Personal Data except on instructions from theController; and      Notifythe Controller without undue delay after becoming aware of a Personal DataBreach;

2. Legal Basis for data collection

2.1 Types of Data / Privacy Policy Scope

“Personal Data” means any information about an individual from which that person can be identified.It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds ofPersonal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:      

Profile/IdentityData: This is data relating to your first name, last name, gender, date of birth.      
Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.      
Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.      
Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.    
FinancialData: These are your banking details e.g. your account number and sort code.   TransactionalData: This is information of details and records of all payments you have made for our services or products.      

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we relyon are:      

“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy toreceive email newsletters from us, or ‘opt in’ to a service.    
“Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.      
“Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.      
“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

3. How we use your personal data

3.1 Our Uses

We will only use your Personal Data when the law allows usto. Set out below is a table containing the different types of Personal Data wecollect and the lawful basis for processing that data. Please refer to section2.2 for more information on the lawful basis listed in the table below.

Examples provided in the table below are indicative innature and the purposes for which we use your data may be broader thandescribed but we will never process your data without a legal basis for doingso and it is for a related purpose. For further inquiries please contact us.

3.2 Marketing and Content Updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

**3.3 Change of Purpose **

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Your rights and how you are protected by us

4.1 What Control Do I Have Over Devtropolis Ltd’s Use Of My Personal Data?

You may delete your account at any time – this will removeyour account page from our systems and our related software.

We guarantee this will delete all stored data.

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorised access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

You can access information associated with your account by logging into your account you created with us.

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorised access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

4.2How Does Devtropolis Ltd Protect Customers' Personal Data?

California Privacy Rights: Under California Civil Codesections 1798.83-1798.84, California residents are entitled to ask us for anotice identifying the categories of personal customer information which weshare with our affiliates and/or third parties for marketing purposes, andproviding contact information for such affiliates and/or third parties. If youare a California resident and would like a copy of this notice, please submit awritten request to

4.2 How Does Devtropolis Ltd Protect Customers' Personal Data?

We are concerned with keeping your data secure andprotecting it from inappropriate disclosure. Any Personal Data collected by usis only accessible by a limited number of employees who have special accessrights to such systems and are bound by obligations of confidentiality. If andwhen we use subcontractors to store your data, we will not relinquish controlof your Personal Data or expose it to security risks that would not have arisenhad the data remained in our possession. However, unfortunately no transmissionof data over the internet is guaranteed to be completely secure. It may bepossible for third parties not under the control of Devtropolis Ltd tointercept or access transmissions or private communications unlawfully. Whilewe strive to protect your Personal Data, we cannot ensure or warrant thesecurity of any Personal Data you transmit to us. Any such transmission is doneat your own risk. If you believe that your interaction with us is no longer secure, please contact us.

4.3 Opting Out Of Marketing Promotions

You can ask us to stop sending you marketing messages at any time by Unsubscribe link.

Where you opt-out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

4.4 How to Request your Data and the Process for Obtaining it

You will not have to pay a fee to access your Personal Data(or to exercise any of the other rights). However, if your request is clearlyunfounded, we could refuse to comply with your request.

We may need to request specific information from you tohelp us confirm your identity and ensure you have the right to access yourPersonal Data (or to exercise any of your other rights). This is a securitymeasure to ensure that Personal Data is not disclosed to any person who has noright to receive it. We may also contact you to ask you for further informationin relation to your request to speed up our response.

5. Your data and third parties

5.1 Will We Share Your Data With Third Parties?

We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors (only when necessary and with your consent) or affiliates (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions).

We may also share Personal Data with interested parties in the event that Devtropolis Ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If Devtropolis Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations, your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).We may share your Personal Data at any time if required forl egal reasons or in order to enforce our terms or this Privacy Policy.

6.How long will we retain your data for?

We will only retain your Personal Data for as long asreasonably necessary to fulfill the purposes we collected it for. We may retainyour Personal Data for a longer period than usual in the event of a complaintor if we reasonably believe there is a prospect of litigation in respect to ourrelationship with you.

7. Age limit for our users

You must not use Devtropolis Ltd unless you are aged 18 or older. If you are under 18 and you access Devtropolis Ltd by lying about your age, you must immediately stop using Devtropolis Ltd.

This website is not intended for children and we do not knowingly collect data relating to children.

8. International transfer of data

Your information may be stored and processed in the US orother countries or jurisdictions outside the US where Devtropolis Ltd hasfacilities. We are currently storing data in the EU and so, by usingDevtropolis Ltd, you are permitting and consenting to the transfer of information,including Personal Data, outside of the US.

9. Notification of changes and acceptance of policy.

We keep our Privacy Policy under review and will place anyupdates on this webpage. This version is dated 30 June 2020. By usingDevtropolis Ltd, you consent to the collection and use of data by us as set outin this Privacy Policy. Continued access or use of Devtropolis Ltd willconstitute your express acceptance of any modifications to this Privacy Policy.

10. Interpretation

All uses of the word "including" mean"including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have.

provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).Our staff are not authorised to contract on behalf of Devtropolis Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Devtropolis Ltd address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Devtropolis Ltd rights, the email contentwill be read down to grant precedence to the latter.The only exception to this is genuine correspondence expressed to be from the Devtropolis Ltd legal department.