The purpose of this privacy policy (the “Privacy Policy”) is to clearly and accurately inform the users (the “Users”) of the website hosted under the domain devengo.com (the “Website”) about the processing of personal data collected by DEVENGO, S.L. (hereinafter, “DEVENGO”) through the aforementioned Website.
This Privacy Policy applies exclusively to the Website, which includes all dependent subdomains, pages, and subpages that DEVENGO makes available to Users. DEVENGO shall not be held responsible for the privacy and personal data protection policies that may be contained on third-party websites accessed by Users through hyperlinks on this Website and which are not directly managed by DEVENGO.
This Privacy Policy applies to information collected by DEVENGO through the Website, for example, via forms or browsing activity.
In accordance with applicable regulations, DEVENGO informs Users that the data provided through the Website will be incorporated into its data files, for which it is responsible.
By filling in the forms or providing information during the provision of services, Users acknowledge and unreservedly accept this Privacy Policy. For this reason, Users are advised to carefully read this Privacy Policy beforehand.
Identity and contact details of the data controller
DEVENGO, S.L. is a company with registered office at Calle Barquillo 40, 1º derecho, Madrid, with Tax ID (CIF) B-88353412, registered in the Mercantile Register of Madrid, Book 39.112, folio 9, Sheet M-694.923.
Contac email: [email protected]
Data Protection Officer (DPO): [email protected]
Data required for certain processing
Providing the data requested in the Website’s forms is voluntary for Users, although omission of certain data may prevent access to specific services provided by DEVENGO.
Users shall, in all cases, be responsible for the truthfulness, accuracy, validity, and authenticity of the personal data provided, and DEVENGO reserves the right to exclude from registered services any Users who have provided false information, without prejudice to any other legal actions that may apply.
Information collected from Users
DEVENGO processes the following personal data from Users:
- Identification data, such as first name and surname(s).
- Contact information, such as email address, postal address, or telephone number.
Additionally, DEVENGO collects and stores data obtained through the Website using tools such as cookies, which gather information about the User’s browsing activity.
If you contract our services, the processing of data relating to the provision of payment services and account ownership verification shall be governed by the service agreement and its specific privacy conditions.
Purposes and legal basis for processing
DEVENGO processes your personal data lawfully, basing each processing activity on the corresponding legal basis under the General Data Protection Regulation (GDPR).
We process your data for the provision of payment services, which includes the execution of payment orders, verification of bank account ownership, and general management of contracted services. The legal basis for this processing is the performance of the service contract entered into with DEVENGO.
We also process your data to comply with legal obligations applicable to our activity, particularly in matters of anti-money laundering (AML) and counter-terrorist financing (CTF), tax regulations, and requirements under payment services regulation (PSD2). The legal basis is compliance with such legal obligations.
To ensure transaction security and prevent fraud, we perform identity checks and transaction monitoring. This processing is based on our legitimate interest in protecting both DEVENGO and our Users from fraudulent activities, as well as compliance with legal obligations.
We also process data provided through our Website forms to manage commercial requests, job applications, and information inquiries. This processing is based on the User’s consent or on the application of pre-contractual measures requested by the User.
Regarding information obtained through cookies and similar technologies, such as pixels or code snippets, that enable data storage and retrieval, the legal basis is consent as defined by applicable regulations and guidance issued by the Spanish Data Protection Agency (AEPD) at the time of drafting this Privacy Policy, as well as DEVENGO’s legitimate interest in ensuring the proper functioning of the Website’s features.
User consent
By accepting the legal notice, the cookie policy, and this Privacy Policy, the User acknowledges having read and understood the terms and conditions of use, as well as the legal provisions set forth herein, and expressly and unequivocally accepts their application to the use of the Website during browsing and the provision of the corresponding services.
Users expressly declare that they have been informed of and authorize DEVENGO to collect and process their data for the purposes described in this Privacy Policy.
Users must notify DEVENGO of any changes to the data provided and shall remain responsible at all times for the accuracy and truthfulness of such data. DEVENGO reserves the right, without prejudice to other actions available to it, to withhold services or cancel the registration of Users who provide false or incomplete data, or who share photographs not permitted under law or morality. The foregoing shall not imply any liability on the part of DEVENGO for damages arising from the falsity or inaccuracy of the data provided, for which the User shall be solely responsible.
Data disclosure and international transfers
Personal data collected through the Website will not be transferred to third parties for their own use, except in cases where the User has given consent for such processing.
However, Users’ personal data may be accessible to DEVENGO’s authorized staff and to other third parties or partners providing services on behalf of DEVENGO, for the purpose of managing the provision of services, contractual and/or pre-contractual relationships with Users, or handling Users’ requests. Where access to data by collaborating companies is permitted, such access shall be governed by the corresponding contract, as required by applicable law.
DEVENGO may also disclose personal data in cases where such transfer is legally established or required by applicable regulations, or when requested by competent authorities.
Data retention periods
DEVENGO will retain Users’ personal data as long as necessary for the purposes for which it was collected and in accordance with the applicable legal basis. DEVENGO will keep personal data for as long as there is a contractual and/or commercial relationship with the User and until the User exercises their right to object and/or request deletion of their personal data.
In such cases, DEVENGO will duly block the data, refraining from using it, while it remains necessary for the exercise or defense of claims or while any legal, judicial, or contractual liability may arise requiring its retention.
User rights
At any time, Users may exercise their rights of access, rectification, erasure, objection, portability, and right to be forgotten through the following rights-exercise link, or by writing to the contact email provided for this purpose: [email protected], attaching a copy of their passport or identity document (of the data subject) and explicitly indicating in the subject line the request they wish to make:
- Access: Through the exercise of this right you can know which of your personal data is being processed by DEVENGO; its purpose, origin, or possible transfer to third parties.
- Rectification: You may modify your personal data that are inaccurate or incomplete, specifying in the request which data you wish to be modified.
- Cancellation: Allows the cancellation of your personal data as inadequate or excessive.
- Opposition: The right to object means that you can oppose the processing in certain cases or for a specific purpose, for example, in the hypothetical case that your data are used for advertising and commercial prospecting activities or if the purpose of the processing is to take a decision concerning you based solely on automated processing of your personal data.
- Portability: You will be able to receive your personal data provided in a structured, commonly used and machine-readable format, and transmit it to another data controller, provided that it is technically possible.
- Forgetfulness: You may request the deletion of personal data without due delay when any of the cases mentioned above occur. For example, unlawful data processing, or when the purpose for which the data was processed or collected has disappeared.
Use of cookies
The Website uses cookies as well as other technological devices in order to provide certain services and functions, as well as to help Users improve their online experience. We recommend that Users read carefully our Cookie Policy to be informed about the responsible use that DEVENGO makes of them and about the options they have to configure their browser and manage cookies.
Modification of the Privacy Policy
DEVENGO may update this Privacy Policy when necessary to adapt it to regulatory changes, new services, or improvements in information transparency.
Any change will be published on this page with an indication of the date of the latest update. If the changes are significant and affect your rights, we will notify you via the email provided or through a prominent notice on our Website.
We recommend periodically reviewing this policy to remain informed about how we protect your data.
Security measures
DEVENGO processes Users’ personal data with absolute confidentiality and has implemented appropriate technical and organizational measures to ensure data security and prevent destruction, loss, unlawful access, or improper alteration. These measures have been established considering the scope, context, and purpose of the data processing, the state of technology, and the associated risks.
DEVENGO shall treat your personal data as absolutely confidential. It has also implemented appropriate technical and organisational measures, according to the type of data collected, to ensure the security of your personal data and prevent its destruction, loss, illicit access, or unlawful alteration. In determining these measures, criteria such as the scope, context, and purposes of the processing, the state of the art, and the risks involved were taken into account.
If you have any questions about our Privacy Policy, please contact us by sending an e-mail to [email protected]. Likewise, if you consider that your rights are not duly addressed, you have the right to file a complaint with the Spanish Data Protection Agency, whose contact details are: Telephone: 900 293 183; Postal Address: C/ Jorge Juan, 6 28001-Madrid; Electronic Headquarters: https://sedeaepd.gob.es/sede-electronica-web/ and web page: and web page: www.agpd.es
