This Privacy Policy (“Policy”) sets out how Devtrios (“Devtrios”, “we”, “us”, or “our”), a company incorporated and registered in England and Wales with its registered office at 27 Old Gloucester Street, London, WC1N 3AX, United Kingdom, collects, uses, processes, stores, transfers, and protects personal data when you (“User”, “you”, “your”) access or use our website located at [www.devtrios.com] (“Website”).

This Policy is drafted in accordance with the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018, and other applicable data protection laws. By using the Website, you acknowledge that you have read and understood this Policy.

1. Definitions

For the purposes of this Policy:
(a) “Personal Data” means any information relating to an identified or identifiable natural person, including but not limited to names, contact details, IP addresses, device identifiers, and online behaviour data;
(b) “Processing” means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, or erasure;
(c) “Cookies” means small data files placed on your device, as further described in our Cookie Policy;
(d) “Controller” means Devtrios, which determines the purposes and means of Processing Personal Data;
(e) “Third Parties” include CRM providers, analytics providers, hosting services, and other technical service providers engaged by Devtrios.

2. Categories of Personal Data Collected

2.1 Devtrios may collect and Process the following categories of Personal Data:
(a) Directly Provided Data: information you provide via contact forms, subscription forms, or email correspondence, including names, company details, email addresses, telephone numbers, and project requirements;
(b) Automatically Collected Data: IP addresses, device identifiers, browser type, operating system, referral sources, and browsing behaviour, collected via cookies, server logs, and similar technologies;
(c) Analytics Data: data generated through the use of analytics providers (including Google Analytics and similar tools), including user engagement, traffic patterns, and location approximations;
(d) Marketing Data: data collected through marketing pixels or tags (such as Meta Pixel, LinkedIn Insight Tag, and Google Ads tags), subject to your consent.

2.2 Devtrios does not knowingly collect or Process special category data (e.g. health, ethnicity, biometric data).

3. Purposes of Processing and Legal Basis

3.1 Devtrios Processes Personal Data for the following purposes:
(a) to respond to enquiries and provide information regarding Services (contractual necessity);
(b) to provide, maintain, and improve the functionality of the Website (legitimate interests);
(c) to analyse Website usage, measure performance, and monitor security (legitimate interests);
(d) to send newsletters, updates, or marketing communications where the User has provided consent (consent);
(e) to comply with legal obligations imposed by applicable law (legal obligation).

3.2 For the avoidance of doubt, Devtrios does not use Personal Data for recruitment purposes.

4. Sharing of Personal Data

4.1 Devtrios does not sell, rent, or trade Personal Data.

4.2 We may share Personal Data with:
(a) Hosting providers and cloud services (including AWS and similar platforms);
(b) CRM systems and analytics providers engaged to manage relationships and analyse data;
(c) Regulatory authorities, courts, or law enforcement agencies where required by applicable law.

4.3 Some Third Parties may be located outside the UK/EEA. Where such transfers occur, Devtrios shall ensure compliance with Chapter V of the UK GDPR, including reliance on adequacy regulations or Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner’s Office.

5. Retention of Personal Data

Personal Data shall be retained only for as long as is strictly necessary to fulfil the purposes for which it was collected, or to comply with applicable legal, regulatory, or contractual obligations. Retention periods are determined based on the nature of the data, the purpose of Processing, and applicable legal requirements.

6. Data Subject Rights

Subject to applicable law, you have the following rights in respect of your Personal Data:
(a) the right to access your Personal Data (Article 15 UK GDPR);
(b) the right to rectification of inaccurate or incomplete Personal Data (Article 16);
(c) the right to erasure (“right to be forgotten”) (Article 17);
(d) the right to restriction of Processing (Article 18);
(e) the right to data portability (Article 20);
(f) the right to object to Processing carried out on the basis of legitimate interests (Article 21);
(g) the right to withdraw consent to Processing where consent is relied upon (Article 7);
(h) the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection.

7. Children’s Data

The Website and Services are not directed to individuals under the age of sixteen (16), and Devtrios does not knowingly collect or Process Personal Data relating to children. If we become aware that such data has been collected, we shall promptly delete it.

8. Security of Personal Data

Devtrios implements appropriate technical and organisational measures designed to protect Personal Data against unauthorised or unlawful Processing, accidental loss, destruction, or damage. While we strive to protect Personal Data, no transmission over the internet or storage system is entirely secure, and we cannot guarantee absolute security.

9. Cookies

The Website uses cookies and similar technologies to improve functionality, analyse usage, and support marketing efforts. Details of the categories of cookies used, their purposes, and how you can manage preferences are set out in our Cookie Policy, which forms part of this Policy.

10. Amendments

Devtrios reserves the right to amend this Policy at any time. The effective date shall be updated accordingly. Continued use of the Website following publication of an amended Policy shall constitute acceptance of the revised terms.

11. Contact Information

For any questions, requests, or to exercise your rights under this Policy, please contact us at:

Devtrios
27 Old Gloucester Street
London WC1N 3AX
United Kingdom
Email: info@devtrios.com
Tel: +44 7470 801776