[ LEGAL ]
Privacy Policy
This Privacy Policy explains what personal information AAS Devel LLC (“AAS Devel”, “we”, “us”) collects through the website at https://aasdevel.com and in our dealings with you as a visitor, a prospective or current client, or a job applicant, and how we use and protect it. We do not sell your personal information.
Information we process for our clients is not covered by this policy. When we deliver software, cloud, data or AI services, our client controls the personal information in its environments and we act on its instructions, under our services agreement and data processing terms with that client. If you believe your information is held in an environment we support for a client, please contact that client directly.
If we update this policy, we will change the date above. If the changes are significant, we will say so on this page and, where the law requires, tell you directly.
1. What personal information we collect
Depending on how you deal with us, we may collect:
- Identity data: your name, job title and the company you represent.
- Contact data: your business email address, telephone number and postal address.
- Enquiry data: what you tell us when you contact us, such as the services you are interested in, when you would like to start, your message, and anything you send by email or share in a call or meeting.
- Technical data: your IP address, browser type and version, operating system, the pages you request and the time of each request, as recorded in our server logs.
- Communication data: our correspondence with you and your preferences about hearing from us.
- Contract and billing data, if you engage us: names and contact details of signatories and billing contacts, billing address, purchase order references and payment records.
- Application data, if you apply for a role: your CV and what it contains, such as education and work history, portfolio or repository links, references, technical assessment results and work authorisation status.
We do not ask for sensitive personal information, such as health information or government identification numbers. Please do not send it through our project form or by email.
2. How we collect it
- Directly from you, when you send the form on our Start a project page, email us at hello@aasdevel.com or careers@aasdevel.com, call or meet us, or sign an agreement with us.
- From others, such as people who refer you to us, professional networking platforms like LinkedIn where you have made your professional information public, and public business sources.
- Automatically, when our servers record technical data for each page request. Section 3 explains what this website stores in your browser.
4. How and why we use it
Where the law allows, we use personal information:
- to reply to your enquiry and tell you about our services;
- to prepare proposals, estimates, statements of work and contracts;
- to deliver the services we agree to provide, and to manage invoices and payments;
- to manage our relationship with you, including telling you about changes to our terms or this policy;
- to run, secure and protect our website and business, including preventing spam, fraud and abuse, troubleshooting, and keeping records;
- to comply with the law and with lawful requests from authorities, and to establish or defend legal claims;
- to send you news, articles and invitations about our work, where the law allows (see Section 8); and
- to assess job applications and contact you about the hiring process.
We keep records of enquiries and client relationships in our own customer relationship management (CRM) tool, which we operate ourselves.
We do not use personal information you send us to train AI models, and we do not enter it into third-party AI services.
5. Who we disclose it to
- Our affiliated engineering company in Yerevan, Armenia, whose team delivers our services, for the purposes described in this policy. See Section 6.
- Service providers acting on our behalf. We host this website and our CRM on servers we operate ourselves, and our business email is provided by Microsoft (Exchange). Other providers, such as accountants, payment providers and professional advisers, may support us under confidentiality and data protection terms.
- Subcontractors who help deliver a client engagement, under written confidentiality and data protection terms and only with the information they need.
- Authorities, regulators, courts and professional advisers, where the law requires it or to protect our legal rights.
- A buyer or successor, if we sell, merge or reorganise our business, in line with applicable law.
- Anyone else at your request or with your consent.
We do not sell personal information, and we do not share it for advertising.
6. International transfers
AAS Devel LLC contracts with clients in the United States, and our engineering team works from Yerevan, Armenia. Your personal information may therefore be accessed, stored or processed in the United States, in Armenia, and in other countries where our service providers operate.
When we transfer personal information out of a country that restricts such transfers, we put appropriate safeguards in place. For transfers from the European Economic Area, the United Kingdom or Switzerland, see Section 3 of the EEA+ Privacy Notice.
7. How we protect it
We use technical, physical and organisational measures that match the risk. These include encryption in transit (this website is served only over HTTPS), multi-factor authentication on company email and cloud accounts, and access to personal information limited to the people who need it for their work.
No security measure is perfect, so we cannot guarantee that information will never be accessed without authorisation. We have procedures for handling a suspected breach, and we will notify you and the relevant regulator where the law requires it.
8. Marketing emails
We may send news, articles or event invitations to business contacts. We do this only with your consent where the law requires it, and otherwise on the basis of our legitimate interest in keeping in touch with the people we work with. Every marketing email includes a way to unsubscribe, or you can email privacy@aasdevel.com. Unsubscribing does not stop the messages we need to send you about an enquiry or an engagement.
9. Your privacy rights
Depending on where you live, you may have the right to access, correct or delete personal information we hold about you, to object to or restrict how we use it, to receive a copy in a portable format, and to withdraw your consent. To make a request, email privacy@aasdevel.com. We may need to confirm your identity before we act on it.
- If you live in a US state with a comprehensive privacy law, our US State Privacy Notice also applies to you.
- If you are in the European Economic Area, the United Kingdom or Switzerland, our EEA+ Privacy Notice also applies to you.
- If you are in Armenia, the Law of the Republic of Armenia on Protection of Personal Data may also give you rights.
If you choose not to give us certain information, or you withdraw your consent, we may not be able to respond to you or provide our services.
10. Children's privacy
Our website and services are for businesses and business professionals, not children. We do not knowingly collect personal information from children under 16. If we learn that we have, we will delete it promptly. If you are a parent or guardian and think your child has given us personal information, email privacy@aasdevel.com.
11. How long we keep it
We keep personal information only as long as we need it for the purposes above, or longer where the law requires it.
| Information | Kept for |
|---|---|
| Enquiries that do not lead to an engagement | 24 months after our last contact |
| Client contract, billing and project records | As long as tax and accounting law requires, typically 7 years after the engagement ends |
| Marketing preferences | Until you unsubscribe; we then keep only what we need to make sure we do not email you again |
| Applications that do not lead to a role | 12 months |
| Server logs | Up to 90 days |
We may keep information longer where we have a legal right or duty to, for example during a dispute.
12. Other websites
We are not responsible for websites we link to, such as our LinkedIn, Instagram and Facebook pages. Your use of those sites is governed by their own policies, so please read them before you share personal information there.
13. Contact us
- Privacy requests
- privacy@aasdevel.com
- Job applications
- careers@aasdevel.com
- Postal mail
- AAS Devel LLC, Attn: Privacy Team, 16192 Coastal Highway, Lewes, Delaware 19958, United States
[ SUPPLEMENTAL NOTICE ]
US State Privacy Notice
Some US states give their residents specific privacy rights. This notice supplements our Privacy Policy for residents of those states and includes our notice at collection under California law. It does not cover processing that falls under an exception in the applicable law, including exceptions for some business-to-business and employment information.
1. California residents
What we collect, why, and who receives it
In the past 12 months we have collected the following categories of personal information directly from California residents who use our website, contact us, engage us or apply for a role.
| Personal information | Category under California law | Why we collect it | Disclosed to | Kept for |
|---|---|---|---|---|
| Name, job title, company, business email, telephone number, postal address | Identifiers; customer records | To reply to enquiries, tell you about our services, prepare proposals and contracts, manage our relationship and protect our business | Our affiliate and our service providers | 24 months after our last contact, unless you become a client |
| Form contents, messages and files you send us; your preferences about hearing from us | Commercial information | To reply to enquiries, understand what may interest you, and send news where the law allows | Our affiliate and our service providers | 24 months after our last contact, unless you become a client |
| Contract, billing and payment records; signatory and billing contact details | Identifiers; customer records, including financial information; commercial information | To deliver services, manage payments, comply with the law and defend our interests in a dispute | Our affiliate, our service providers, authorities and professional advisers | Typically 7 years after the engagement ends |
| IP address, browser, operating system, pages requested and times | Identifiers; internet or other electronic network activity | To run, secure and protect our website | Our service providers | Up to 90 days |
| CV and application details, such as work history, portfolio links and assessment results | Professional or employment-related information; education information | To assess applications, manage the hiring process and contact you about it | Our affiliate and our service providers | 12 months if the application does not lead to a role |
We do not sell personal information, and we do not share it for cross-context behavioural advertising. We do not use or disclose sensitive personal information for any purpose other than those the law permits.
Your rights
- Right to know and access: to ask what personal information we have collected about you, and for a copy of it.
- Right to delete: to ask us to delete personal information we collected from you, subject to legal exceptions.
- Right to correct: to ask us to correct inaccurate personal information.
- Right to limit the use of sensitive personal information: we only use it as the law permits, so there is nothing to limit.
- Right to opt out of sale or sharing: we do not sell or share personal information, so there is nothing to opt out of.
We will not discriminate against you for exercising these rights. We will not deny you services, charge you different prices or give you a different level of service.
2. Residents of other states
If you live in Virginia, Colorado, Connecticut, Utah or another state with a comprehensive privacy law, you may also have the right to access, correct and delete your personal information. You may also have the right to opt out of targeted advertising, the sale of personal information, and profiling that has legal or similarly significant effects. We do none of these. Depending on where you live, you may not have every right listed here.
3. How to make a request
Email privacy@aasdevel.com with “Privacy request” in the subject line, or write to AAS Devel LLC, Attn: Privacy Team, 16192 Coastal Highway, Lewes, Delaware 19958, United States. Tell us what you would like to access, correct or delete.
We may need to confirm your identity first and may ask for more information to do so. We respond within the time the law requires; if we need longer, we will tell you why in writing. We may refuse a request, or meet it only in part, where the law allows; if we do, we will explain why.
You can ask an authorised agent to make a request for you. The agent must give us your signed permission, and we may still ask you to confirm your identity directly.
Appeals: if you disagree with our decision on your request, you may appeal. Our reply to your request will explain how.
4. Contact
Questions about this notice: privacy@aasdevel.com, or AAS Devel LLC, Attn: Privacy Team, 16192 Coastal Highway, Lewes, Delaware 19958, United States.
[ SUPPLEMENTAL NOTICE ]
EEA+ Privacy Notice
This notice applies if you are in the European Economic Area, the United Kingdom or Switzerland (“EEA+”). It supplements our Privacy Policy with the information the General Data Protection Regulation and the UK GDPR (together, “GDPR”) require. In this notice, “personal data” means the same as personal information.
1. Who is responsible for your personal data
AAS Devel LLC is the controller of your personal data for the processing described in our Privacy Policy.
2. Our legal bases
We rely on these legal bases under the GDPR: performance of a contract, or steps you ask us to take before entering one; compliance with a legal obligation; our legitimate interests, weighed against your rights and interests; and your consent.
| Purpose | Legal basis |
|---|---|
| Replying to your enquiry and preparing proposals | Steps you ask us to take before a contract. Where you enquire for an organisation, our legitimate interest in developing business relationships. |
| Managing our relationship with you, including telling you about changes to our terms or this policy | Legal obligation, where the law requires us to respond. Otherwise, our legitimate interest in keeping our records up to date and improving our services. |
| Delivering services, invoicing and collecting payments | Performance of our contract. Collecting amounts owed: our legitimate interest. |
| Running, securing and protecting our website and business, including server logs and spam prevention | Legal obligation, where data security law requires it. Otherwise, our legitimate interest in running our business securely and preventing fraud and abuse. |
| Sending news, articles and invitations | Your consent, where the law requires it. Otherwise, our legitimate interest in keeping in touch with business contacts. |
| Assessing job applications | Steps you ask us to take before a contract, and our legitimate interest in assessing candidates. Keeping your details for future roles: your consent. |
| Complying with the law and establishing or defending legal claims | Legal obligation, or our legitimate interest in protecting our legal rights. |
| Disclosing personal data to our affiliate and service providers for the purposes above | The legal basis of the purpose the disclosure serves. |
| Disclosing personal data in a sale, merger or reorganisation of our business | Our legitimate interest in carrying out the transaction, where your interests do not override it. Otherwise, your consent. |
| Disclosing personal data to courts, law enforcement or regulators | Legal obligation, or our legitimate interest in preventing unlawful conduct and protecting our legal rights. |
3. International transfers
We transfer personal data to our affiliate and service providers outside the EEA+, including to the United States and to Armenia. Where the European Commission or the UK Government has found that a country provides adequate protection, the transfer relies on that adequacy decision.
Armenia does not have an adequacy decision. For transfers to Armenia, and to any other country without one, we use Standard Contractual Clauses approved under the GDPR, supported by a transfer impact assessment and any additional safeguards it shows are needed, or another transfer mechanism the GDPR permits. You can ask for a copy of these safeguards by emailing privacy@aasdevel.com.
4. How long we keep personal data
See Section 11 of our Privacy Policy. We may keep personal data longer to comply with the law or in the event of a complaint or legal claim.
5. Your rights
- Access: to receive a copy of your personal data and information about how we use it.
- Correction: to have incomplete or inaccurate personal data corrected.
- Erasure: to have your personal data deleted where there is no good reason for us to keep it. Where we cannot, for legal reasons, we will tell you.
- Objection: to object to processing based on our legitimate interests, where your particular situation makes you want to.
- Restriction: to ask us to pause processing, for example while we check the accuracy of your data or assess an objection.
- Portability: to receive personal data you gave us, in a structured, machine-readable format, or have it sent to someone else, where we process it on the basis of consent or a contract.
- Withdrawing consent: at any time, where we rely on your consent. This does not affect processing before you withdrew it.
To use any of these rights, email privacy@aasdevel.com. We would like the chance to resolve any concern first, but you always have the right to complain to your data protection authority.
6. Your choices
You do not have to give us personal data. If you do not, we may not be able to reply to your enquiry or provide our services.
7. Contact
Email privacy@aasdevel.com, or write to AAS Devel LLC, Attn: Privacy Team, 16192 Coastal Highway, Lewes, Delaware 19958, United States.