New Wave Devs LLC (“we”, “us”, “our”, “NWD”) values your privacy. By this Privacy Policy (“Policy”) We shall explain when, why, how, and what personal information (personal data) We may process about you (“User”, “you”) when:
New Wave Devs LLC is a Wyoming Domestic Limited-Liability Company filed On August 25, 2021. The company's filing status is listed as Active and its File Number is 2021-001030622.
The Registered Agent on file for this company is Registered Agents Inc. and is located at 30 N Gould St Ste R, Sheridan, WY 82801. The company's principal address is 30 N Gould St Ste R, Sheridan, WY 82801 and its mailing address is 30 N Gould St Ste R, Sheridan, WY 82801.
Any representation of information that permits the identity of an individual to whom the information applies to be reasonably inferred by either direct or indirect means is personal information. Further, personal information is defined as information: (i) that directly identifies an individual (e.g., name, address, social security number or other identifying number or code, telephone number, email address, etc.) or (ii) by which an agency intends to identify specific individuals in conjunction with other data elements, i.e., indirect identification.
As a brief introduction, we would like to define personal information categories that we do/do not process:
1. Identifiers[Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.]
Is processed: ✓ Yes
2. Personal information categories listed in the California Customer Records statute[Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.]
Is processed: ✓ Yes
3. Protected classification characteristics under California or federal law[Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).]
Is processed: ⨉ No
4. Commercial information[Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.]
Is processed: ✓ Yes
5. Biometric information[Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.]
Is processed: ⨉ No
6. Internet or other similar network activity
[Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.]
Is processed: ✓ Yes
7. Geolocation data[Examples: Physical location or movements.]
Is processed: ⨉ No
8. Sensory data[Examples: Audio, electronic, visual, thermal, olfactory, or similar information.]
Is processed: ✓ Yes
9. Professional or employment-related information[Examples: Current or past job history or performance evaluations.]
Is processed: ✓ Yes
10. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))[Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.]
Is processed: ⨉ No
11. Inferences drawn from other personal information[Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.]
Is processed: ✓ Yes
We may collect the following personal information, depending on how we deal with you, for the following purposes:
I. User type: Visitor(i.e., user that monitors Website with no specific defined intention yet)
Identifiers/Internet or other similar network activity/Sensory data:
We must process certain technical data in order to (1) protect Website & Users and (2) provide you access to our website.
(1) Your consent and (2) our legitimate interest in business development and protection of website/clients/other parties serve as a legal basis for such processing.
We store such data for 1 year or less, unless affiliated with cybersecurity incident or candidate/prospect application – retention period may be extended for 3 years or more if required by applicable laws.
II. Data subject type: Candidate(i.e., user that submits a job/cooperation application via Website)
Identifiers/ Professional or employment-related information/Commercial information:
We are always happy to cooperate with talented individuals! We collect and process this data only if it is submitted by you.
(1) Necessity to process such data to take steps at the request of the data subject prior to entering into a contract and (2) our legitimate interest in business development and protection of website/clients/other parties serve as a legal basis for such processing.
We store such data for 3 years or less. If we proceed with cooperation, data will be processed and stored based on respective service agreement.
III. Data subject type: Prospect(i.e., user that wants to commission NWD services via Website)
Identifiers/ Professional or employment-related information/Commercial information:
To assist you with your project, we will have to get acquainted first. We use this information to verify your identity and to respond to your request. We collect and process this data only if it is submitted by you.
(1) Necessity to process such data to take steps at the request of the data subject prior to entering into a contract and (2) our legitimate interest in business development and protection of website/clients/other parties serve as a legal basis for such processing.
We store such data for 3 years or less. If we proceed with cooperation, data will be processed and stored based on respective service agreement.
IV. Data subject type: Business contact(i.e., a person whose work contact details we collect so that we can contact them on our own initiative about our services, for example a founder, CEO, CTO or engineering leader at a company that may need engineers. This also covers people whose public LinkedIn posts we collect so our team can read and comment on them.)
Identifiers/ Professional or employment-related information/ Inferences drawn from other personal information:
We do not look for or use special category data (such as health, religion or political views), even if a message or public post we hold happens to contain it. We look only for work e-mail addresses. If we get a personal e-mail address by mistake, we do not use it and delete it. We do not track whether you open our e-mails or click links in them.
Who is responsible. New Wave Devs LLC, 30 N Gould St, Ste R, Sheridan, WY 82801, USA, is the controller of this data. You can reach us at requests@newwavedevs.com.
Why we use it. To find companies that may need software engineers, to contact the right person there about our services by e-mail or on LinkedIn, to keep track of our conversations, and to make sure we do not contact people who asked us to stop. If we collect your public LinkedIn posts, we use them only so our team can read and comment on them.
Legal basis. Our legitimate interests (Article 6(1)(f) of the GDPR and of the UK GDPR). Our interest is to grow our business by telling companies that may need engineers about our services, and to take part in professional discussions on LinkedIn. The law recognizes that direct marketing may be a legitimate interest (GDPR Recital 47, UK GDPR Article 6(11)(a)). We think this is fair to you because we use only work details, we write to you in your professional role about something related to your job, and we stop when you ask. We keep our do-not-contact list to respect your objection, which is also in our legitimate interests.
Where we got your data.
Your company's website, public company registers, public job postings and the public parts of your LinkedIn profile are publicly accessible sources. LinkedIn Sales Navigator, Snov.io and event attendee lists are not public.
Who receives your data.
Snovio Inc. (USA) and we are joint controllers for the contact details we find, check and keep in the Snov.io platform. Under Snov.io's joint controllership terms, we give you this notice and handle your requests. You can also send requests to Snov.io at help@snov.io. Once we copy your details into our own tools, we alone are the controller. Snov.io stores data in the United States, and its staff work from several countries outside the EEA and the UK, which may not protect personal data to the same standard.
We do not sell your data.
Transfers outside the EEA and the UK. We are a US company, so your data is handled in the United States. Google, HubSpot, Snov.io, our LinkedIn messaging tool and our web data collection service store data in the United States (Google also in other countries). Our team members and contractors in Ukraine also work with it. Neither the European Commission nor the UK has an adequacy decision for Ukraine. For the United States, the EU and UK adequacy decisions cover only companies certified under the EU-U.S. Data Privacy Framework and its UK Extension. New Wave Devs LLC is not certified. Where the law requires a safeguard for these transfers, we use the European Commission's standard contractual clauses and, for UK data, the UK addendum or the UK international data transfer agreement. These are part of our providers' data processing terms and our contracts with our contractors. You can ask us for a copy at requests@newwavedevs.com.
How long we keep it. If we have not contacted you within one month of collecting your details, we delete them. If we contact you and we do not start working together, we delete your outreach record 12 months after our last contact with you. We delete public LinkedIn posts we collected 30 days after collecting them. If we start working together, your data is kept as described for Prospect above and in our service agreement. If you object or ask us to stop, we delete the rest of your outreach record and keep only your name, company, work e-mail address or LinkedIn profile URL, and the date on our do-not-contact list for as long as we do outreach, so that we do not contact you again. We keep this short entry even if you ask us to delete your data, because without it we could contact you again by mistake.
Your right to object
You can object at any time to us using your data to contact you about our services. This also covers our notes about whether our services may fit your company. You do not need to give a reason. Once you object, we stop using your data for this purpose, we stop contacting you by e-mail and on LinkedIn from every mailbox and account we use, and we keep only the short do-not-contact entry described in “How long we keep it”.
You can also object to any other use of your data based on our legitimate interests, for reasons related to your situation. If you object to us collecting your public LinkedIn posts, we stop and delete the posts we hold.
To object, reply “no” to any e-mail or LinkedIn message from us, or write to requests@newwavedevs.com.
Your other rights. You can ask us for a copy of the data we hold about you, and ask us to correct it, delete it or limit how we use it. Write to requests@newwavedevs.com. We reply within one month. If a request is complex or we receive many, we may need up to two more months. If so, we tell you within the first month.
Complaints. You can complain to us at requests@newwavedevs.com. We confirm receipt within 30 days and tell you the outcome without undue delay. You can also complain to a data protection authority, in particular in the country where you live or work or where you think the problem happened: in the UK the Information Commission (ICO, ico.org.uk), in Sweden Integritetsskyddsmyndigheten (IMY, imy.se). Contact details of all EU authorities are at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.
Automated decisions. We do not make decisions about you based only on automated processing that have legal or similarly significant effects on you.
We protect your personal information to maintain its confidentiality and integrity, to prevent unauthorized use or disclosure of your personal information, and to protect your personal information from loss, unauthorized access, alteration and destruction.
We do not sell personal information. We have not sold any personal information for last 12 months. We share personal information only with the parties (categories of parties) mentioned in this section.
Please note that your personal information may be disclosed in cases defined for by applicable law, in particular by court order, in order to prevent fraud and other crimes, etc.
Parties that ensure the proper functioning of the Website. Since data protection of all users of the Website is one of the key tasks of the NWD, the administration of the NWD can be carried out jointly with parties that are able to ensure the appropriate level of cyber security and the quality of data display.
Tools for e-mail and outreach. To find business contacts, send e-mails and LinkedIn messages and keep track of conversations, we use Google Workspace (e-mail), HubSpot (CRM), a LinkedIn messaging tool, LinkedIn, Snov.io (finding and checking work e-mail addresses) and a web data collection service (collecting public LinkedIn posts). For contact details we find, check and keep in the Snov.io platform, Snovio Inc. and we are joint controllers (see “IV. Data subject type: Business contact”).
Our team members and contractors. People who work with us in Ukraine and Spain access personal information to handle requests, research and outreach for us.
Cookies are small text files that are stored on your computer or mobile phone after visiting Website. While Cookies normally do not contain enough information to identify a person, some cookies may identify a device. We try to limit use of Cookies only to first party (directly stored by us) Cookies required to make use of Website comfy; We try to refrain from using marketing Cookies.
Following Cookie is being used by Us:
Cookie key – “_ga”
Domain: .newwavedevs.com
Expiration: 2 years
This first party cookie is associated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.
We may store your personal information in cloud provided by Hetzner Online GmbH (Germany; servers located in Germany, Finland, and United States of America). Data about business contacts (see “IV. Data subject type: Business contact”) is kept in our e-mail and outreach tools: Google Workspace, HubSpot, Snov.io, LinkedIn, a LinkedIn messaging tool and a web data collection service. HubSpot, Snov.io, the LinkedIn messaging tool and the web data collection service store data in the United States. Google stores data in its data centers in the United States and other countries. Personal information may be also accessed and stored by our team members and contractors in Ukraine and Spain.
Please note that in case of transfer of data to third parties in accordance with Cross-Border Transfer Section, the data may be stored on media and devices of such third parties.
We are a US company, so personal information we hold is handled in the United States. It is also transferred to Ukraine, where most of our team members and contractors work, and may be stored in Finland or Germany on servers provided by Hetzner Online GmbH. Our e-mail and outreach tools store data mainly in the United States (see Where Personal Information May Be Stored?).
Neither the European Commission nor the UK has an adequacy decision for Ukraine. For the United States, the EU and UK adequacy decisions cover only companies certified under the EU-U.S. Data Privacy Framework and its UK Extension. New Wave Devs LLC is not certified.
If your personal information comes from the EEA or the UK and the law requires a safeguard for its transfer, we use the European Commission's standard contractual clauses and, for UK data, the UK addendum or the UK international data transfer agreement. These are part of our providers' data processing terms and our contracts with our contractors. You can ask us for a copy at requests@newwavedevs.com.
You can make the following choices regarding your Personal Information:
We remain at your disposal if further explanation or execution of any rights is required: requests@newwavedevs.com
The provisions of this Policy may be changed at the discretion of the NWD. In the case of changes to this Policy, its updated content will be posted within the Website, or sent to you via e-mail, if your e-mail address is known to the NWD and you have not asked us to stop contacting you. Changes to the Policy take effect from the moment the new version of the Policy is published within the Website.