Privacy Policy

1. Who We Are

DevRune is operated by:

FLOWQE SOLUTIONS SRL
IDNO: 1023600066800
Bd. Decebal 139/5, ap. 61
MD-2060 Chișinău
Republic of Moldova

Website: https://devrune.com

Privacy inquiries: privacy@devrune.com

Recruitment inquiries: hr@devrune.com

For the processing described in this Privacy Policy, FLOWQE SOLUTIONS SRL generally acts as the data controller.

2. Scope of This Privacy Policy

DevRune.com is primarily a corporate presentation website through which visitors can learn about DevRune, contact us, discuss potential business relationships, and submit employment applications.

This Privacy Policy applies when you:

• visit devrune.com;

• browse information about DevRune or our services;

• submit a contact form;

• contact us through another communication channel that we make available;

• inquire about a potential project or business relationship;

• upload a file;

• send us a CV, resume, portfolio, or other recruitment material;

• apply for a position;

• participate in interviews or assessments;

• communicate with our recruitment team; or

• otherwise interact with DevRune in connection with the website.

This Privacy Policy primarily governs the public DevRune website, business inquiries, and recruitment activities.

Personal data that DevRune processes on behalf of customers as part of software-development projects may instead be governed by the relevant customer agreement, Data Processing Agreement, statement of work, or other project-specific agreement.

3. Age Requirement

The DevRune website, contact functionality, and recruitment processes are intended primarily for persons who are at least 18 years old.

We do not knowingly solicit employment applications from persons under 18.

If you believe that a person under 18 has provided personal data to us inappropriately, please contact us at privacy@devrune.com.

4. Personal Data We Collect

The information we process depends on how you interact with DevRune.

4.1 Contact and Business Inquiry Information

Our website contact forms may collect information including:

• name;

• email address;

• telephone number;

• the category or subject of your inquiry, including information entered under “What’s this about?”;

• the content of your message;

• CVs or other uploaded files; and

• other information you voluntarily provide.

Where you contact us through email, telephone, Microsoft Teams, professional networks, or another communication channel, we may process the information that you provide through that channel.

4.2 Business and Project Information

Where you contact us concerning a potential business relationship or project, we may also process information such as:

• company or organization name;

• your role or position;

• business requirements;

• technical requirements;

• project descriptions;

• documentation;

• expected timelines;

• contact information;

• attachments; and

• other information necessary to understand and respond to the inquiry.

Please avoid sending confidential, sensitive, or security-critical information unless it is reasonably necessary for the discussion.

5. Recruitment and Applicant Information

Applicants may provide information in whatever form is reasonably relevant to their application.

Depending on what you choose to provide and what is relevant to the recruitment process, we may process:

• name;

• email address;

• telephone number;

• city or country of residence;

• CV or resume;

• employment history;

• education;

• qualifications;

• professional experience;

• technical skills;

• language skills;

• portfolio information;

• LinkedIn or other professional-profile information;

• GitHub or other public development-profile information;

• availability;

• salary expectations, where provided;

• cover letters or messages;

• coding assignments;

• technical assessment results;

• interview notes;

• interviewer assessments;

• communications with our recruitment team;

• reference information;

• previous-employment information; and

• other information voluntarily provided during recruitment.

You should provide only information that is reasonably relevant to your application.

6. Information From Public Professional Sources

Where reasonably relevant to recruitment, we may review professional information that an applicant has made publicly available.

This may include information from:

• LinkedIn;

• GitHub;

• public portfolios;

• personal professional websites;

• public software-development repositories; or

• similar professional sources.

We do not use this as authorization to investigate unrelated aspects of an applicant's private life.

Public professional information is used only where reasonably relevant to assessing the candidate for employment or another professional relationship.

7. Background and Reference Checks

For candidates who progress through the recruitment process, we may verify relevant information concerning previous employment where reasonably necessary for the position.

Such checks are generally intended to occur only where relevant and, where practicable, at a later stage of the recruitment process.

We do not normally request passport or identity-document copies as part of an ordinary initial application.

We also do not normally request medical or health information during the ordinary recruitment process.

Where additional checks become legally or operationally necessary for a particular position, we will process the relevant information in accordance with applicable law.

8. Interviews and Interview Recordings

DevRune may conduct interviews through communication services including Microsoft Teams.

In some circumstances, an interview may be recorded.

We do not intentionally record interviews secretly.

Where an interview will be recorded, the candidate will be informed before recording begins and, where required by applicable law, appropriate consent will be obtained.

Interview recordings:

• are used only for purposes reasonably connected to the relevant recruitment process;

• are accessible only to persons who reasonably require access for that recruitment process;

• are not used for advertising;

• are not used to train our AI models; and

• are not intended for unrelated internal use.

Under our normal retention practice, interview recordings may be retained for up to 90 days after the relevant recruitment process ends, unless earlier deletion is appropriate or longer retention is reasonably necessary for a legal claim, dispute, security matter, or legal obligation.

9. Coding Assignments and Assessments

Applicants may be asked to complete coding exercises, technical assignments, assessments, or other evaluation tasks.

We process these materials for purposes such as:

• evaluating technical skills;

• assessing suitability for the role;

• comparing candidates; and

• supporting hiring decisions.

Submitting a recruitment assignment does not automatically give DevRune the right to reuse the applicant's work commercially.

DevRune does not use candidate coding assignments commercially outside the recruitment process without separate permission or another appropriate legal basis.

We also do not use candidate coding assignments to train our own general-purpose AI models.

10. Sensitive Personal Data

DevRune does not ordinarily require sensitive personal data to respond to website inquiries or assess employment applications.

Please avoid submitting unnecessary information concerning:

• medical or health conditions;

• genetic information;

• biometric identifiers;

• racial or ethnic origin;

• political opinions;

• religious or philosophical beliefs;

• trade union membership;

• information concerning a person's sex life or sexual orientation;

• criminal-history information unless specifically relevant and lawfully requested;

• passwords;

• private cryptographic keys;

• API secrets;

• authentication tokens;

• payment-card security information; or

• similar highly sensitive information.

If such information is provided, we will process it only where there is an appropriate legal basis and any additional conditions required by applicable law are satisfied.

11. Website and Technical Information

When you visit devrune.com, Wix and other website infrastructure may automatically process technical information such as:

• IP address;

• browser type and version;

• operating system;

• device information;

• preferred language;

• approximate geographic information;

• date and time of access;

• pages visited;

• referring website or page;

• session information;

• interactions with the website;

• technical errors;

• network information; and

• security-related information.

This information may be used to operate, maintain, secure, diagnose, and understand use of the website.

12. Wix Website Infrastructure

DevRune.com is built and hosted using Wix Studio / Wix.

Wix provides functionality used by the website, which may include:

• website hosting;

• forms;

• form submissions;

• file uploads;

• Wix Contacts and CRM functionality;

• website security;

• technical infrastructure;

• cookie-management functionality; and

• website analytics functionality.

When you submit a form through devrune.com, relevant information may be processed and stored through Wix systems as part of providing those services to DevRune.

Contact information submitted through the website may also create or update a contact record within Wix Contacts or Wix CRM.

We use such information only for purposes described in this Privacy Policy.

13. File and CV Uploads

The DevRune website may allow visitors to upload CVs and other files through Wix Forms.

Uploaded files may contain personal data and potentially confidential information.

Uploaded CVs and other files are treated as confidential information and are shared internally only where reasonably necessary for the relevant business inquiry or recruitment process.

You must not intentionally use our forms to upload:

• passwords;

• API credentials;

• private cryptographic keys;

• authentication tokens;

• malware;

• malicious software;

• complete payment-card credentials; or

• other information creating an unreasonable security risk.

Files submitted through the website may be processed and stored through Wix infrastructure.

14. How We Use Personal Data

14.1 Business Inquiries

We may process information submitted through our website or other communications to:

• respond to inquiries;

• answer questions;

• understand business requirements;

• prepare proposals or estimates;

• arrange meetings;

• discuss potential projects;

• establish business relationships; and

• communicate regarding DevRune services.

Depending on the circumstances, processing may be necessary to take steps at your request before entering into a contract or may be based on our legitimate interests in operating and developing our business.

14.2 Recruitment

We process recruitment information to:

• receive applications;

• evaluate candidates;

• assess professional experience;

• assess technical skills;

• communicate with applicants;

• arrange and conduct interviews;

• conduct coding or technical assessments;

• conduct relevant personality or professional assessments;

• verify relevant previous employment;

• contact references where appropriate;

• compare candidates;

• make recruitment decisions;

• prepare employment offers; and

• take steps toward entering into an employment relationship.

Depending on the processing activity, the legal basis may include taking steps at the candidate's request before entering into an employment relationship, legitimate interests, compliance with applicable employment law, or consent where appropriate.

14.3 Website Operation and Security

We may process technical information to:

• operate the website;

• prevent spam;

• prevent abuse;

• diagnose technical problems;

• maintain website availability;

• detect unauthorized activity;

• investigate incidents; and

• protect our systems.

Where applicable, we rely on our legitimate interests in maintaining a secure and reliable website.

14.4 Legal Compliance

We may process personal data where necessary to:

• comply with applicable law;

• comply with employment or corporate obligations;

• respond to valid legal processes;

• establish, exercise, or defend legal claims;

• resolve disputes;

• investigate misconduct; or

• obtain legal or professional advice.

15. Google Analytics and Website Analytics

DevRune uses Google Analytics in connection with website analytics and search-engine optimization.

We may also use analytics functionality provided through Wix.

Analytics may process information including:

• pages visited;

• session information;

• device and browser information;

• referral information;

• approximate geographic information;

• website interactions; and

• usage patterns.

Where consent is required by applicable law, non-essential analytics technologies are used only after the visitor has provided the necessary consent.

Visitors may use the cookie-consent interface to manage non-essential analytics preferences.

We do not intentionally send CV contents, uploaded documents, contact-form messages, passwords, or other sensitive form content to Google Analytics for analytics purposes.

16. Cookies and Similar Technologies

DevRune uses cookies, local storage, and similar technologies.

Some technologies are necessary for purposes such as:

• website operation;

• security;

• session management;

• abuse prevention;

• remembering preferences; and

• providing functionality requested by visitors.

Other technologies may be used for analytics and similar non-essential purposes.

DevRune uses the cookie-consent functionality available through Wix.

Where applicable law requires consent, non-essential cookies and scripts are not intended to operate until the necessary consent has been provided.

Visitors can use the cookie-consent interface to manage their choices.

Necessary technologies may continue to operate where they are required to provide requested website functionality or maintain security.

17. Communications

We may contact you in connection with the reason you originally contacted DevRune.

For example, if you submit a project inquiry, we may contact you to:

• respond to the inquiry;

• ask follow-up questions;

• schedule a meeting;

• provide a proposal; or

• continue discussions about the potential business relationship.

Submitting a contact form does not automatically subscribe you to marketing communications.

18. Marketing Communications

DevRune may introduce newsletters, company announcements, service updates, or other marketing communications.

Where required by applicable law, marketing communications will use a separate, optional opt-in.

You will not be required to accept marketing as a condition of submitting a contact inquiry or employment application.

You may withdraw marketing consent or unsubscribe from optional marketing communications at any time.

19. Email and Communication Providers

DevRune uses Google Workspace / Gmail for business email and communications.

Recruitment or internal collaboration may also use Microsoft 365 and Microsoft Teams.

Personal data may therefore be processed through these providers where necessary to:

• communicate with visitors;

• handle business inquiries;

• manage recruitment;

• share applications internally;

• conduct interviews;

• store interview recordings; or

• collaborate internally.

20. Internal Access to Personal Data

Access to personal data submitted to DevRune is restricted to personnel who reasonably require access for their responsibilities.

For example, recruitment information may be accessed by:

• recruitment or HR personnel;

• relevant managers;

• technical interviewers;

• company management; or

• other personnel directly involved in the recruitment decision.

Applications may be shared internally using tools such as email or Microsoft Teams where reasonably necessary.

We do not make CVs or applicant information generally available to everyone within the company.

21. Recruitment Platforms and Future Providers

DevRune does not currently rely on a dedicated third-party recruitment platform for its primary recruitment workflow.

We may introduce recruitment platforms or other recruitment service providers in the future.

If such a provider materially changes how applicant personal data is processed, we will update this Privacy Policy or provide other appropriate notice where required.

If you apply to DevRune through an independent third-party employment or professional platform, that platform may process your data under its own privacy policy in addition to our processing.

22. Other Service Providers

We may use third-party service providers where reasonably necessary to operate our website and business.

Current providers include services supplied by:

• Wix — website hosting, forms, file uploads, CRM/Contacts, cookie management, and related website infrastructure;

• Google — Google Workspace/Gmail and Google Analytics;

• Microsoft — Microsoft 365 and Teams.

We may also use appropriate professional advisers and technical providers where necessary.

Depending on the service, providers may process personal data on our behalf or under their own legal obligations.

Where providers process personal data on our behalf, we seek to use appropriate contractual, organizational, and security safeguards.

23. International Data Transfers

FLOWQE SOLUTIONS SRL is established in the Republic of Moldova.

The technology providers used by DevRune operate internationally.

Personal data may therefore be processed in:

• the Republic of Moldova;

• countries within the European Economic Area;

• the United States; or

• other jurisdictions in which our authorized providers operate.

Where applicable data protection law requires safeguards for international transfers, we seek to rely on an appropriate legal mechanism, which may include:

• an adequacy decision;

• Standard Contractual Clauses;

• contractual safeguards;

• another recognized transfer mechanism; or

• an applicable statutory exception.

24. Recruitment Data Retention

24.1 Unsuccessful Candidates

Where an applicant is not hired, we may retain their application and relevant recruitment information for up to 12 months after the relevant recruitment process ends.

This period may allow us to:

• maintain appropriate recruitment records;

• respond to questions concerning the recruitment process;

• protect against or respond to legal claims; and

• consider the candidate for another reasonably relevant opportunity where permitted by applicable law.

You may request earlier deletion as described below.

24.2 Hired Candidates

Where an applicant becomes an employee, relevant recruitment information may become part of their employee record.

That information will then be processed and retained according to applicable employment, personnel, accounting, legal, and internal retention requirements rather than the unsuccessful-candidate retention period.

24.3 Interview Recordings

Interview recordings are normally retained for no longer than 90 days after the relevant recruitment process ends.

They may be deleted earlier where no longer required.

They may be retained longer only where reasonably necessary for an ongoing dispute, legal claim, investigation, or legal obligation.

24.4 Early Deletion Requests

Candidates may request deletion of their application or recruitment information by contacting privacy@devrune.com.

Where the information is no longer necessary and no applicable legal basis requires continued retention, we will delete it.

We may retain limited information where reasonably necessary to:

• comply with applicable law;

• establish, exercise, or defend legal claims;

• resolve a dispute; or

• maintain information that we are otherwise legally required to retain.

25. Contact and Business Inquiry Retention

Information submitted through contact forms or other business communications is retained only for as long as reasonably necessary for purposes such as:

• responding to the inquiry;

• maintaining relevant correspondence;

• pursuing a potential business relationship;

• managing an active business relationship; or

• protecting legal rights.

Where the information is no longer reasonably necessary, we seek to delete or anonymize it unless another lawful retention requirement applies.

26. No AI Training With Recruitment Materials

DevRune does not use CVs, interview recordings, recruitment coding assignments, or other applicant materials to train its own general-purpose AI models.

We also do not use these materials for unrelated advertising or public demonstrations.

27. No Sale of Personal Data

DevRune does not sell personal data submitted through devrune.com.

This includes:

• CVs;

• recruitment information;

• interview recordings;

• coding assignments;

• contact-form information; and

• uploaded files.

28. Information Security

We use technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, loss, or destruction.

Our practices include, where appropriate:

• restricted access to personal data;

• individual employee accounts;

• multi-factor authentication for administrative systems;

• access based on operational need;

• secure communication services;

• cloud-provider security controls;

• the ability to revoke personnel access; and

• reasonable internal access controls.

Accounts used to administer services such as Wix, Google Workspace, and Microsoft 365 are protected using individual access credentials and multi-factor authentication where configured for personnel with relevant access.

Access can be revoked when an employee no longer requires it or leaves the company.

No electronic system can guarantee absolute security.

29. Personal Data Breaches

If FLOWQE SOLUTIONS SRL becomes aware of a suspected personal data breach, we may:

• investigate the incident;

• take reasonable containment measures;

• remediate identified vulnerabilities;

• determine what information may have been affected;

• assess risks to individuals;

• document the incident; and

• notify competent authorities or affected individuals where required by applicable law.

We do not undertake to notify users about every minor technical or security incident.

Affected individuals will be notified where required by applicable law or where otherwise appropriate based on the nature and risk of the incident.

Security or privacy concerns can be reported to:

privacy@devrune.com

30. Your Data Protection Rights

Depending on your location and applicable law, you may have rights concerning your personal data.

These may include the right to:

• obtain confirmation as to whether we process personal data concerning you;

• request access to your personal data;

• receive a copy of applicable personal data;

• request correction of inaccurate information;

• request completion of incomplete information;

• request deletion of personal data;

• request restriction of processing;

• object to certain processing;

• request data portability where applicable;

• withdraw consent where processing is based on consent;

• object to direct marketing; and

• lodge a complaint with a competent supervisory authority.

These rights are subject to applicable legal conditions, limitations, and exceptions.

For example, a request for deletion does not necessarily require us to delete information that we are legally required or entitled to retain for an ongoing legal claim or another valid legal purpose.

31. Exercising Your Rights

Privacy requests may be submitted to:

privacy@devrune.com

We may request information reasonably necessary to verify your identity and prevent unauthorized access to another person's information.

We may also ask you to clarify a request where necessary to understand which information or processing activity it concerns.

We will respond within the period required by applicable law.

32. Withdrawal of a Job Application

You may withdraw your application at any time.

You may contact:

hr@devrune.com

or

privacy@devrune.com

Withdrawal of an application ends consideration for the relevant position.

Withdrawal does not necessarily require immediate deletion of every record where limited retention remains lawful and reasonably necessary.

33. Republic of Moldova

FLOWQE SOLUTIONS SRL is established in the Republic of Moldova.

Where Moldovan data protection law applies, personal data is processed in accordance with applicable Moldovan legislation, including Law No. 195/2024 on Personal Data Protection.

Individuals may have the right to lodge a complaint with the:

National Center for Personal Data Protection of the Republic of Moldova (CNPDCP)

Contacting DevRune first is not a condition for exercising a right to complain to a competent authority.

34. European Union and EEA

Where the GDPR applies, we may process personal data on legal bases including:

• taking steps at your request before entering into a contract;

• performance of a contract;

• compliance with a legal obligation;

• our legitimate interests;

• consent; or

• another legal basis permitted by applicable law.

Where processing relies on legitimate interests, we consider those interests against the rights and freedoms of affected individuals.

Individuals may also have the right to lodge a complaint with a competent EU or EEA data protection supervisory authority.

35. Automated Decision-Making

DevRune does not currently use AI or other solely automated systems to automatically rank, reject, or select job applicants in a manner that produces legal or similarly significant effects.

Recruitment decisions involve human evaluation.

If our practices materially change, we will update our disclosures where required by applicable law.

36. Legal Disclosures

We may disclose personal data where we reasonably believe disclosure is necessary to:

• comply with applicable law;

• comply with a valid court order or legal process;

• respond to a lawful request from a competent authority;

• comply with corporate or employment obligations;

• investigate fraud or abuse;

• respond to a security incident;

• establish, exercise, or defend legal claims;

• protect DevRune's infrastructure; or

• protect the rights, property, or safety of FLOWQE SOLUTIONS SRL or others.

Where legally permitted and reasonably practicable, we seek to limit disclosure to information necessary for the relevant purpose.

37. Business Transfers

If FLOWQE SOLUTIONS SRL or DevRune is involved in a:

• merger;

• acquisition;

• corporate restructuring;

• financing;

• sale of assets; or

• similar corporate transaction,

personal data may be transferred where reasonably necessary as part of that transaction.

Any such processing remains subject to applicable data-protection requirements.

38. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

Changes may result from:

• changes to devrune.com;

• changes to our recruitment process;

• new website functionality;

• new service providers;

• new analytics or security technologies;

• changes to our processing practices; or

• changes in applicable law.

The “Last updated” date at the beginning of this document indicates when it was most recently revised.

Where a change materially affects how personal data is processed, we may provide additional notice where appropriate or required by law.

39. Contact Us

For questions about this Privacy Policy, privacy-rights requests, or security concerns, contact:

FLOWQE SOLUTIONS SRL
IDNO: 1023600066800
Bd. Decebal 139/5, ap. 61
MD-2060 Chișinău
Republic of Moldova

Privacy: privacy@devrune.com
Recruitment: hr@devrune.com
Website: https://devrune.com