Privacy Policy

Introduction

DevEngine Ltd. (the "Company") connects West Coast US technology companies with software engineers located in Vancouver, British Columbia, by building distributed engineering teams (the "Services"). The Company respects the privacy of individuals and strives to collect, use and disclose Personal Information in a manner consistent with all applicable laws. The Company is committed to safeguarding the privacy of Personal Information that it collects, uses or discloses in the course of providing the Services and will not sell Personal Information.

Application of Policy

This Policy establishes the Company's obligations and expectations for the use, collection and disclosure of Personal Information of visitors to or registered users of the Company's website (collectively, the "User" or "Users" as applicable)—whether oral, electronic or written. This Policy does not apply to the Personal Information of the Company's employees.

Personal information

In this policy, "Personal Information" means any information about an identifiable individual but does not include business contact information which enables an individual at a place of business to be contacted. Information that is organized in the aggregate and/or which does not reasonably identify the individual to whom it pertains is not Personal Information.

Purposes

Except as otherwise provided by law, the Company shall collect, use or disclose Personal Information only as reasonably required for providing the Services (the "Purposes"). The Purposes include, but are not limited to:

• facilitating the interactions between clients and engineers through email, phone or SMS;
• managing the accounts of registered users, including billing;
• notifying engineers of new and upcoming relevant job opportunities;
• presenting engineers' profiles and resumes to a specific job opportunity;
• facilitating job interviews between clients and engineers;
• improving the delivery of the Services, including providing customer support;
• monitoring the use of the Company's website, for creating, improving or editing the Company's website content, and to protect the security and integrity of the Company's website;
• enforcing the User's compliance with all applicable terms of use and all applicable laws, including investigating any complaints or claims related thereto or assisting law enforcement or any authority with jurisdiction in any investigation;
• providing Users with notifications relating to the Services, including notifications from other Users, updates about changes to, and features of, the Services, important news which may impact a User's use of the Services, and as may be required by law, and
• complying with the Company's legal obligations, business requirements, and regulatory compliance and for auditing purposes. If the Company wishes to use or disclose Personal Information for any purpose other than the Purposes, the Company will obtain the consent of the User, as required under applicable laws and regulations.

Consent

By visiting the Company's website, or by voluntarily providing Personal Information to the Company in the course of becoming a registered user, as applicable, the User is deemed to have given his or her consent to the collection, use and disclosure of Personal Information under this Policy. A User may withdraw his or her consent in writing to the use, and disclosure of their Personal Information at any time unless the Personal Information is necessary for the Company to fulfill its legal obligations. If a User withdraws consent to the use and disclosure of Personal Information, it may compromise the Company's ability to provide the User with the Company's Services.

Collection of personal information

The types of Personal Information that the Company may collect include, but are not limited to, the following:

• email address, postal code, first and last name, cell phone number, physical address, resume, references, banking information, incorporation information, and GST number.
• information related to the use of the Company's website, including IP address, browser type, the referring domain, pages visited, and search history;
• information relating to the User's interactions with the Company, including records of correspondence, internal notes or memoranda, financial records, and business records.
• The Company normally collects Personal Information directly from the User but may collect User's Personal Information from third parties as authorized by law.

Disclosure of personal information

The Company may disclose Personal Information to third parties for legitimate business purposes or the Purposes and will obtain assurances from such third parties that they will safeguard Personal Information in a manner consistent with this Policy. To the extent such Personal Information is disclosed to third parties in other countries, those countries to which Personal Information will be transferred may or may not have laws that seek to preserve the privacy of Personal Information.

The Company uses services hosted by third parties in the course of providing the Services, including Zoho ATS, and Amazon AWS (the "Third Party Hosts"). To the extent any Third Party Host collects the Personal Information of Users, such collection will be subject to the applicable privacy policies of the Third-Party Hosts and shall not fall under the scope of this Policy.

Retention and destruction

• Subject to the terms of this Policy, Personal Information is only retained as long as is reasonable to fulfill the purpose for which it was collected or for legal or business purposes (such as backup, archival, or audit purposes, or to improve the Services) or as otherwise required under applicable law.
• Personal Information which is used to make a decision that directly affects the User to whom it pertains will be retained for at least one year after the date of that decision.

The Company normally collects Personal Information directly from the User but may collect User’s Personal Information from third parties as authorized by law.

Security

The Company will take reasonable precautions, including technical, administrative and physical measures to protect Personal Information from loss, misuse, and unauthorized access, disclosure, alteration or destruction. Records containing Personal Information are considered Company property and will be afforded confidential treatment at all times, regardless of whether these records are in electronic or paper form.

• Accuracy The Company will employ reasonable efforts to keep Personal Information relevant to its intended use, accurate, complete and current. The Company relies on Users to notify it if there is a change to their Personal Information. The Company will take reasonable steps to permit Users to correct, amend or delete Personal Information that is demonstrated to be inaccurate or incomplete. These requests may be made by contacting the company founder. In the event Personal Information is corrected, the Company will as soon as reasonably possible send applicable corrections to each organization the Personal Information was disclosed to during the year before the Personal Information was corrected. In the event Personal Information is not corrected, the Company will note the requested correction where applicable.
• Access Users have a right to access their Personal Information that is in the custody or under the control of the Company, subject to exceptions provided for in applicable privacy laws. In the event an access request is refused, the User will be advised in writing of the reasons for the refusal and other applicable information.

Users also have a right to ask the Company to provide them with information about how their Personal Information has or is being used, as well as with the names of the individuals and organizations to which a user’s Personal Information has been disclosed. Any requests for access or information about how Personal Information has been used and to whom it has been disclosed should be made in writing and should be directed to the company founder at the address set out below. The Company may charge Users a minimal feel for access or information requests.

Contact information of privacy officer

Please submit questions or comments regarding this Policy or the Company’s practices concerning Personal Information to: Company Founder 422 Richards Street, Suite 170, Vancouver, BC, V6B 2Z4. Tel: 1(888)-342-8687. If a customer is not satisfied with the response of the Company, the customer may have a right to complain to the applicable privacy commissioner. In British Columbia, complaints may be directed to the Office of the Information and Privacy Commissioner for British Columbia.

• Changes to this Policy This policy may be amended from time to time, consistent with the requirements of applicable law. Appropriate notice will be given concerning any such amendment.
• Effective Date This Policy is effective as of August 1, 2019.