Privacy Policy

Introduction

DevAcrobats Ltd (formerly Nara Syst Ltd.) with UIC/PIC 131571959 is registered in the Commercial register and register of Non-profit Legal Entities in Bulgaria, Company case: 13904/2005 110. Our legal address is 47А Cherni Vrah Blvd., fl.4-5, Puzl, 1407 Sofia, Bulgaria. You can reach us by e-mail at [email protected]. Throughout this policy, references to ‘us,’ ‘we,’ and ‘our’ mean DevAcrobats Ltd.

As an Atlassian Marketplace Partner, we provide a variety of Cloud and downloadable applications (for Server and Data Center) available through the Atlassian Marketplace. Throughout this policy, we refer to these products and any other offerings collectively as ‘Services’ or ‘Apps.’

We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Policy describes our policies and practices regarding the collection and use of your personal data and explains your privacy rights. We recognize that information privacy is an ongoing responsibility, so we may update this Privacy Policy periodically as we adopt new personal data practices or implement additional privacy measures.

How we collect and use (process) your personal information

What types of data we collect and how we obtain information about you

 

Data collected or obtained about customers and users of our Apps

  • Data Received After App Installation or Purchase
    When you install a free trial or purchase any of our apps (Cloud, Server, or Data Center), we receive certain personal data linked to your Atlassian product license. This data may include:

    • Company details: Company name, country, and region.

    • Technical and billing contacts: Name, email, address, and phone number.

    • License details: License ID (SEN), type and status, hosting type, and sales channel.

    • Solution Partner Information: If applicable, we may access the partner’s name, contact name, and email address.

This information is provided to us by Atlassian.

  • Data from Support or Service Inquiries

    • When you submit a ticket in our Service Management System, we obtain personal data such as your name, email address, job title and other details included in your request.

    • If you contact us via email, we may obtain similar information as part of your correspondence.

  • Data Generated During App Usage

    • For Cloud app versions, the Cloud app servers generate log files to help us operate. These log files include:

      • IP addresses

      • Browser type and operating system

      • App URLs accessed during app usage

  • Additional Information Provided for Support

To resolve support inquiries, we may request additional details, such as screenshots of app configurations. This data is used solely to provide support and is not used for any other purpose.

  • App Usage Statistics. For Cloud versions of our apps, we may collect usage statistics, which include:

    • Domain name (no personal data or Jira instance data is collected or processed).

    • Statistics depending on app features. For example, for the Performance Objectives app these may include: number of users, metric type usage, gadget usage, calculation mode usage, Jira mode (dark or light), and similar.

  • Sensitive Personal Information

We do not request, collect, or process sensitive personal data. If we identify sensitive data has been provided to us, we take immediate steps to delete it. If you notice any such case, please inform us at [email protected].

Data collected or obtained about prospects, job applicants and other parties

We may obtain personal data when you contact us through the following channels:

  • Data provided by you through any of the following channels:

    • Email, phone, postal services, support system, social media profiles, etc.

    • Job applications submitted by email or through relevant platforms.

  • Data Received from Third Parties

Occasionally, we may receive personal data from third parties, which may include further details about your employer or industry. For instance, we may collect data from third-party websites like LinkedIn.

Data collected or obtained about visitors on our marketplace app listing pages

As a marketplace vendor, we maintain dedicated app listing pages on the Atlassian Marketplace. These pages are governed by Atlassian’s Privacy Policy and Cookie Notice, available at:

When you visit these pages, and depending on your consent to Atlassian’s Cookie policy, we may receive site usage data for these pages gathered by cookies.

We may share this aggregated, non-personally identifiable information with our advertising and analytics partners for statistical, marketing, or promotional purposes. These partners may associate this aggregated information with other identifiable information they hold about you, such as your email address or online profile. We or our service providers may then send marketing communications and marketing to these emails or profiles.

Data collected or obtained about our website visitors at https://performance-objectives.com/ and https://devacrobats.com/

We use cookies and other tracking technologies on our websites to collect data, which may include cookie IDs, device details, IP addresses, browser types, the region or general location from which your device accesses the internet, operating system, and other aggregated usage information. This data helps us analyze website performance, track visitor movements, and gain insights into visitor preferences.

We use this information based on our legitimate interest in understanding how visitors use our websites to enhance the user experience and provide more relevant services and content.

For non-essential cookies (e.g., for analytics and marketing), we obtain your consent before placing them on your device. You can manage your cookie preferences through our cookie management tool or you browser settings.

We may share aggregated, non-personally identifiable data collected through cookies and other tracking technologies with third-party analytics and advertising partners for statistical, marketing, or promotional purposes. These partners may associate this aggregated information with other identifiable information they have about you, such as your email address or online profile. We or our service providers may then send marketing communications and marketing to these emails or profiles.

Our websites may integrate with third-party services such as YouTube, LinkedIn, or others. If you choose to share information from our websites via these services, please review their privacy policies. If you are a member of these third-party services, they may associate your visit to our sites with your personal data.

In some cases, your IP address and browser information may be processed by security plugins installed on our websites, especially if you attempt to access restricted areas. This data helps us secure our websites.

We do not combine site usage data with any personal data we may have about you as a prospect, customer, or user of our Services.

Cookies and tracking technologies

We make available a comprehensive Cookie Policy that describes the cookies and tracking technologies used on our websites and how we use them and provides information on how users can accept or reject them. For more information, please see our Cookie Policy.

  • Legal Basis: Contractual Necessity
    We process personal data to fulfill our contractual obligations with you, including providing access to our apps, delivering technical support, and providing product updates.

  • Legal Basis: Legitimate Interest. We may process your personal data based on our legitimate interests, such as:

    • To perform our duties and normal activities: responding to your inquiries, developing new functionalities, maintaining and improving our services to ensure the best possible user experience.

    • To maintain, enhance, and manage customer relationships, including collecting feedback for service improvement.

    • For statistical analysis and development: We use aggregated data to continuously improve our apps, services, and customer experience through research and development. This may involve analyzing app usage patterns and preferences to gather insights and make informed decisions, ensuring that individual users cannot be identified.

    • Communication and marketing:
      Based on our legitimate interests, we may use your contact details to send you electronic communication about our services. This includes updates on new features, tips for getting the most out of our apps during trials, reminders for license renewals, price updates, and similar communications. Occasionally we may also send you information about similar services and new apps by DevAcrobats that may interest you. You have the option to unsubscribe from such communications at any time by following the instructions provided in the message or contacting us directly. Please note that you cannot unsubscribe from essential communications related to your use of our services, such as updates about pricing, changes to our terms and conditions, or important service notifications.

    • To carry out a business transaction, such as a merger, acquisition, reorganization of our company, to facilitate the transfer of ownership or business functions.

    • Promoting User Experiences and Feedback:
      If you share your opinion as a user or provide us with an interesting use case for our apps, we may use this feedback for promotional purposes (e.g., blog posts, website content, newsletters, etc.). Company and personal information will not be included without your explicit consent.

    • To establish, exercise, or defend our legal claims or legal rights, including for litigation purposes.

    • To ensure security and prevent unauthorized access: we may process personal data to prevent fraud, ensure the integrity and security of systems, and safeguard networks and information systems against threats such as hacking, malware, and other unauthorized activities.

    • For internal administrative functions, such as business operations, auditing, and internal reporting.

    • To administer recruitment activities: we process personal data to manage recruitment processes, such as evaluating candidates’ qualifications and suitability for employment, scheduling interviews, and making hiring decisions.

  • Legal Basis: Legal Obligations. We process your personal data when required to fulfill our legal obligations, including:

    • Compliance with tax and accounting regulations.

    • Meeting industry-specific or general regulatory requirements

    • Responding to lawful requests from public authorities.

    • Handling complaints and addressing requests or concerns.

  • Consent for Specific Purposes

We may request your explicit consent for certain processing activities not covered above. For example, this could include publishing testimonials or customer success stories that feature your company or personal information. You retain the right to withdraw your consent at any time. Please note that withdrawing consent will not affect the legality of any data processing conducted prior to your withdrawal.

Sharing information with third parties

We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of our services.

The personal information DevAcrobats collects from you is stored in one or more databases hosted by third parties. These third parties do not use or have access to your personal information for any purpose other than cloud storage and retrieval. On occasion, DevAcrobats may engage third parties to send information to you, including information about our services and events.

List of DevAcrobats subprocessors

We do not otherwise reveal your personal data to non-DevAcrobats persons or businesses for their independent use unless:

  • you request or authorize it.

  • the information is provided to comply with the law (for example, compelled by law enforcement to comply with a search warrant, subpoena, or court order), enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others.

  • the information is provided to our agents, vendors or service providers who perform functions on our behalf.

  • to address emergencies or extraordinary events, such as natural disasters, extreme weather conditions, or other events beyond our reasonable control.

  • to address disputes, claims, or to persons demonstrating legal authority to act on your behalf.

  • In the event of sale, merger, acquisition, reorganization of our company, in which cases a third party may gain access to your personal data.

We do not share your personal data with any third party for their own marketing purposes.

Transferring personal data internationally

DevAcrobats has its headquarters in Bulgaria. We may transfer, process, and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you with the Services.  This may include countries outside the European Economic Area (EEA), where the level of data protection may not be deemed adequate by the European Commission (i.e., where you have fewer rights in relation to your information).

Whenever we transfer your information, we take steps to protect it. We make sure that our third-party service providers guarantee a high level of protection of personal data. Such transfer may take place:

  • to countries for which the European Commission has issued adequacy decisions on the protection of Personal Data (European Commission Adequacy Decisions) without the need to fulfil additional requirements.

  • to United States when our third-party service providers are participants in the EU-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Data Privacy Framework, and Swiss-U.S. Data Privacy Framework.

  • to United States or other countries, primarily on the basis of Standard Contractual Clauses with additional safeguards (technical and legal) and/or Binding Corporate Rules.

In certain cases, we may collect and transfer internationally personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest of DevAcrobats in a manner that does not outweigh your rights and freedoms. We endeavor to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with us and the practices described in this Privacy Policy. We also enter into data processing agreements and model clauses with our vendors whenever feasible and appropriate.

If the Service you have chosen has the possibility of data residency, you will be informed of this in its documentation.

For more information or if you have any questions, please contact us at [email protected].

Data storage and retention

DevAcrobats Ltd. is committed to protecting the personal data of its customers and users. We work hard to maintain physical, electronic and procedural safeguards to protect your information in accordance with applicable data protection requirements. However, we draw special attention to the fact that there are risks in the provision of personal information, whether this information is provided in person, by telephone, online or other media or terminal. So far, there is no system or technology that is completely safe and protected from unauthorized access or intrusion by others. We have made every effort and have provided appropriate technical and organizational measures to prevent and minimize the risks of unauthorized access and misuse of personal information.

If you use our server or data center apps, responsibility for securing storage and access to the information you put into the apps rests with you and not us. We strongly recommend that server or data center users configure SSL to prevent interception of information transmitted over networks and to restrict access to the databases and other storage points used.

Children’s data

Our services are not intended for use by children. We do not knowingly collect, solicit, or process personal data from children. If we become aware that we have inadvertently collected or processed personal information from a child, we will take immediate steps to delete such data.

Your rights regarding the data we collect and process

he European Union’s General Data Protection Regulation (GDPR) and other countries’ privacy laws provide certain rights for data subjects. Data Subject rights under GDPR include the following:

  • Right of Access to Personal Data

You have the right to request information about the personal data we process about you. You can request a copy of this data, including details about the purposes of processing, categories of data, recipients, data retention periods, and the rights available to you. We will respond to your request within one month of receiving it, and in most cases, this will be provided free of charge unless your request is manifestly unfounded or excessive.

  • Right to correct inaccurate personal data

You have the right to request the correction of inaccurate personal data and, where applicable, to have incomplete personal data completed.

  • Right of Deletion (“Right to be Forgotten”). You have the right to request the deletion of your personal data in the following cases:

    • When the data is no longer necessary for the purposes for which it was collected.

    • When you withdraw your consent, and there is no other legal basis for processing.

    • When the data has been unlawfully processed.

    • When there is a legal obligation to delete the data.

However, the right to deletion is not absolute and does not apply where processing is necessary for compliance with a legal obligation or the establishment, exercise, or defense of legal claims.

  • Right to Restrict Processing. You have the right to request the restriction of processing in the following situations:

    • If you contest the accuracy of the data, for a period enabling us to verify the data’s accuracy.

    • If the processing is unlawful and instead of deletion you request the restriction of its use.

    • If the data is no longer needed for processing, but you need it for the establishment, exercise, or defense of legal claims.

    • If you object to processing pending the verification of whether our legitimate grounds override your rights and freedoms.

In the event of a correction, deletion or restriction of processing, we will notify any recipient to whom the personal data has been disclosed, unless this is impossible or requires a disproportionate effort.

  • Right to Portability of Machine-Readable Data

You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit this data to another controller, where technically feasible. This right applies only to data processed on the basis of your consent or under a contract with you.

  • Right to Object to Processing Based on Legitimate Interest

You have the right to object to the processing of your personal data when the processing is based on our or a third party’s legitimate interest. In such cases, we will no longer process your data unless we demonstrate compelling legitimate grounds for the processing that override your interests or rights, or the processing is necessary for the establishment, exercise, or defense of legal claims.

  • Right to Object to Direct Marketing

We may use your contact information to send you more information about our apps and similar DevAcrobats Ltd. services that may be relevant to you, including communication about new apps we develop, new features of our apps, our events, etc.

You have the right to object to the processing of your personal data for direct marketing purposes. If you object, we will cease sending you marketing communications immediately. You can opt-out at any time by following the unsubscribe instructions in any marketing communication, contacting us directly, or submitting a request through our service management system.

  • Right to Withdraw Consent

You have the right to withdraw your consent at any time where we rely on your consent to process your personal data. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. To withdraw your consent, please contact us directly or follow the instructions provided in communication channels where your consent was initially obtained.

  • Right to Complain to a Supervisory Authority

You have the right to lodge a complaint with a supervisory authority in the EU, should you feel that your rights have been violated. On the territory of the Republic of Bulgaria, where the seat of DevAcrobats Ltd. is located, the supervisory body is the Commission for Personal Data Protection.

Commission for Personal Data Protection
2, Prof. Tsvetan Lazarov Blvd.
Sofia 1592
Tel. +359 2 915 3523
Fax +359 2 915 3525
e-mail: [email protected]
Website: http://www.cpdp.bg/

Questions, concerns or complaints

If you have questions, concerns, complaints, or would like to exercise your rights, please contact us at:
DevAcrobats Ltd.
Postal Address: 47 Cherni Vrah Blvd., floor 6, 1407 Sofia, Bulgaria
Email: [email protected]

We aim to respond to inquiries within one month. However, in cases of complex inquiries, an extension may be necessary.

Policy Updates

We reserve the right to update our Privacy Policy without prior notice when necessary to address specific requirements, changes in how information is collected or used, or to provide additional clarifications. Any updates will take effect upon publication on our company website. By continuing to use our services after the updated Privacy Policy is published, you acknowledge and agree to the changes.

We encourage you to review our Privacy Policy periodically to stay informed about how we protect your data. If you do not agree with the updated policy, you must discontinue the use of our services.