Privacy Policy

This Privacy Policy discloses the privacy practices for the https://devellp.com/ site and various related services including mobile applications (together referred to as the "Site"). DEVELLP, LLC, the provider of the Site (referred to as "us " or "we"), is committed to protecting your privacy online. Please read the information below to learn the following regarding your use of this Site.
You acknowledge that this Privacy Policy is part of our Site Terms of Use, and by accessing or using our Site, you agree to be bound by all of its terms and conditions. If you do not agree to these terms, please do not access or use this Site.
We reserve the right to change this Privacy Policy at any time. Such changes, modifications, additions or deletions shall be effective immediately upon notice thereof, which may be given by means including, but not limited to issuing an e-mail to the e-mail address listed by registered users and posting the revised Policy on this page. You acknowledge and agree that it is your responsibility to maintain a valid e-mail address as a registered user, review this Site and this Policy periodically and to be aware of any modifications. Your continued use of the Site after such modifications will constitute your: (a) acknowledgment of the modified Policy; and (b) agreement to abide and be bound by the modified Policy.

Types of Information Collected

In order to better provide you with our services, we collect two types of information about our users: Personally Identifiable Information and Non-Personally Identifiable Information. Our primary goal in collecting information from you is to provide you with a smooth, efficient, and customized experience while using our Site.
Personally Identifiable Information: This refers to information that lets us know the specifics of who you are. When you engage in certain activities on this Site, such as registering for a membership, ordering a product or service, submitting content and/or posting content in discussion forums or other public areas, entering a contest or sweepstakes, filling out a survey, or sending us feedback, we may ask you to provide certain information about yourself by filling out and submitting an online form. It is completely optional for you to elect to engage in these activities, however, we may ask that you provide us personal information, such as your first and last name, mailing address (including zip code), e-mail address, employer, job title and department, telephone and facsimile numbers, and other personal identifying information. When ordering products or services on the Site, you may be asked to provide a credit card number. Depending upon the activity, some of the information we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.
Non-Personally Identifiable Information: This refers to information that does not by itself identify a specific individual. We gather certain information about you based upon where you visit on our Site in several ways. This information is compiled and analyzed on both a personal and an aggregated basis. This information may include the website’s Uniform Resource Locator ("URL") that you just came from, which URL you next go to, what browser you are using, and your Internet Protocol ("IP") address. A URL is the global address of documents and other resources on the internet. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol ("TCP/IP") network, such as the internet. Networks like the internet use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the internet, allowing servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the internet.

Collection Methods and Use of Information

We do not collect any Personally Identifiable Information about you unless you voluntarily provide it to us. You provide certain Personally Identifiable Information to us when you (a) register for our services and register your e-mail address with us; (b) enter sweepstakes or contests sponsored by us or one of our partners; (c) sign up for special offers from selected third parties; (d) send e-mail messages, submit forms or transmit other information by telephone or letter; or (e) submit your credit card or other payment information when ordering and purchasing products and services on our Site. We may also collect information from you at other points on our Site that state that such information is being collected.
In addition, we may also collect, or our third-party ad server and/or content server may collect, certain Non-Personally Identifiable Information. This information is ultimately stored in the form of store categories, and, in some cases, specific URLs. We use your IP address to diagnose problems with our servers, software, to administer our Site and to gather demographic information. Our third-party ad servers will also provide us with summary, but not individual, reports that will tell us how many ads were presented and clicked upon at our Site.
We will primarily use your Personally Identifiable Information to provide our services to you, as required by our agreements with you. We will also use Personally Identifiable Information to enhance the operation of our Site, fill orders, improve our marketing and promotional efforts, statistically analyze Site use, improve our product and service offerings, and customize our Site's content, layout, and services. We may use Personally Identifiable Information to deliver information to you and to contact you regarding administrative notices. We may also use Personally Identifiable Information to resolve disputes, troubleshoot problems and enforce our agreements with you, including our Site Terms of Use, Sales Terms and Conditions, and this Private Policy.

Privacy Policies of Third Party Sites

Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. Other Sites accessible through our Site have their own privacy policies and data collection, use and disclosure practices. Please consult each Site's privacy policy. We are not responsible for the policies or practices of third parties. Additionally, other companies which place advertising on our Site may collect information about you when you view or click on their advertising through the use of cookies. We cannot control this collection of information. You should contact these advertisers directly if you have any questions about their use of the information that they collect.
Our site uses technologies of third-party partners such as NextRoll to help us recognize your device and understand how you use our site(s) so that we can improve our services to reflect your interests and serve you advertisements about the products and/or services that are likely to be of more interest to you. Specifically, NextRoll collects information about your activity on our site(s) to enable us to:
● ​measure and analyze traffic and browsing activity on our site(s);● show advertisements for our products and/or services to you on third-party sites;● measure and analyze the performance of our advertising campaigns;
Some customers provide their customer relationship data to us (e.g. name, email address, company address) or instruct us to collect clear email addresses on the Customer’s behalf using NextRoll Technology (“Customer CRM Data”) for processing as part of our Services. By doing so, we can help our Customers serve, measure and analyze interest-based ads to the end user (we may also trigger these ads by licensing RollWorks B2B Contact Data to a customer). For example, using the example we already provided above, if you gave ACME Soccer Ball Co. your email address, ACME Soccer Ball Co. may use our Services to send you a promotional email for a soccer ball you looked at but did not purchase. Similarly, if you provided your email to a software website when you downloaded a white paper, through our Services the software company may (subject to your marketing preferences) send you a follow up email providing you with more information about the software company’s products or services. We use our Customer’s CRM Data only as a processor for the purpose of assisting that particular Customer with their own advertising efforts and, in some cases, reporting performance back to the Customer's CRM system. We do not share clear email addresses belonging to one Advertiser with another Advertiser for their advertising purposes.
If an Advertiser permits us, we collect hashed versions of the email addresses that consumers have entered on that Advertiser’s site. Hashing is a technology process that pseudonymizes (i.e. digitally scrambles) email addresses. For instance, when moc.llortxen%40tac_eht_eoj is run through a typical hashing function, it becomes the following string of digits:
0F0B7B1A1A7E8BDBBC6AA545F8CCD6F83671B32479271BFCB6CC8498912058D5
We take this step to de-identify data and protect email addresses, while being able to use the unique identifier created for the purpose of recognizing you and sending your interest-based ads across different devices (computers, tablets and mobile devices) and browsers (also called “cross-device matching”). We describe cross-device matching in further detail in How We Use the Data We Collect.
Shopping Data: Some Advertisers provide us with data about their buyers’ shopping habits, including transactional data, product codes, and check-out activity in addition to the browsing data that we collect. This data may come from their Digital Properties or other transactional data they maintain. We generally use this data to help us better target, personalize, and measure the effectiveness of advertising campaigns, etc.

We also collect data from our own customers and those who visit our website(s). To learn more about how we collect and use that data, please see our Privacy Notice below.

Data We Automatically Collect From Your Device

​Unless you have opted-out or have otherwise refused to provide consent, the following is data that we collect from your device automatically:
​Device Information: This is technical information about the device you use to access the Advertiser's Digital Property such as your device's IP address and operating system. Additionally, in the case of mobile devices, your device type, and mobile device's unique advertising identifier (such as the Apple IDFA or Android Advertising ID) and any other unique identifier that may be assigned to the mobile device, such as an Android ID or UDID in older Apple phone models, or a non-cookie unique identifier used by Non-Cookie Technologies.
Browser Data: This is technical information about the browser you are using that is captured in order to serve you an ad that can be rendered on your device. An example of browser information is the technical information that identifies your browser as, for example, Chrome, Firefox, Safari etc.
Activity on Advertisers’ Digital Properties: This is data about your browsing activity on the Advertiser's website or application. For example, which pages you visited and when, what items were clicked on a page, how much time was spent on a page, whether you downloaded a white paper on a B2B website, what site or ad brought you to the Advertiser’s website, what items you placed into your online shopping cart, and what products were purchased and the price of the products purchased.
Location Data: This is non-precise information related to your geography derived from your device’s IP address (e.g. laptop, desktop or mobile etc.). This does not reveal your precise geographic coordinates (i.e. your GPS latitude and longitude) - only country, state, city and zip/postal code level location data, and helps us to display ads that are relevant to your general location (for example, showing ads in French if you are located in France).
Ad Data: This is data about the online ads we have served (or attempted to serve) to you. For example, how many times an ad has been served to you, what page the ad appeared on, and whether you clicked on or otherwise interacted with the ad.

Data We Collect From Third Party Sources

Campaign Performance Data: This data includes information about how well our Customers’ ads and campaigns have performed, whether on our platform or on other platforms.
Attribute Data: We may collect additional information about you from other third party sources where they have the rights to share such information and we have the rights to use it, for example, demographic data or title and employer data. We use this data to better understand our Customers and to better market our Services to you.
Data from Advertising Partners: This is data that allows us to match the NextRoll cookie identifier with identifiers that may already be used by other companies in the digital advertising ecosystem that we work with (“Advertising Partners”), for example, ad exchanges or companies that sell advertising space on publishers’ websites (sometimes referred to as “supply side platforms”). Matching cookie identifiers help us deliver ads to you and recognize you across browsers and devices, and may include pseudonymous advertising identifiers (meaning identifiers that help identify your browser or device, but not you directly) which some third party advertising platforms choose to share with us. We may work with our Advertisers and Advertising Partners to synchronize their unique, pseudonymous identifiers to our own to enable us to more accurately recognize a particular unique browser or device and the advertising interests associated with it (commonly known as “ID Syncing”).

Data Sharing

We may disclose information about you:
With a Customer: We may share data about how you have interacted with that Customer’s Digital Properties, email campaigns or its Ads. If we have collected contact data from third parties as set out in What Data We Collect (specifically in the section “Contact Data from Third Parties”) as part of the data collected pursuant to the RollWorks Services, we may share the business contact data collected from third party sources or inferred (for example, based on email naming conventions) if we think that your business or employer would be interested in that Customer’s products. In regards to RollWorks Services, we do not collect contact data about residents of European Territories from third parties.
With Our Service Providers: We contract with companies who provide services to us to support our business operations (e.g., for example, website and data hosting, fraud prevention, viewability reporting, data hygiene, marketing, and email delivery), as well as billing, collections, tech, customer and operational support.
With Our Subsidiaries and Affiliates: Our subsidiaries and corporate affiliates will only process your data for the purposes already explained in this Service Privacy Notice. Our subsidiaries are NextRoll Limited (Ireland), AdRoll Limited (UK), and NextRoll Pty Limited (Australia).
With our Advertising Partners: We also share data with our Advertising Partners, including hashed email addresses (or other pseudonymous identifiers associated with those hashes), device information, browser data, activity on Advertiser’s Digital Properties, location data, shopper data and Customer CRM Data. This enables them and us to better personalize ads to you.
In Connection with Legal Proceedings: When we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of NextRoll, our Customer or any other third party.
In Connection with Legal Proceedings: When we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of NextRoll, our Customer or any other third party.

Cross-Device

We may share data, such as hashed email derived from emails or other online identifiers collected on our site(s) with NextRoll. This allows our partners to recognize and deliver you ads across devices and browsers. To read more about the technologies used by NextRoll and their cross device capabilities please refer to NextRoll’s Privacy Notice.

Opting-Out

We recognize how important your online privacy is to you, so we offer the following options for controlling the interest-based ads you receive and how we use your data.
​Opting-out of this type of advertising will not prevent you from seeing ads, rather those ads will likely be less relevant. This is because they will not be tailored to your specific interests but will instead be based on the context of the Digital Property in which they are displayed (for example, if you are on a movie website, you may only see ads about movies) or the ads you see may be randomly generated.

How You Can Control How We Use Your Data

Web Browser: You can opt-out of receiving interest-based ads served by us or on our behalf by clicking on the blue icon that typically appears in the corner of the ads we serve and following the instructions provided or by clicking here. Please note that this “opt-out” function is browser-specific and relies on an “opt-out cookie”. This means if you delete your cookies or upgrade your browser after having opted out, you will need to opt-out again.
Cross Device Opt-Out: In some cases, we may link multiple browsers or devices to you. If you opt-out on a browser or device and we have additional devices or browsers linked to you, we will extend your opt-out decision to any other linked browsers and devices. Since we only link users across browsers and devices in certain conditions, there may be cases where you are still being tracked in a different browser or device we have not linked, and where we are treating you as a different user.
Mobile Device Opt-Out: To opt-out of receiving interest-based ads that are based on your behavior across different mobile applications, please follow instructions for iOS and Android devices:
● For iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting; and● For Android devices with OS 2.2 or Higher: Open your Google Settings app > Select Ads > Enable “Opt out of interest-based advertising”

Industry Opt-Out Tools and Self-Regulation

​Our partners such as NextRoll may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. For this reason, you can use the following third-party tools to decline the collection and use of information for the purpose of serving you interest based advertising:
● ​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

Information For California Residents Only

https://www.nextroll.com/privacy#service-13

Privacy Statement

This PRIVACY NOTICE FOR U.S. RESIDENTS applies solely to visitors, users, and others who reside in the U.S. (“consumers” or “you”).  
Information We Collect
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 (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months: 

Category A: IdentifiersExamples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Collected: YES

Category B: Personal information categories. Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.Collected: YES

Category C: Protected classification characteristics. Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Collected: NO

Category D: Commercial information. Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Collected: NO

Category E: Biometric information. Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Collected: NO
Category F: Internet or other similar network activity. Examples: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Collected: NO
Category G: Geolocation data. Examples: Physical location or movements. Collected: NO
Category H: Sensory data. Examples: Audio, electronic, visual, thermal, olfactory, or similar information. Collected: NO
Category I: Professional or employment-related information. Examples: Current or past job history or performance evaluations. Collected: NO
Category J: Non-public education information.Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Collected: NO
Category K: Inferences drawn from other personal information.Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Collected: NO
Personal information does not include: 
● Publicly available information from government records. ● De-identified or aggregated consumer information. 
We obtain the categories of personal information listed above from the following categories of sources:
● Directly from our Consumers or Service Providers. ● Indirectly from our Consumers. For example, through information we collect from our Consumers in the course of providing services to them. ● Directly and indirectly from activity within our Site. For example, from submissions through our Site or Site usage details collected automatically. 
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes: ● To fulfill or meet the reason for which the information is provided. ● To provide you with information, products or services that you request from us. ● To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections. ● To improve our Site and present its contents to you. ● For testing, research, analysis and product or service development. ● As necessary or appropriate to protect the rights, property or safety of us, our Consumers, Service Providers or others. ● 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.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. 
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
● Category A: Identifiers. ● Category B: California Customer Records personal information categories. ● We disclose your personal information for a business purpose to the following categories of third parties: 
1. Our affiliates. 2. Consumers and Service Providers. 3. Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Your Rights and Choices
This section describes your rights and explains how to exercise those rights. 
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you: 
● The categories of personal information we collected about you. ● The categories of sources for the personal information we collected about you. ● Our business or commercial purpose for collecting or selling that personal information. ● The categories of third parties with whom we share that personal information. ● The specific pieces of personal information we collected about you (also called a data portability request). ● If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose or identifying the personal information categories that each category of recipient obtained. 
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. 
We may deny your deletion request if retaining the information is necessary for us or our service providers to: 
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. 2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 3. Debug products to identify and repair errors that impair existing intended functionality. 4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.      5. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent. 6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. 7. Comply with a legal obligation. 8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it. 
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us through our Site.  
Only you may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. 
You may only make a verifiable consumer request for access or data portability twice within a 12- month period. The verifiable consumer request must: 
● Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. ● Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. 
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 
Non-Discrimination
We will not discriminate against you for exercising any of your rights. Unless permitted by law, we will not: 
● Deny you goods or services. ● Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. ● Provide you a different level or quality of goods or services. ● Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. 
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our Site. 
Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us through the Site using “ATTENTION: PRIVACY COMPLIANCE OFFICER” in the message.

Your General Data Protection Regulation (“GDPR”) Rights 

If you are a citizen of the European Union (“EU”), you are entitled to certain rights under the GDPR. You have the right to: 
● Know how long we’ll keep your information. We’ll keep your personal information until the earlier of: (1) you either ask us to delete your information or (2) the Company decides it no longer needs the data and the cost of retaining it outweighs the value to keeping it. ● Access, rectify or erase your personal information. ● Withdraw your consent to the Company’s processing of your data, which shall have no effect on the lawfulness of the processing of your personal information prior to your withdrawal.● Lodge a complaint with a supervisory authority that has jurisdiction over GDPR issues.● Provide only your personal information which is reasonably required to enter into a contract with us. The Company will not ask for your consent to provide unnecessary personal information on the condition of entering into a contractual relationship with the Company. 

Miscellaneous Privacy Issues

You must be at least 18 years old to have our permission to use this Site. Our policy is that we do not knowingly collect, use or disclose Personally Identifiable Information about visitors that are under 18 years of age.
You should also be aware that when Personally Identifiable Information is voluntarily disclosed (i.e. your name, e-mail address, etc.) in the discussion forums or other public areas on this Site, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this Policy does not apply to such information. Any submissions to chat rooms or other public areas on this Site are accepted with the understanding that they are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for maintaining the secrecy of your password and/or account information. Please be careful and responsible whenever you're online.
If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Site, please contact us by sending a letter to:
DEVELLP, LLCAttn: Privacy Compliance Officer6750 N Andrews Ave Suite 200Fort Lauderdale, FL 33309
You may also contact us by e-mail at moc.plleved%40troppus