Privacy Statement

This Privacy Statement explains how Diamond Edge IT, Inc., doing business as Smart Code ("Diamond Edge IT", "Smart Code", "Company", "us", "our", or "we") collects, uses and discloses personal data collected from and about you when you visit smartcode.technology, smartcode.news, thedevplatform.com or any related sub-domains that belong to Smart Code, or utilize any other services provided by Smart Code ("Services").

When you use Services provided by Smart Code, you trust us with your data. Smart Code is committed to keeping that trust and believes the commitment starts with being very transparent and up-front about how we collect, use and disclose your personal data. This Privacy Statement also describes the rights and controls you have over your personal data and how to contact us with any questions, comments, concerns and requests relating to your personal data.

Please review this Privacy Statement carefully to understand our policies and practices regarding your data and how we will treat it. If you do not agree with our policies and practices, you cannot use our Services. By accessing or using our Services, you agree to this privacy statement. This policy may change from time to time (see Changes to this Privacy Statement). Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

If you have any questions, comments or concerns about any aspect of this Policy, please do not hesitate to contact us by using the details set forth below in the "How To Contact Us" Section.

1. Data Controller

Smart Code provides Services to users throughout the world. However, Smart Code processes personal data inside of the United States only. Smart Code does not transfer data of its users outside of the United States.

Smart Code's data controller is:

Questions, comments and complaints about Smart Code's data practices can be submitted to Smart Code at [email protected].

In Summary… Regardless of your location, Smart Code is the only controller of your personal data, all your data is located within the United States, and none of it is transferred outside of the United States.

2. The Data We Collect From You

In order for you to utilize our Services, including but not limited to scheduling a meeting via our Calendly link, submitting an inquiry, voting on tools, nominating tools, or reviewing tools on thedevplatform.com, we collect the following data from you:

1. Data You Provide

• Inquiry and Scheduling Information: When you schedule a meeting or contact us through our website, we collect information necessary to facilitate that communication and provide the requested services. This includes your name, email address, title or role, and any appointment information submitted through Calendly. It also includes any additional information you choose to provide in your message or during the scheduling process.
• Voting on thedevplatform.com: When you vote on a tool, we collect your email address. This is required to ensure the integrity of voting and prevent duplicate or fraudulent submissions.
• Nominating a Tool on thedevplatform.com: When you nominate a tool, we collect your email address and any information you provide about the tool you are nominating.
• Reviewing a Tool on thedevplatform.com: When you submit a review, we collect your name, email address, and your title or role. This information is used to verify the authenticity of reviews and maintain transparency in our evaluation ecosystem.
• Correspondence with Smart Code: Smart Code may collect personal data from you if you contact us directly. The purpose of collecting this data is to assist you in resolving any issues or answering any questions you may have. This may include information such as your email address or contact number for follow-up conversations.

2. Data Collected Automatically

To collect certain data automatically, we use analytics tools that incorporate tracking technologies designed to recognize your device and compile information about your interactions with our Services. This may include your IP address, device type, browser type, interaction logs, and other technical information. One example includes the use of cookies. For more information, please see the section titled "Policy on Cookies and Similar Technologies".

Partner listings in the "Explore" section do not collect personal data unless you choose to interact with a partner's website or submission form.

In Summary… We collect personal data from you when you schedule a meeting with us, submit an inquiry, vote on a tool, nominate a tool, review a tool, or engage in any communications with us. We also automatically collect certain data when you visit or otherwise use our Services through the use of cookies or other similar tracking technologies.

3. How We Use Your Data

We collect, store, and use the data you provide to us for the following purposes:

• Company Communications: We use your data to contact you through email, phone, or other means to facilitate scheduled meetings, respond to your inquiries, and provide information related to our Services. This includes communications about the availability of our Services, security, or other service-related issues. You may change your communication preferences at any time.
• Development of the Services: We use the data we receive, including feedback and submissions from thedevplatform.com, to: (i) monitor and analyze trends; (ii) further develop our Services in order to provide you and others with a better, more intuitive, and personalized experience; (iii) estimate our audience size and usage patterns; and (iv) improve our customer service and support. This includes data collected when you vote on tools, nominate tools, or submit reviews, which helps us maintain the integrity of the platform. When possible, we use this data in aggregated or de-identified form to support platform development and analytics.
• Marketing & Advertising Communications: We use your data to provide you with relevant marketing and advertising content, including newsletters, new product offerings, special discounts, event notifications, and select third-party opportunities that align with our Services. By engaging with us, you consent to receiving such communications. Marketing communications are optional and are not required to vote, nominate tools, submit reviews, or otherwise use thedevplatform.com.

We are committed to your privacy. Every promotional email will include clear instructions for opting out of future marketing communications. You may also manage your preferences or opt out at any time by contacting Smart Code at [email protected].

In Summary… We use your data to facilitate communication, to further develop and personalize our Services, and to send you marketing communications. You can manage your marketing preferences or opt out at any time.

4. Who We Share Your Data With

We share the data we collect from you with third party service providers who help us operate, support, and improve our Services. This may include:

1. With Third Party Service Providers

• Scheduling and Communication Platforms — We use Calendly to facilitate meeting scheduling. Calendly has its own separate privacy statement that can be found at calendly.com/privacy.
• Payment processors and facilitators — We use QuickBooks for all payment and processing needs associated with facilitating our Services. QuickBooks has its own separate privacy statement that can be found at quickbooks.intuit.com/eu/privacy-policy.
• Professional Service Providers — We may share your data with consultants, lawyers, accountants, auditors, and other professional service providers who assist us in operating our business.
• Data Analytics Providers: We may share certain data with analytics providers who help us understand usage patterns, improve our Services, and maintain platform integrity, including voting, nominations, and reviews submitted on thedevplatform.com.

2. With Investigators, Governmental Bodies, Authorities or Law Enforcement Agencies

We may share your data if required by applicable law, regulation, legal process, or governmental request, or where disclosure is appropriate due to a safety or similar concern. This includes sharing your data with law enforcement officials, government authorities, or other third parties as necessary to enforce our Terms of Service or other policies, and to investigate and protect Smart Code or its users from fraudulent, abusive, inappropriate, or unlawful acts.

3. With Potential Buyers or Investors

We may share your data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation, restructuring, financing, or acquisition of all or a portion of our business by or into another company. This includes bankruptcy, liquidation, or similar proceedings in which personal data held by Smart Code about its users is among the assets transferred.

4. With Other Parties You Consent To

We may share your data with any other third parties not described in this policy if we notify you and you consent to the sharing.

5. With Marketers and Advertisers

Smart Code may share, but does not sell, your data with third parties for marketing or advertising purposes. If this changes in the future, you will be immediately notified, and this policy will be revised to provide you with the right to opt out of any such marketing or advertising.

In Summary… We may share your data with third parties who help us provide our Services. We may also share your data when required by law or to protect the rights and safety of you, us, or others. We may share your data with marketers or advertisers, but we do not sell your data.

5. How Long We Retain Your Data

Data Retention & Erasure: Smart Code retains your communication history and associated personal data for as long as necessary to fulfill the purposes for which it was collected or to provide the Services you have requested. You may request the erasure of your personal data at any time by contacting Smart Code at [email protected]. Upon receipt of a valid request, Smart Code will process the deletion of your identifiable communication records within thirty (30) days.

Please note that certain categories of data are not deleted upon request. Votes, reviews, and nominations submitted on thedevplatform.com are retained permanently to preserve the integrity, transparency, and continuity of our evaluation ecosystem.

Compliance & Regulatory Records: Smart Code is subject to various global regulatory, tax, and legal requirements. To comply with these obligations, we maintain certain records, including transaction histories and core communication logs, for a period of seven (7) years. Following this period, Smart Code will securely delete or anonymize such data in accordance with applicable laws.

In Summary… We maintain your personal data as long as we have an active business relationship with you. We can delete your personal data upon request, but we are required to maintain certain records for seven (7) years to comply with legal obligations. Votes, reviews, and nominations on thedevplatform.com are retained permanently and are not deleted.

6. Your Rights Relating to the Use of Your Data

We at Smart Code want you to have complete control of your data, and therefore, you always have the right to:

• Access any of your personal data we hold about you.
• Ask us to erase any personal data we hold about you.
• Ask us not to use your personal data for direct marketing purposes.
• Restrict the way we process your personal data.
• Have your personal data provided to a third-party provider of services.
• Have a copy of any personal data we hold about you.
• Object to our processing of your personal data.

If you need help or wish to exercise any of the above rights or have questions about them, please contact Smart Code at [email protected]. If you would like to request that we delete your personal data from our system, you can do so by contacting Smart Code at [email protected].

Please note that some categories of data cannot be deleted. Votes, reviews, and nominations submitted on thedevplatform.com are retained permanently to preserve the integrity of our evaluation ecosystem.

In Summary… You can access, update, and request deletion of your personal data by emailing us. You have many choices about how your data is collected, used, and shared, and we will help facilitate any of those choices you wish to pursue.

7. How We Secure Your Data

We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personally identifiable customer data. When our accounting software processes purchase orders, the purchase order is subject to strong security measures designed to protect against unauthorized access, destruction, loss, alteration, or misuse. Our security procedures may require us to request proof of identity before disclosing personal information to you.

Although we use reasonable organizational, technical, and administrative measures to protect your personal data, it is true that no data transmission over the Internet can be guaranteed to be 100% secure. While we do our best to protect your personal data, we cannot fully guarantee the security of any personal data you transfer over the Internet. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained in our Services.

If you have reason to believe that your interaction with us is no longer secure, please contact us immediately at [email protected].

In Summary… Our data transmissions are secured through encryption, and we monitor for and attempt to prevent security breaches. However, no data transmissions over the Internet can ever be guaranteed to be 100% secure.

8. Special Information for Individuals Located in the European Economic Area

Beginning May 25, 2018, the processing of personal data of users within the European Economic Area ("EEA") is subject to the EU General Data Protection Regulation ("GDPR"). This section summarizes Smart Code's grounds for processing personal data under the GDPR and the rights of such users as it relates to Smart Code's handling of personal data.

1. EU User Rights

If you are located within the EEA, you have the following rights with respect to how Smart Code handles your data:

• Requesting Explanations of What Data of Yours Smart Code Stores and How It Is Used — You have the right to request an explanation of the data that Smart Code has about you and how Smart Code uses that data.
• Requesting Copies of Your Data — You have the right to receive a copy of the data that Smart Code collects about you if collected on the basis of consent or because Smart Code requires the data to provide the Services that you request.
• Requesting Correction to Your Data — If Smart Code has data about you that you believe is inaccurate, you have the right to request correction of your data.
• Requesting Your Data to be Deleted — You may request deletion of your personal data at any time by contacting Smart Code at [email protected]. We may retain certain data about you as required by law and for legitimate business purposes permitted by law, which is further discussed in Section 5.
• Filing an Objection or Complaint — Users in the EEA have the right to object to Smart Code's processing of personal data, including for marketing purposes based on profiling and/or automated decision-making. Smart Code may continue to process your data notwithstanding the objection to the extent permitted under GDPR. Users in the EEA also have the right to file a complaint relating to Smart Code's handling of your personal data with their local Data Protection Authority ("DPA"). You may also submit complaints or objections directly to Smart Code by contacting Smart Code at [email protected].

2. Legal Basis for Processing Your Data

The GDPR requires that companies processing the personal data of EEA users do so on the basis of specific legal grounds. As such, Smart Code will only process your personal data in the following situations:

• The Processing Is Necessary to Perform Our Contract With You. Smart Code must collect and use certain data in order to provide its Services that you have contracted with Smart Code for. This includes user data that is necessary to facilitate scheduling and provide requested information.
• The Processing is Necessary for Smart Code's Legitimate Interests. Smart Code collects and uses personal data to the extent necessary for its legitimate interests, which includes: (i) to provide customer support; (ii) to optimize our service and develop new services; (iii) for research and analytical purposes; (iv) to enforce Smart Code's Terms of Service; and (v) to provide you notices about changes to our Services.
• Your Explicit Consent Is Given. Smart Code may collect and use your data on the basis of your consent. For example, we rely on your consent for us to use your personal data to send you marketing information (such as our newsletters and promotional offers) by email, SMS, or telephone. You may revoke your consent at any time.

In Summary… You have a right to: (i) request explanations of what data Smart Code stores and how it is used; (ii) request copies of your personal data; (iii) request your data to be deleted; or (iv) file a complaint about the use of your data. Our legal basis for collecting, using and sharing your data include consent, contract and legitimate interest. If the legal basis is consent, then you may withdraw your consent at any time.

9. International Data Transfers

The personal data we collect may be transferred to, and processed and stored in, countries outside of the jurisdiction you are located in. For example, if you are located in a country with the EEA, your personal data may be processed in the United States. All international transfers of your personal data are made:

• To a country or territory ensuring an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data as determined by the European Commission.
• To the third party that is a member of a compliance scheme recognized as offering adequate protection for the rights and freedoms of data subjects as determined by the European Commission.
• Pursuant to appropriate safeguards, such as the Standard Contractual Clauses (processors) approved by European Commission Decision C(2010)593 or any subsequent version thereof released by the European Commission or the EU-U.S. Privacy Shield.

If you wish to enquire further about these safeguards used, please contact Smart Code at [email protected].

In Summary… All of our data is processed in the United States. If you are located outside of the United States, then your data is safely transferred to our processors located within the United States in accordance with all applicable laws.

10. Policy on Cookies and Similar Technologies

Smart Code and its partners may use cookies on our websites and emails for purposes described in this policy.

• What are cookies? A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services.
• What are cookies used for? Smart Code uses cookies for security and protection (Cloudflare places required cookies to identify legitimate visitors and maintain performance) and for analytics (to analyze traffic and understand how visitors interact with our pages). Smart Code does not use cookies for advertising, behavioral tracking, personalization, or user authentication.
• How long will cookies stay on my device? Session cookies stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted.
• Who does the cookies belong to? First-party cookies belong to Smart Code. Third-party cookies such as those placed by Cloudflare and analytics providers are subject to those companies' own privacy policies.
• Types of Cookies Used: Technical/Required cookies are essential for our Services to function properly. Analytics cookies help us understand and improve our Services. Smart Code does not use advertising, targeting, or personalization cookies.

In Summary… We use tracking technologies such as cookies and web beacons to help provide and improve the Services. Our websites are intentionally accessible to bots and automated agents. If you wish not to utilize cookies, you can opt out through your browser or device settings. However, disabling cookies may limit certain aspects of the Services.

11. Links to Third Party Sites

Our Services may contain links to other sites. If you click on a third-party link, you will be directed to that site. We do not operate these external sites. Therefore, we strongly advise you to review the privacy statement and any terms of use for any such websites, as those websites may collect personal data from you or have their own policies regarding the use of tracking cookies and related technology. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

In Summary… We may have links that take you to sites other than ours. If you click on one of those links, you will be bound by that website's privacy policies.

12. Age Restrictions; Parental Consent

Our Services are intended for users of all ages; however, unfortunately, no one under the age of 13 may use the Services unless such person has a parent or guardian who first provides verifiable parental consent. We do not knowingly collect personal data from children under 13, unless such an individual has provided explicit verifiable parental consent. If you are under 13, do not use our Services or provide any data about yourself to us, including your name, email address, company or any screen name or user name you may use, without first having your parent contact us to provide verifiable consent.

If we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that data. If you believe we might have any data from or about a child under 13 without having the necessary parental consent, please contact Smart Code at [email protected]. To request a parental verification, please contact Smart Code at [email protected].

In Summary… Our Services are not for children under the age of 13, unless we have first obtained verifiable parental consent. To request a parental verification, please contact Smart Code at [email protected].

13. Changes to this Privacy Statement

The date this Privacy Statement was last revised is identified at the top of this agreement. If we make changes to this Privacy Statement about how we treat our users' personal data, we will notify you by email to the primary email address specified in your inquiry. We will also post the updated privacy statement on our website in the same location as the previous version. You are responsible for ensuring we have an up-to-date, active and deliverable email address for you, and for periodically visiting our website and this Privacy Statement to check for any changes. If we make material changes to this Privacy Statement, we will notify you by email at least fifteen (15) days prior to the date on which such changes take effect.

In Summary… We may update this Privacy Statement from time to time. You will be notified of any updates by email, and copies of the updated Privacy Statement will be located on our website.

14. How to Contact Us

We are here to help and be as transparent as possible regarding how we use, store and transfer your data. If you have any questions regarding this Privacy Statement, or if you wish to exercise any of your rights in relation to your personal data, or if you want to object to the collection or processing of your data by Smart Code, whether entirely or partially, please contact us at [email protected].

In Summary… Please contact us with any questions, comments or concerns you may have at [email protected].