Privacy Policy

We, Devenue Inc., a company incorporated under the laws of Delaware, having its registered office at 838 Walker Rd., Suite 21-2, Dover, Delaware, 19904, County of Kent, USA (hereinafter referred to as "Company", “we”, “our”, “Dev” and “us”), the creator of this privacy policy (“Privacy Policy”) ensures to keep any and all personal information collected of those individuals who visit our website, https://www.reo.dev/ ("Website"), use our products, software, documents, material and our intellectual property (“Products”) and avail our services (“Services”), as defined in detail below accurate, confidential, secure and private. The Website, Product and the Services will be collectively referred to as (“Offerings”). 

To enhance better protection of your privacy, we provide this notice explaining our information practices, and the choices you can make about the way your information is collected and used.

All individuals who access our Offerings shall be jointly and severally referred to as "you" or "Users" in this Privacy Policy. You are advised to read and understand our Privacy Policy carefully, as by accessing the same you agree to be bound by the terms and conditions of the Privacy Policy and consent to the collection, storage and use of information relating to you as provided herein. By way of using the Offerings, you will be deemed to have read, understood and agreed to the practices and policies outlined in this Privacy Policy and agree to be bound by the same. If you use or access the Offerings on behalf of someone else or an entity (such as your employer), you represent that you are authorised by such individual or entity to accept this Privacy Policy on such individual’s or entity’s behalf, and consent on behalf of such individual or entity to our collection, use and disclosure of such individual’s or entity’s information as described in this Privacy Policy.

If you do not agree with the terms and conditions of our Privacy Policy, including in relation to the manner of collection or use of your information, please do not use or access our Offerings.

If you have any questions or concerns regarding this Privacy Policy, you should email us at: dataprivacy@reo.dev.  

Our Offerings are not in any manner intended for children under the age of 18. We do not knowingly collect any Personal Information (as defined below) from children below the above-mentioned age. If we become aware that our Database (as defined below) includes information of a User who is below the age of 18 years, we will promptly delete such information. 

THEREFORE, this Privacy Policy shall govern any and all data collection and usage thereof. Through the use of https://www.reo.dev/, you are herein consenting to the following data procedures expressed within this Privacy Policy.

1. WHAT DO WE DO

• We primarily focus on the Services, i.e., delivering valuable data and insights of the Users to our clients, while prioritizing privacy and data security. We collect business contact and related information pertaining to you (usually the kind of information that would be made available on a business card). This data allows us to analyse and identify potential customers and/or other relevant business connections for our clients, and provide them with relevant information, including contact information, to enable them to contact you and optimize their marketing spending and sales efforts.

• Our comprehensive analysis provides valuable information to our client’s marketing, sales, and community teams. By leveraging this data-driven intelligence, our clients can make informed decisions and enhance their strategies, resulting in more effective outreach and engagement with their target audience.

• Through the aggregation of de-identified data , we derive industry-level insights, including best practices and trends. These insights help businesses across various sectors better understand the market landscape and make informed decisions regarding their marketing, sales, and community engagement strategies.

2. INFORMATION WE COLLECT AND USE

• Information that we may collect or receive: We collect various types of information to create professional profiles of individuals and business profiles of companies (“Profile(s)”) stored on our database (“Database”) to provide Services to our clients. These information categories include: 

• information such as email address along with additional information, such as your name, address, telephone number (general, direct business  and/or mobile), email address, internet protocol address, current or past job history, including but not limited to job title and department, industry, professional proficiency information (such your preferred coding languages), business-related address, employment history, education background and links to social media profiles and handles (such as LinkedIn, Twitter and Facebook);

• information about Products or Services purchased by you or intended to be purchased by you and/or organisations affiliated with you; 

• information collected while providing customer support, including the voice recordings of interactions with the customer support and information you may provide by way of feedback, comments, or other communications with us; 

• geolocation information such as information about your physical location, including your IP address, obtained from geolocation features from your devices; and  

• depending on how you use our Offerings, we may also receive information from external applications you use to access our Offerings or we may receive information through various web technologies, such as Cookies (as defined below), log files, clear gifs, web beacons and any others. This information is compiled and analysed on an aggregated basis. This information may include the URL that you just came from (whether this URL is on the Website or not), which URL you next go to (whether this URL is on the Website or not), your computer browser information, your IP address, and other information associated with your interaction with the Website.

collectively referred to as “Personal Information”

2. Primary sources of information: we rely on the following sources to collect the information specified in Clause 2.1 above to create Profiles:

1. OUR CLIENTS AND THEIR REPRESENTATIVES: We may collect information from our clients and their authorized representatives, such as: (i) information that was provided to them in relation to a purchase of any Products or Services of our clients; (ii) information that was provided by our client during the registration process; and (iii) information that was provided during the interaction or communication with our clients;

2. THIRD-PARTY DATA VENDORS: We may obtain your information from third-party data vendors to help us create accurate and comprehensive profiles. Third Parties include certain data vendors and our clients, who provide us with information through licensing, sponsorship, or other agreements. For example, we provide certain services to clients in which clients authorize us to collect certain information and data to develop professional profiles that are compiled into our commercial database. We also obtain information from third-party providers, partners and integrators who gather data from a variety of sources including data co-ops or publicly available sources. 

In addition, we may collect information from clients through web-based exchanges, aggregators, and publishers that is collected from their sites and properties, which might include identifiers such as IP address, Cookie and other unique identifiers that might be considered Personal Information. The type of information collected via the identifiers might include information about online behaviour, such as pages visited, time spent on a web page, session start/stop time, whether the visitor scrolled through or clicked on an ad or webpage, and referring to a website address, that is then associated with the company identified; and

3. THROUGH FIRST-HAND RESEARCH ON PUBLICLY AVAILABLE WEB SOURCES: We conduct first-hand research on publicly available web sources to gather information that contributes to creating Profiles. This may include collecting data from publicly accessible websites, professional networking platforms, social media profiles, or other publicly available sources of information and shall include data such as information about businesses and the personnel who work or were previously employed with and other information and identifiers, such as name, title, company or business, business contact information, email address, employment history, social media data.

3. Information collected through Reo’s integrations: As part of the Services, our clients have the option to integrate our Services with various platforms. These integrations allow the transmission of information from various software that may be installed by you or our clients, for instance, the client’s CRM tools, email systems, and browser extensions. Through these integrations, we may collect information about individuals and companies and process the same to create, organize, scan, merge, and update Profiles in the Database. This helps us improve our research processes and enhances the Services provided to the clients.

4. Information collected from visitors of our Website: when the Users visit our Website, we may collect the following Personal Information sent to us by the computer, mobile and other access devices of the Users. Such Personal Information could be: (i) Device information: details about the User’s device, such as the browser type, operating system, language preference, domain name, and the time of the visit; (ii) Mobile network information: information pertaining to the User’s mobile network; (iii) IP address: User’s IP address to help us identify the device and provide a general idea of their location; and (iv) Alerts for troubleshooting: information related to alerts and notifications received during the usage, to address errors and bugs effectively; (v) Cookies and other similar technologies such as web beacons, log files, API, scripts, and e-Tag (collectively, “Cookies”) on our Website, and the client’s website and other portals. When you are using/accessing the Offerings, our servers and/or those of the client automatically records certain information that the web browser sends, such as web request, IP address, browser type, referring/exit pages and URLs, page loads and clicks, domain names, landing pages, pages viewed, time and date of use, and other information.

5. Purpose for which we collect Personal Information:

We only collect and use such information from you that we consider necessary for achieving a seamless, efficient and safe experience. We may use your Personal Information for the following purposes:

1. to provide a meaningful user experience, better usability, troubleshooting and maintenance of our Offerings;
2. to develop and improve our Offerings and such other aspects we deem necessary; 
3. to develop new products, user experiences, services, etc.;
4. for compliance and undertaking of the purchase orders/contract for our Services;
5. to understand when and which parts of our Website/Services are most visited and its frequency;
6. to identify a User;
7. to communicate with a User, including contacting and responding to queries or requests and such other communication as may be required;
8. to communicate special offers and general information about our Products, Services and events which we may offer, that may be similar to those that you have already purchased or enquired about, unless the User has opted not to receive such communication/data;
9. to offer tailored content based on Users’ preferences;
10. to enhance and optimize our Company’s operations, systems, security and processes; 
11. to enable marketing and sales related communications and purposes;
12. to protect and defend the rights or property of the Company;
13. to protect against, or defend any legal liability; 
14. to share profiles with our clients to provide Services and grant access to accurate and updated information which could be used by them for their internal sales and marketing operations. 
15. in order to be compliant with applicable law or to honour back-to-back obligations we may have with any other third party in relation to our Offerings. 
16. Activity and interactions on client’s websites, products, services, applications, etc. Reo may collect information about you based on your interactions with websites, products, services, applications, or other digital platforms owned or operated by clients or their affiliates. This may include data such as your browsing history, usage data, preferences, and engagement with specific content or features, etc.

We use the information gathered from you for the purpose of analytics and continuous improvement of our Offerings. The information received through the usage of our Offerings, feedback, or through email communication(s) is further used to improve your experience of all our Offerings. We may record any calls, training sessions, webinars or similar events that you participate in, in accordance with the applicable law. We may also track certain passive information received to improve our marketing, business analytics, and for this we may need to work with third party providers if and when we feel it is fit and necessary.

Where any service requested by you refers to any website, company or individual apart from that of the Company, such information as is reasonably necessary by the Company to carry out your service request may be shared with such third party. Third parties provide certain services which we may use to analyse the data and information you provide to personalize, drive insights and help us enhance your experience or reach out to you with more value-added services. However, these third parties do not have any independent right to share this information. 

To the extent possible, we provide you the option of not divulging any specific information that you wish for us not to collect, store or use. You may also choose not to use a particular service or feature on the Website and opt out of any non-essential communications from the Company. If you wish to opt out of our use of your Personal Information for our email marketing purposes, you can click the ‘Unsubscribe’ button located within the most recent marketing email you received from us or submit your request at dataprivacy@reo.dev.

Further, transacting over the internet has inherent risks which can only be avoided by you following security practices yourself, such as not revealing account/login related information to any other person and informing our customer care team about any suspicious activity or where your account has/may have been compromised.

Your Personal Information is also used to contact you when necessary. We use your IP address to help diagnose problems with our server, and to administer our Website. Your IP address is also used to help identify you and to gather broad demographic information. Finally, we may use your IP address to help protect our partners and ourselves from fraud. We will continue to enhance our security procedures as new technology becomes available. We will transfer information about you if we are acquired by or merged with another company. In this event, we will notify you by email or by putting a prominent notice on the Website, before information about you is transferred and becomes subject to a different privacy policy.

We may release your Personal Information to a third-party in order to comply with a court order or other similar legal procedure, or when we believe in good faith that such disclosure is necessary to comply with the law; prevent imminent physical harm or financial loss; or investigate or take action regarding illegal activities, suspected fraud, or violations of our Privacy Policy. We may disclose Personal Information in our sole discretion if we believe it is necessary or appropriate in connection with an investigation of fraud, intellectual property infringement, piracy, or other unlawful activity. In such events, we may disclose name, address, country, phone number, email address.

We may share your Personal Information with our affiliated companies, including any parent organizations, subsidiaries, and other companies that are under common ownership and control with us. These affiliates may act on our behalf for the purposes described in this Privacy Policy.

In the event that we or substantially all of our assets are acquired, or if we undergo a merger or declare bankruptcy, your Personal Information that is in our possession may be included among the transferred assets.

We may use third party vendors, service providers, including logistic service providers, payment gateway service providers, maintenance service providers, etc., to help us better provide our Offerings to you. The services they provide may include customer support, email communications, infrastructure, data storage, security services, web-hosting services, data analytics, integrating with clients’ CRM and other software, profile creation, updating and system logging. Such services may require disclosing your Personal Information to these service providers. Additionally, as necessary for managing partnerships, we may also provide deidentified data to our partners relating to the usage of products and services they provide. These third party vendors/service providers are given access to the information we collect, which may contain Personal Information, on a ‘need-to-know’ basis. To ensure the security and privacy of your information, we conduct thorough evaluations of our vendors’/service providers’ privacy and security practices before engaging them, and we mandate that they enter into agreements upholding the confidentiality of your information and adhering to data protection laws. Maintaining the security and privacy of your information remains a top priority for us.

Further, you explicitly consent to us de-identifying the information we collect so that the information cannot reasonably be identified/linked back to you or your device, or we may collect information that is already in de-identified form. Our use and disclosure of de-identified information is not subject to any restrictions under this Privacy Policy, and we may use and disclose it to others for any purpose, without limitation.

We may act as a controller or processor of the information available in the Database, depending on the purpose for which it is being stored or used.

6. Limitation of Purpose: 

1. Before or at the time of collecting Personal Information, we will identify the purposes for which information is being collected.
2. We will collect and use Personal Information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.
3. We will only retain Personal Information as long as necessary for the fulfilment of those purposes.
4. We will collect Personal Information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
5. Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up to date.

3. YOUR RIGHTS & PREFERENCES AS A DATA SUBJECT: 

This Privacy Policy is governed by your rights as per applicable law within the territory from where you access our Offerings. 

You shall also have the option to provide or deny consent for use of the Personal Information collected for the purposes mentioned in this Privacy Policy, restrict disclosure to third parties, data retention, data rectification, revoke consent already granted to collect Personal Information and if required, make us delete/anonymize the data collected by us. However, in the event of the foregoing, please note that we may not be able to provide all our Offerings efficiently to you. 

To the extent allowed under applicable law, you can exercise rights by submitting a request to the grievance officer.

4. DATA RETENTION:

We take reasonable steps to ensure that your Personal Information is available only for so long as is necessary for any purpose, or longer, if required under any applicable law, subject to appropriate safeguards. We retain the Personal Information from our Users for as long as the User’s information is likely required for us to effectively meet the User’s requests, render Services, or as long as the User’s account remains active on the Database, whichever is later. We may retain your information until such time as we may deem fit, subject to applicable law, following the last activity in your account, in order to comply with our legal and contractual obligations or to protect ourselves from any potential disputes or as long as required by laws applicable to record-keeping, and to have proof and evidence concerning your relationship with us, should any legal issues arise following the termination of your account. Additionally, we retain the information that we collect when a User exercises their right to opt-out, withdraw consent, or erasure for the duration necessary to ensure information related to such Users are removed from our Database. In such an event, we will not be able to provide you with our Offerings.

The retention periods are determined considering the quantity, nature, and sensitivity of the Personal Information, as well as the purposes for which it was collected. Once the retention period expires, we will delete the information. In cases where deletion is not feasible, appropriate measures will be implemented to prevent any further use of the information.

5. ADDITIONAL RIGHTS

In addition to the rights mentioned under the Privacy Policy, you have the right to request that we:

1. provide you with a copy of the Personal Information we hold about you;
2. update any of your Personal Information if it is inaccurate or out of date;
3. delete the Personal Information we hold about you - if you are using a product, and you ask us to delete Personal Information we hold about you then we may be unable to continue providing access to our Offerings to you;
4. restrict the way in which we process your Personal Information;
5. stop processing your Personal Information if you have valid objections to such processing; and
6. transfer your Personal Information to a third party.

6. LINKS TO OTHER WEBSITES

Our Website does contain links to other websites. The Company does not claim nor accept responsibility for any privacy policies, practices, and/or procedures of other such websites. Therefore, we encourage all users and visitors to be aware when they leave our Website and to read the privacy statements of each and every website that collects personally identifiable information. The aforementioned Privacy Policy applies only and solely to the information collected by our Website.

7. DATA SECURITY

The Company shall endeavour and shall take every precaution to maintain adequate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure or modification of the User’s Personal Information under our control. The Company also uses Secure Socket Layer (SSL) for authentication and private communications in an effort to build Users’ trust and confidence in the internet and Website use by providing simple and secure access and communication of any Personal Information.

We shall use generally accepted industry standards to protect the Personal Information of the User submitted to us, both during transmission and upon receipt. However, please be advised that, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, even though we strive to use commercially acceptable means to protect Personal Information of the User we cannot guarantee its absolute security and your use of our Offerings is at your sole risk and discretion. We also cannot warrant that such Personal Information of the User may not be misused in the event our safeguards and protocols are breached maliciously. Further, we are not liable to, nor can we fully control the actions of other users with whom you may choose to share your information.

The collection, usage, and sharing of User data by us shall be in compliance with applicable laws. If any security breach comes to our knowledge, then we may take all steps required to protect misuse of such Personal Information and may attempt to notify you electronically so that you can take appropriate steps. 

8. CHANGES TO PRIVACY POLICY

The Company reserves the right to update, modify, add, delete and/or change the terms of the  Privacy Policy, and as such we will post those change in our Website homepage at https://www.reo.dev/, so that the Users and/or visitors are always aware of the type of information we collect, how it will be used, and under what circumstances if any, we may disclose such information. To this end, we request you to go through the Privacy Policy every time you access or use the Offerings. If at any point in time we decide to make use of any Personal Information on file, in a manner vastly different from that which was stated when this Personal Information was initially collected, the User or Users shall be promptly notified by email. Users at that time shall have the option as to whether or not to permit the use of their Personal Information in this separate manner.

9. COOKIES

The Cookies are either used to improve the quality of our Offerings or for storing your preferences as a User, improving the overall User experience. You have the option of disabling Cookies via your device settings. However, if you disable Cookies, some parts of our Offerings may not function in the manner it was designed/intended to.

If you would like to disable our access to any passive Personal Information we receive from the use of various technologies, you may do so by disabling Cookies in your web browser/device, which may affect the complete use of our Offerings. Please note that we may still receive data about your usage and also your Personal Information, such as your email address. If you choose to terminate your engagement with us, we will store data about you for such period as permitted under applicable law.

10. EU, EEA, UK & US RESIDENTS: APPLICABILITY

The terms hereof shall specifically apply if you are located in the European Economic Area (EEA), Switzerland or the United Kingdom (UK) and are subject to the terms of the European Union General Data Protection Regulation 2016/679 ("GDPR"), the Data Protection Act, 2018, UK GDPR.

With regard to processing of Personal Information of certain US residents, we confirm that we do not sell, trade, or rent your Personal Information to any third party (not being customers/clients) unless you have expressly authorized us to do so, either in writing or electronically. However, we provide limited information of our clients in order to better tailor our Offerings to your needs and preferences. We do not process any Personal Information of minors.

11. TRANSFER OF DATA

In providing the use/access of the Offerings to you, you understand that we may transfer your information to different locations around the world where we have facilities or in which we engage service providers. For Users located in the United States, EEA or UK, where your personal data is transferred from the United States, EEA or UK to a recipient outside the united States, EEA or UK to a third country not recognized as providing an adequate level of protection for Personal Information, such transfer shall be covered by a framework recognized by the relevant authorities or courts as providing an adequate level of protection for Personal Information, including, but not limited to, Standard Contractual Clauses as approved by the European Commission and any applicable country addenda) or any transfer mechanism recognised by the Information Commissioner’s Office, the terms of which shall be incorporated by reference.

12. NODAL GRIEVANCE REDRESSAL OFFICER

As required under the Information Technology Act, 2000, and Rules made thereunder, and for the purposes of addressing complaints, you may contact our Nodal Grievance Redressal Officer whose name and contact details are provided below:

In the European Economic Area: contact details of EU data protection authorities can be found at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

In the United Kingdom, you can contact the Information Commissioner's Office at https://ico.org.uk/. 

13. GOVERNING LAWS 

The Privacy Policy shall be governed by the laws of the State of Delaware. 

14. ENTIRE AGREEMENT

The Privacy Policy, the Terms of Use, Work Order, Data Processing Agreement and Documentation (collectively, the “Agreement”), including any attachments, exhibits, or addenda, constitutes the entire agreement between the Parties and supersedes all prior or contemporaneous discussions, representations, agreements, or understandings, whether written or oral, regarding the subject matter of the Agreement. Neither Party has relied upon any such prior or contemporaneous communications. Words not defined herein will have the same meaning ascribed to it in the Terms of Use of Reo.

15. If you should have any suggestions or questions regarding these Terms, please contact the Company at dataprivacy@reo.dev