CleverDev Software operates as a network of affiliated legal entities that collectively deliver digital services across multiple regions. Each entity independently determines how and why personal data is processed when it is collected through this website or through direct interactions with us.
For clarity, when this document refers to “CleverDev Software,” “we,” or “our,” it describes the specific legal entity that is responsible for your personal data in a given context.
This Privacy & Data Stewardship Notice explains how we handle personal data in connection with our services and digital platforms. It also describes your privacy rights under the EU General Data Protection Regulation (GDPR), the UK GDPR and Data Protection Act 2018, and applicable US state privacy frameworks such as the California Consumer Privacy Act (as amended by the CPRA).
Rather than treating privacy as a formal obligation alone, we approach it as an ongoing responsibility to manage information ethically, transparently, and proportionately.
The personal data we process arises directly from your interactions with us or from operational contexts where your information is necessary for communication, service delivery, or recruitment activities.
When you contact CleverDev Software through our website, messaging tools, or email channels, we typically process identifiers such as your name, email address, phone number, organization, geographic location, and the substance of your message. This information exists in our systems solely to enable meaningful communication and to evaluate or respond to your request.
If you submit a job application or share a CV, we process professional identity data including employment history, academic background, skills, certifications, and other details you voluntarily include. In some recruitment scenarios, especially those involving relocation or regulated employment environments, additional information such as work authorization or immigration-related documentation may be processed where legally required.
When you browse our website, we collect operational and analytical signals generated by your device and browser. These may include IP-based location approximations, device type, browser configuration, session timing, navigation paths, and interaction patterns. This category of data is primarily generated through cookies and similar tracking technologies, which are described separately below.
We may also receive limited professional contact data from trusted third parties such as clients, recruitment platforms, or business partners where such exchange is necessary for legitimate collaboration or service coordination.
Across all categories, we apply strict data minimization principles and avoid collecting information that is not directly relevant to a defined purpose.
We process personal data only when a lawful basis under applicable privacy legislation exists, and only for clearly articulated operational purposes.
In most business interactions, personal data is processed because it is necessary to respond to requests, maintain communication, and support pre-contractual or contractual engagement. This includes handling inquiries, coordinating meetings, and providing information about our services. These activities are grounded in legitimate business interests and, where applicable, contractual necessity.
In cases where individuals interact with us in a professional capacity — such as clients, suppliers, or partners — we process data to maintain working relationships, deliver services, manage operational workflows, and ensure compliance with legal and regulatory obligations.
Where consent is required, particularly for marketing communications or non-essential tracking technologies, we rely exclusively on affirmative and voluntary consent. Consent is never assumed, bundled, or preconditioned, and it can be withdrawn at any time without affecting prior lawful processing.
Website analytics and functionality-related processing occur only to the extent necessary to maintain performance, security, and usability. Where legally required, such processing is activated only after explicit consent is granted.
Recruitment-related processing is conducted to evaluate candidates, manage hiring workflows, and assess suitability for employment. In certain regulated contexts, additional processing may occur to comply with labor, tax, or immigration requirements.
We do not repurpose personal data for unrelated or incompatible objectives.
Our website relies on cookies and comparable technologies that support essential functionality, performance analysis, and — where permitted — user experience optimization.
From a compliance perspective, we treat cookies as active data processing tools rather than passive website features. Non-essential cookies are deployed only after explicit user consent, which is collected through a clearly structured consent interface that avoids pre-selection or implied agreement.
Cookies may support functions such as remembering user preferences, measuring site performance, detecting technical issues, and analyzing aggregated usage behavior. Some cookies are operated by third-party providers acting under our instruction and subject to contractual safeguards.
Where users are located in jurisdictions recognizing global privacy signals, we make reasonable efforts to respect such signals as part of our consent management framework.
Users retain full control over cookie preferences and may modify or withdraw consent at any time.
We do not sell personal data under any circumstances.
Personal data may be shared internally within the CleverDev Software group where necessary for operational coordination or service delivery. Additionally, we engage carefully selected external service providers who support infrastructure, analytics, communication systems, and recruitment operations.
These providers operate strictly under contractual data processing agreements, which require them to follow our instructions, maintain confidentiality, and implement security measures aligned with GDPR-level expectations.
Disclosure of personal data may also occur where required by law, regulatory authorities, or court orders, or where necessary to protect legal rights, prevent fraud, or ensure system security.
Because CleverDev Software operates internationally, personal data may be transferred across borders, including to jurisdictions outside the European Economic Area and the United Kingdom.
Where such transfers occur, we apply legally recognized safeguards designed to ensure continued protection of personal data. These include standardized contractual protections approved by regulatory authorities, supplemented by additional technical and organizational security measures where necessary.
We continuously assess international transfer mechanisms in light of evolving regulatory guidance and court decisions to ensure ongoing compliance.
We do not retain personal data indefinitely or without purpose. Instead, retention is guided by necessity, proportionality, and legal requirement.
Personal data is retained only for as long as it remains relevant to the purpose for which it was collected. In practice, this means retention periods vary depending on context—ranging from short-term handling of inquiries to longer retention in recruitment or contractual environments where ongoing obligations or legal limitations apply.
At appropriate intervals, data is reviewed and either securely deleted or anonymized when it is no longer required.
Depending on applicable law, individuals interacting with CleverDev Software may exercise rights over their personal data. These rights may include access to information we hold, correction of inaccurate data, deletion under qualifying conditions, restriction of processing, objection to certain types of processing, data portability, and withdrawal of consent where applicable.
In jurisdictions such as California and other US states with modern privacy laws, individuals may also request disclosure of collected information, request deletion or correction, and opt out of certain types of data sharing. CleverDev Software does not engage in the sale of personal data.
We aim to respond to all valid privacy requests within legally required timeframes and in a transparent manner.
We apply layered technical and organizational safeguards designed to protect personal data against unauthorized access, accidental loss, alteration, or unlawful disclosure. These safeguards are continuously reviewed and adjusted in response to technological developments and emerging security risks.
CleverDev Software does not use automated decision-making systems that produce legal or similarly significant effects on individuals. Any analytical processing that occurs is limited to operational improvement and does not result in automated decisions affecting individual rights.
This Privacy & Data Stewardship Notice may be updated periodically to reflect changes in legal requirements, regulatory expectations, or internal operational practices. The most current version will always be made available on our website, with updates taking effect upon publication unless otherwise stated.
If you have questions regarding this Notice or the handling of your personal data, you may contact us using the channels provided on our website.
Where you believe that your data has been processed in a manner inconsistent with applicable law, you also retain the right to lodge a complaint with your local supervisory authority, including EU data protection authorities, the UK Information Commissioner’s Office, or relevant US state privacy regulators.
CleverDev Software Ltd.
Tel. +1 214 736 3425
E-Mail: info@cleverdev-software.com
