devgrowthlab

This privacy policy sets out how devgrowthlab uses and protects your personal data.

1. Important information and who we are

This privacy policy gives you information about how devgrowthlab collects and uses your personal data through your use of this website, including any data you may provide when you register and subscribe with us. For details of how you can contact us please go to the contact details section below (paragraph 10).

This website is not intended for children, and we do not knowingly collect data relating to children.

Controller

devgrowthlab is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (9), please see information set out in the contact details section (10) below.

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We collect personal data from users of our website and customers:

From users: Name, email, billing address, company name (if applicable). This data is shared between devgrowthlab and Paddle in a Controller-Controller relationship in order to provide the service to the user. Paddle are a third party organisation that processes payments made by you, devgrowthlab does not collect or store payment information.

When signing in: Cookies. Cookies are only used to provide the service, to store the sign-in details temporarily to authenticate customers use of the online portal. Please see our cookie policy for more details here

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

Use of AI/ML on user data: Machine learning models are used to detect unusual changes in retention patterns and to generate email alerts. All processing occurs on anonymised, aggregated datasets and no personal data is processed as part of this.

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, business name, tax identifier, company number, username or similar identifier.
Contact Data includes billing address and email addresses.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes 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.
Usage Data includes information about how you interact with and use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account to enable access to our online platform and website;
- subscribe to our service or publications;
- request marketing to be sent to you; or
- give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using server logs and other similar technologies.
Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
- Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Paddle.com Market Ltd [inside the UK], Paddle Payments Ltd [outside the UK], and Paddle. com Inc [outside of the UK].

How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract, we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose / Use	Type of data	Legal basis
To register you as a new customer	Identity & Contact	When you sign up for our services, we collect information such as your name, company name, and contact details (including your email address). We process this information so that we can create and manage your account, communicate with you about your subscription, and provide you with access to our platform. Our lawful basis for this processing is the performance of a contract: we need this data to deliver the services you have requested. We will retain this data for up to 6 years after you cease being a customer, as required for tax, legal, and accounting purposes.
To process and deliver your order including: Manage payments, fees and charges Collect and recover money owed to us	Identity, Contact & Transaction	When you purchase services from us, we collect information such as your name, company name, billing address, email address, and transaction details. We process this information so that we can manage payments, issue invoices, handle any billing enquiries, and recover any outstanding amounts owed to us. Our lawful bases for this processing are the performance of a contract: we need this information to process your payments and deliver the services you have requested; and our legitimate interests: to recover any debts if payments are overdue. We will retain this information for up to 6 years after your account is closed, in order to comply with legal, tax, and accounting requirements.
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity, Contact & Technical	When we administer and protect our business and this website, we collect information such as your name, contact details, and technical data, including your browser type, and usage information. We process this information so that we can troubleshoot issues, perform data analysis and testing, maintain and improve our systems, provide support, generate reports, host data securely, prevent fraud, and manage any business reorganisations or group restructuring exercises. Our lawful bases for this processing are our legitimate interests: to run our business efficiently, provide administration and IT services, ensure network and information security, and prevent fraud; and compliance with a legal obligation, for example, to maintain records required by law. We will retain this information for up to 90 days.
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity, Contact, Usage, Marketing and Communications & Technical	When you visit our website, we may collect information such as your browser type, device, location (e.g., country), and pages you visit. We process this information so that we can deliver content and online advertisements that are relevant to you, and to measure or understand the effectiveness of the advertising we serve. For example, we may show product suggestions based on the sections of the site you have visited or track which ads lead to clicks. Our lawful basis for this processing is our legitimate interests: we aim to provide a more useful and engaging experience for our users and to ensure our advertising is effective. We will retain this information for up to 90 days.
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectivenessof our communications and marketing	Technical & Usage	We collect information about how you interact with our website, products, services, and communications, including feature usage, pages visited, and responses to emails or notifications. We process this information to improve our website, products, and services, enhance customer relationships and experiences, and measure the effectiveness of our communications and marketing. For example, we may identify which features are most popular or adjust messaging to make it more useful. Our lawful basis for this processing is our legitimate interests: analysing this information allows us to improve our offerings and provide a better experience for our customers. We will retain this information for up to 90 days.
To carry out market research through your voluntary participation in surveys		From time to time, we may invite you to participate in surveys to collect feedback about our products, services, or website. Participation is entirely voluntary. We process this information to carry out market research, understand customer needs, and identify areas where we can improve our offerings. For example, we may ask for your feedback on new features or the overall user experience. Our lawful basis for this processing is our legitimate interests: gathering feedback helps us improve our products and services and better meet the needs of our customers. We will retain survey responses for up to 1 year.

Cookies

Cookies are small pieces of information, normally consisting of just letters and numbers, which online services provide when users visit them. Software on the user’s device (for example a web browser) can store cookies and send them back to the website next time they visit.

We only use cookies that are essential for the operation of our website and online portal. These cookies are strictly necessary to keep you signed in securely and to provide the services you have requested and are only created once you are signed in. They are temporary and automatically deleted when you close your browser. Please see our cookie policy for more details.

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

External Third Parties for:
- Third-party data processors:
  - Payments processing: Paddle (in accordance with their Data Processing Addendum)
  - Data storage in the EU and email processor: Azure (in accordance with the Microsoft Products and Services Data Protection Addendum (DPA)))
  - Content delivery, security, and performance: Cloudflare (in accordance with their Data Processing Addendum)
  - Email hosting and internal communications: Google Workspace (used for our support email and document management, in accordance with the Google Data Processing Addendum)
Transfers between entities: all customer accounts and data will be transferred to a successor entity in the event of a business sale, restructuring, or incorporation into a limited company
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:

We may transfer your personal data to service providers that carry out certain functions on our behalf for example to Paddle who process payments on our behalf and Azure who provide storage and email services. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, namely, within the European Economic Area. OR
We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK. To obtain a copy of these contractual safeguards, please contact us via the Contact details listed in section 10.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.

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.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see 99 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in 44 for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine- readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data’s accuracy;
- Where our use of the data is unlawful, but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us (see Contact details at 1110).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

Via web form: https://devgrowthlab.com/support
Postal address: devgrowthlab, 4th Floor, Silverstream House/45 Fitzroy Street, Fitzrovia, London, W1T 6EB, GB

11. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 2025-09-07. Historic versions can be obtained by contacting us.

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, for example a new address or email address.

13. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.