Privacy Policy

1. Introduction

Welcome to Devils.inc. We are committed to respecting your privacy and protecting your personal data in accordance with applicable privacy laws, including the Law of Ukraine “On Personal Data Protection” and, where applicable, the General Data Protection Regulation (GDPR) for users located in the European Union.
In addition, we strive to apply the principles of transparency, data minimization, and user control to all users of our website, regardless of their geographic location — including users from other regions.
This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you visit our website at devils.inc, whether you are a job applicant, business partner, or general visitor.
By accessing or using our website, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and processing of your personal data as described herein.

2. Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings defined below:

Personal Data means any information that relates to an identified or identifiable natural person, including but not limited to name, contact details, resume/CV, IP address, and any other data collected through the use of our website.
Processing means any operation performed on personal data, whether automated or not, such as collection, recording, storage, use, disclosure, or deletion.
User, “you”, or “your” refers to any individual who accesses or uses our website.
Cookies are small text files placed on your device by a website, containing details about your browsing history on that website and other information.
Service Provider means any natural or legal person who processes data on behalf of the data controller. This includes third-party companies or individuals engaged to facilitate the Service, provide the Service, perform Service-related tasks, or assist in analyzing how the Service is used.
GDPR refers to the General Data Protection Regulation (EU) 2016/679.
Applicable Laws means all relevant privacy and data protection laws, including but not limited to the GDPR and the Law of Ukraine “On Personal Data Protection”.

3. Information We Collect

We collect various types of information to provide and improve our services, ensure website security, and comply with legal obligations. The information we collect includes, but is not limited to, the following categories:

3.1 Information You Provide Directly:

• Full name
• Email address
• Phone number
• Resume/CV and other uploaded documents
• Cover letter and responses to application questions
• Company or organization name (if submitted via contact form)
• Any other information you voluntarily submit via forms or email correspondence

3.2 Automatically Collected Information (including via cookies):

• IP address
• Browser type and version
• Operating system and device type
• Language preferences
• Referring URL and pages visited
• Date, time, and duration of visit
• Session activity (clicks, scrolling, etc.)
• Log files and error reports

3.3 Cookies and Tracking Technologies:

• Technical cookies necessary for website functionality
• Preference cookies for saving language or interface choices
• Analytics cookies to monitor usage (e.g., Google Analytics)
• Marketing/tracking cookies (e.g., Facebook Pixel)
• Cookie ID and consent preferences

Note: We do not knowingly collect data from children under the age of 18. If we become aware that such data has been submitted, we will take steps to delete it.

4. How We Use Your Information

We use your personal data for the following purposes, in accordance with applicable laws and based on legal grounds such as consent, contractual necessity, legitimate interest, and legal obligation:

• To process, evaluate, and manage job applications and recruitment processes
• To contact you in relation to your application, inquiries, or feedback
• To maintain, operate, and improve the functionality and security of our website
• To analyze user behavior, preferences, and website performance through cookies and tracking tools
• To protect our systems and data against security breaches and fraudulent activity
• To comply with applicable legal obligations, regulatory requirements, or lawful requests by authorities
• To enforce our Terms and Conditions and prevent misuse of the website
• [Optional] To send service-related announcements or updates, if applicable

We do not sell, rent, or trade your personal data to third parties.
If we decide in the future to use your information for marketing or promotional purposes, this Privacy Policy will be updated accordingly. All changes will be published on this page and will take effect from the date of publication.

5. Legal Basis for Processing

We process personal data in accordance with applicable data protection laws and recognized international standards, including but not limited to:

• the General Data Protection Regulation (GDPR) of the European Union,
• the Law of Ukraine “On Personal Data Protection”, and
• international standards such as transparency, fairness, purpose limitation, data minimization, and user control — regardless of the user’s location.

Depending on the context, we rely on one or more of the following legal bases for processing:

• Consent – When you voluntarily provide information, such as by submitting a job application or contacting us.
• Contractual Necessity – When processing is necessary for the performance of a contract or in order to take steps prior to entering into a contract.
• Legitimate Interests – When we pursue legitimate business interests such as improving security, website functionality, or analytics, provided such interests are not overridden by your fundamental rights.
• Legal Obligation – When we are required to process certain data to comply with legal obligations, such as for tax, employment, or regulatory compliance.

6. How We Share Your Data

We do not sell or rent your personal data. However, we may share your data in the following limited circumstances:

• Internal Teams – Access is provided only to authorized personnel, such as HR staff, recruitment teams, and IT administrators, who need the information to perform their duties.
• Service Providers – Trusted third-party vendors may process data on our behalf to support our operations, including website hosting, analytics, infrastructure security, and document management. These providers are bound by confidentiality obligations and data protection agreements.
• Legal Obligations – We may disclose personal data if required to do so by law, court order, or valid legal request (e.g., from tax authorities or law enforcement).
• Business Transfers – In case of a merger, acquisition, reorganization, or sale of assets, personal data may be part of the transferred assets. In such a case, we will ensure the new entity respects the same level of data protection.
• Cross-Border Transfers – Your Personal Data may be transferred and processed in countries outside of your country of residence, including jurisdictions that may not offer the same level of data protection. In such cases, we take appropriate steps to ensure that your data remains protected and secure in line with applicable data protection laws and industry standards. These measures may include contractual obligations or other safeguards to support a lawful transfer.

7. Data Storage Period

We retain Personal Data only for as long as it is necessary to fulfill the purposes for which it was collected, including for the purposes of providing services, maintaining business records, complying with legal obligations, resolving disputes, and enforcing our agreements.
The exact duration for which we retain data may vary depending on the type of data and the context in which it is processed. Where specific legal retention periods apply, we will retain the relevant data for the duration required by law. In other cases, we will determine the appropriate retention period based on the sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, and whether the purpose of processing can still be reasonably fulfilled.
Once the applicable retention period has expired or the data is no longer needed, we take appropriate steps to securely delete or anonymise the data, unless further retention is required or permitted by law. We may also retain certain information in a de-identified or aggregated form for analytical, statistical, or research purposes.

8. Your Rights

Depending on your location and the applicable data protection laws, you may have certain rights regarding the Personal Data we process about you. These rights are subject to legal limitations and conditions, but may include the following:

• Right to access – You have the right to request access to the Personal Data we hold about you, including the purposes of processing and the categories of data involved.
• Right to rectification – You may request correction of inaccurate or incomplete data relating to you.
• Right to erasure (“right to be forgotten”) – In certain situations, you may request the deletion of your Personal Data, for example, where the data is no longer needed for the original purposes. However, this right may not apply in all cases — for instance, where we are required to retain certain data by law, or where deletion is technically not feasible due to the nature of our systems (e.g., automated backups or archived logs).
• Right to restrict processing – You may have the right to request that we temporarily or permanently stop processing all or some of your Personal Data.
• Right to object to processing – You can object to the processing of your Personal Data if it is based on our legitimate interests or used for direct marketing.
• Right to data portability – You may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and to request that we transfer it to another controller.
• Right to withdraw consent – Where we process your Personal Data based on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of prior processing.
• Right to lodge a complaint – You have the right to file a complaint with a data protection authority if you believe your rights have been violated.

We will respond to your request in accordance with applicable laws. To exercise any of your rights, you may contact us at the contact details provided in this Policy.
Requests to exercise your rights under this Policy may be submitted via email at [email protected].

9. Security Measures

We take the protection of your Personal Data seriously and implement a range of technical and organizational measures designed to safeguard it against unauthorized access, use, disclosure, alteration, or destruction.
Our security practices include, but are not limited to:

• Secure server infrastructure with firewalls, access controls, and intrusion detection systems;
• Encryption of Personal Data during transmission using industry-standard protocols (such as HTTPS/TLS);
• Limited access to Personal Data based on the principle of least privilege and role-based access controls;
• Regular security audits, monitoring, and vulnerability assessments of our systems and infrastructure;
• Policies and procedures governing data access, processing, and incident response.

Although we use reasonable efforts to protect your Personal Data, no method of transmission or storage is completely secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately at [email protected].

10. Cookies and Tracking Technologies

We use strictly necessary and functional cookies to ensure the proper operation of our website and improve your user experience. These cookies enable core site functionality, such as page navigation, access to secure areas, and language preferences.
We do not use cookies or similar tracking technologies for analytics, advertising, or profiling purposes.
You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the performance and functionality of the website.

11. Links to Other Websites

Our website may contain links to third-party websites or services that are not operated or controlled by us. We are not responsible for the content, privacy practices, or policies of such third parties.
If you follow a link to any external site, please be aware that your interaction with such sites is governed by their own terms and privacy policies, not ours. We encourage you to review those policies before providing any Personal Data to third-party services.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. Any changes will be published on this page with a revised “Last Updated” date at the top of the Policy.
We encourage you to review this Privacy Policy periodically to stay informed about how we protect your Personal Data. If we make material changes that significantly affect your rights or the way we process your Personal Data, we will provide additional notice, such as by posting a prominent notice on our website or sending you a direct notification.