Date: 12^th Aug 2025

Privacy Policy

1.    Introduction

This Privacy Policy (together with our terms and conditions and any other documents referred to in it) describes the type of information that we collect from you ("you/your") through the use of DevoTrack ("we," "us," or "our") services and products ("Services"), or the use of our website https://www.devo-space.com, ("Website"), how that information may be used or disclosed by us and the safeguards we use to protect it.

Our Website and Services may contain links to third party websites that are not covered by this Privacy Policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices.

We have drafted this Privacy Policy to be as clear and concise as possible. Please read it carefully to understand our policies regarding your information and how we will treat it. By using or accessing our Website or the Services, you agree to the collection, use and disclosure of information in accordance with this Privacy Policy. This Privacy Policy may change from time to time and your continued use of the Website or the Services is deemed to be acceptance of such changes, so please check periodically for updates.

Please check back regularly to keep informed of updates to this Privacy Policy. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Website. If you do not accept and agree with this Privacy Policy, you must stop using our Website immediately.

You have the right to make a complaint at any time,  so please contact us in the first instance on [Email Address ]. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

If you have any comments on this Privacy Policy, please email them to on [Email Address].

2.    Who We Are

2.1 Here are our details:

-        Our Website address is https://www.devo-space.com,

-        Our trading name is DevoTrack, Commercial Registration No.     , issued    and our trading address is                   [aJ1] .   

2.2 We respect your right to privacy and will only process personal information about you or provided by you in accordance with the applicable Data Protection Legislation in any jurisdictions where we operate, including the Egyptian Personal Data Protection Law (Law No. 151 of 2020) and its Executive Regulations and as amended or updated from time to time (“DP Regulation”).

3.    What we may collect

3.1     Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

 

3.2     We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

·       Identity Data includes first name, last name, username or similar identifier. When you email, phone, live chat or otherwise, we may collect information such as your first name, last name, email address and phone number.

·       Contact Data includes billing address, invoicing address, email address and telephone numbers.

·       Financial Data includes bank account and payment card details.

·       Transaction Data includes details about payments and other details of our Services you have purchased from us.

·       Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.

·       Profile Data includes your username and password, reservations made by you, your interests, preferences, feedback and survey responses.

·       Usage Data includes information about how you use our Website and Services.

·       Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

·       Interaction Data includes any information that you might provide to any discussion forums on the Website.

·       Cookies Data like many websites, we use "cookies" to enhance your experience and gather information about visitors and visits to our websites. Please refer to the "Do we use 'cookies'?" section below for information about cookies and how we use them and what kind.

·       Third Parties and Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or through the Services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Website. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers, and search information providers) and may receive information about you from them.

·       Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Website and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

 

3.3     we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

a) You have given consent to the processing of your personal data for one or more specific purposes;

b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;

c) processing is necessary for compliance with a legal obligation to which we are subject;

d) processing is necessary to protect the vital interests of you or of another natural person;

e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or

f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.

3.4     If you provide personal information to us about another data subject, you are responsible for ensuring that you have their consent to provide that data for the uses set out in this Privacy Policy and for bringing this Privacy Policy to their attention.

 

4.    How We May Collect And Use Your Data

4.1     We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through:

 

Direct interactions. You may give us your information by filling in forms via our Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

a) present Website content;

b) use any of our Services;

c) create an account on our Website;

d) subscribe to our Services or publications;

e) request marketing to be sent to you;

f) enter a competition, promotion or survey; or

g) give us some feedback.

4.2     In addition to the above, we may use the information in the following ways:

a) To personalize your Website experience and to allow us to deliver the type of content and product offerings in which you are most interested.

b) To administer a contest, promotion, survey or other site feature.

c) If you have consented to receive our e-mail newsletter, we may send you periodic e-mails. If you would no longer like to receive promotional e-mail from us, please refer to the “How can you opt-out, remove or modify information you have provided to us?” section below. If you have not opted-in to receive e-mail newsletters, you will not receive these e-mails. Visitors who register or participate in other site features such as marketing programs and ‘members-only’ content will be given a choice whether they would like to be on our e-mail list and receive e-mail communications from us.

d) Present Website content effectively to you.

e) Provide information, and services that you request, or (with your consent) which we think may interest you.

f) Carry out our contracts with you.

g) Provide the relevant Services to you

h) Tell you our charges.

4.3     If you are already our customer, we may contact you electronically about things similar to what was previously sold to you.

4.4     If you are a new customer, you will only be contacted if you agree to it.

4.5     We may keep a record of those links which are used the most to enable us to provide the most helpful information but we agree to keep such information confidential and you will not be identified from this information.

4.6     In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section, you can let us know at any time by contacting us at Info@devotrack.com , and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible products and services to you.

4.7     In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you if you don't provide your personal data in these cases.

4.8     We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

a) Where we need to perform the contract we are about to enter into or have entered into with you.

b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

c) Where we need to comply with a legal or regulatory obligation.

4.9     Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to our marketing communications or sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at Info@devotrack.com, and we will either delete your data from our systems or move your data to our "unsubscribe list". However, you acknowledge this will limit our ability to provide the best possible services to you.

4.10 As already indicated above, with your permission and/or where permitted by law, we may also use your data for marketing purposes which may lead to us contacting you by email and/or telephone with information, news and offers on our Services. We agree that we will not do anything that we have not agreed to under this Privacy Policy, and we will not send you any unsolicited marketing or spam. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under DP Regulation and as amended.

5.    Cookies

5.1     We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

 

5.2     We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

 

5.3     We use cookies to distinguish users and improve our Website. Please look at our Cookie Policy [Insert Link] for more cookie information.

6.    Where We Store Your Data And Security

6.1     We may transfer your collected data to storage outside Egypt or any applicable jurisdiction where we operate (“Country”). It may be processed outside Country to fulfil your order and to receive our Services and Products and deal with payment. If we do store or transfer data outside the Country, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within Country and under DP Regulation. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage with and the use of approved Model Contractual Arrangements. Your acceptance of this Privacy Policy shall be your consent permitting us to store or transfer data outside the Country if it is necessary for us to do so.

 

6.2     Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

6.3     We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

6.4     By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.

6.5     Any payments made by you, will be encrypted.

6.6     We have implemented security measures such as a firewall to protect any data and maintain a high level of security.

6.7     Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.

6.8     If we give you a password upon registration on our Website, you must keep it confidential. Please don't share it.

7.    How Long Do We Keep Your Information?

7.1     We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

7.2     When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7.3     We ensure that all retention and deletion procedures comply with DP Regulation and any sector-specific data retention requirements applicable within Egypt or any other applicable jurisdiction.

 

8.    Disclosing Your Information

8.1     We are allowed to disclose your information in the following cases:

8.1.1      If we want to sell our business, or our company, we can disclose it to the potential buyer.

8.1.2      We can disclose it to other businesses in our group.

8.1.3      We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety or rights.

8.1.4      We can exchange information with others to protect against fraud or credit risks.

8.2     We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data.

8.3     Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under DP Regulation. Any third party that we share data with will not be permitted to use it for any other purpose than fulfilling their contract with us.

9.    How Do We Handle Your Social Logins?

 

9.1     Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

 

9.2     We will use the information we receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their Privacy Policy to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

10.                   Do We Collect Information From Minors?

10.1 We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at Info@devotrack.com.

 

11.                   Controls For Do-Not-Track Features

 

11.1 Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.

 

11.2 At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

12.                   How Can You Contact Us About This Privacy Policy?

12.1 If you have any questions, requests, or concerns about this Privacy Policy or our data-processing practices, you may contact us through either of the following methods:

By Email: Info@devotrack.com

By Post:

[Full Legal Name of Company]
[Full Postal Address]

13.                   How Can You Review, Update, Or Delete The Data We Collect From You?

13.1 In accordance with DP Regulation, you have the right to:

13.1 Access Your Data – Request confirmation as to whether we process your personal data and obtain a copy of such data.

13.2 Rectify Inaccuracies – Request the correction of any incomplete, inaccurate, or outdated personal data.

13.3 Erase Your Data – Request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you have withdrawn your consent, and no other lawful ground exists for its continued processing.

13.4 Withdraw Consent – Withdraw your consent to our processing of your personal data at any time, without affecting the lawfulness of processing carried out prior to such withdrawal.

Please note that these rights may be subject to certain legal limitations or exemptions under DP Regulation.

To exercise any of the above rights, you may submit a Data Subject Access Request by contacting us via:
Email: privacy@devotrack.com
Post: [Insert Company Address]

We will respond to your request within the timeframes prescribed by DP Regulation.

14.                   Your Rights

14.1 When you submit information via our Website, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided above in this Privacy Policy.

14.2 Under the DP Regulation, you have the right to:

·       request access to, deletion of or correction of, your personal data held by us at no cost to you;

·       request that your personal data be transferred to another person (data portability);

·       be informed of what data processing is taking place;

·       restrict processing;

·       to object to processing of your personal data; and

·       complain to a supervisory authority.

14.3 You also have rights with respect to automated decision-making and profiling as set out herein.

14.4 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.

14.5 To enforce any of the foregoing rights or if you have any other questions about our Website or this Privacy Policy, please contact us at Info@devotrack.com.

15.                   Links To Other Sites

15.1 Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our Website. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

16.                   Changes

16.1 We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification via your registered email to US. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information. Continued use of our Website and Services following the publication of any amendments will constitute your acceptance of the updated Privacy Policy.

17.                   Terms And Conditions

17.1 You are required to comply at all times with our applicable policies, including, but not limited to:

·       the Cookies Policy,

·       the Website Terms of Use,

·       the Non-Disclosure Agreement, and

any other policies, guidelines, or rules that we may publish from time to time.

You acknowledge and agree that these policies may be updated, amended, or supplemented periodically at our sole discretion, and your continued use of our website constitutes acceptance of any such modifications.

 

18.                   Your Agreement

18.1 By accessing or using our Website, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy, as well as any other applicable terms, conditions, and policies referenced herein. If you do not agree, you must immediately discontinue use of our Website.

 

19.                   Dispute Resolution

19.1 We will use our best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy Policy or any breach of it.

19.2 Any dispute shall not affect our ongoing obligations under this Privacy Policy.

19.3 This Privacy Policy and any dispute or claim relating to or connected with it shall be governed by and construed in accordance with the laws of Egypt and any other applicable jurisdictions where we may operate,  the courts of Cairo, Egypt are the only place where disputes or claims relating to or connected with this Privacy Policy may be decided.