LEGAL
Privacy Policy
How Devagent collects, uses and protects personal data when you use our website, products and services.
Last updated: July, 3, 2026
This Privacy Policy explains how Devagent collects, uses, stores and protects personal data when you visit our website, contact us, purchase or use our digital products, request support, or work with us on software, website, WordPress, plugin, app or AI-assisted development projects.
Devagent operates from Spain and processes personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the Spanish Organic Law 3/2018 on Personal Data Protection and Digital Rights (“LOPDGDD”), and other applicable Spanish and European data protection rules.
1. Who we are
Devagent is the commercial name used by Gustavo Daniel Sangiovanni Bajo, a self-employed professional established in Spain.
The data controller is:
Gustavo Daniel Sangiovanni Bajo, trading as Devagent
Business/fiscal address: Camino Real de la Carihuela 2, Bajo C, 29630 Benalmádena, Málaga, Spain
Tax ID: NIF 18513212Y
Email: contacto@devagent.es
For privacy-related requests, you may contact us at contacto@devagent.es.
2. Scope of this policy
This policy applies to personal data processed through:
- the website devagent.es;
- contact forms, email communications and support requests;
- customer accounts, purchases, licences, downloads and billing processes;
- Devagent digital products, including WordPress plugins and add-ons;
- software, website, app, WordPress, maintenance and AI-assisted development services;
- technical diagnostics, logs, project files or documentation voluntarily provided by clients.
When Devagent develops, maintains or supports a website, app, plugin or software system for a client, Devagent may process personal data on behalf of that client. In that case, the client is normally the data controller and Devagent acts as a data processor. That processing should be governed by a separate contract or Data Processing Agreement where required.
3. Personal data we may collect
Depending on your interaction with Devagent, we may process the following categories of personal data:
3.1 Contact and identification data
Name, surname, email address, phone number, company name, role, country, website URL, social or professional profile, and any information you provide when contacting us.
3.2 Customer, account and purchase data
Account details, username, email address, billing data, invoice data, purchase history, licence keys, subscription status, renewal status, refund requests, product downloads and support eligibility.
We do not intentionally store full payment card details on our own systems. Payments are processed through third-party payment providers.
3.3 Communications and support data
Messages, support tickets, emails, bug reports, screenshots, technical descriptions, project notes, documentation and any attachments you send to us.
3.4 Project and technical data
When you request development, maintenance, migration, debugging, integration or AI-assisted software services, we may process project-related data such as source code, configuration files, logs, database samples, URLs, server information, WordPress administrator information, plugin/theme information, API documentation, credentials or temporary access details.
You should avoid sending personal data, production database exports, credentials, secrets, API keys or confidential third-party information unless they are strictly necessary for the requested service and you are authorised to share them.
3.5 Website and device data
IP address, browser type, device information, operating system, pages visited, date and time of access, referring URLs, security logs and other technical data generated by your use of the website.
3.6 Marketing preferences
Newsletter subscription status, consent records, email preferences, unsubscribe requests and communication history.
3.7 Cookies and similar technologies
We may use cookies or similar technologies for technical operation, security, analytics or user preferences. Non-essential cookies will only be used where legally permitted and, when required, after obtaining your consent.
More information will be available in our Cookie Policy.
4. Why we process personal data and legal bases
We process personal data only when we have a lawful basis to do so.
Purpose
To respond to enquiries, quote requests or project discussions
Legal basis
Pre-contractual steps, legitimate interest
To provide software, website, WordPress, plugin, app, maintenance or AI-assisted development services
To manage customer accounts, licences, purchases, renewals, downloads and support
Performance of a contract
Performance of a contract
To issue invoices, manage accounting and comply with tax obligations
Legal obligation
To provide technical support, debugging, maintenance and security assistance
Performance of a contract, legitimate interest
To improve our website, products, services and documentation
Legitimate interest, consent where required
To use analytics or non-essential cookies
Consent
To send newsletters or commercial communications
Consent, or legitimate interest where legally permitted for existing customer relationships
To prevent fraud, abuse, unauthorised access or security incidents
Legitimate interest, legal obligation
To establish, exercise or defend legal claims
Legitimate interest, legal obligation
5. AI-assisted processing
Devagent may use AI-assisted tools to support software development, code generation, debugging, documentation, analysis, project planning or customer support.
Where AI tools are used, we aim to minimise the personal data included in prompts, files, logs or project materials. You should not provide personal data, confidential information, credentials, secrets or production data unless it is strictly necessary for the requested service.
When personal data is processed through third-party AI service providers, we will apply appropriate contractual, technical and organisational safeguards according to the nature of the service, the data involved and the applicable transfer mechanism.
AI-assisted outputs may require human review. Devagent does not rely on fully automated decision-making that produces legal or similarly significant effects on individuals.
6. WordPress plugins and digital products
Devagent may develop and distribute WordPress plugins, add-ons and other digital products.
When a Devagent plugin runs on your own WordPress website, the personal data processed inside that website is normally controlled by you as the site owner. Devagent only receives such data if you send it to us, for example through a support request, diagnostic report, licence activation, connected service or another explicit interaction with Devagent.
You are responsible for ensuring that your own website, store, booking system, forms, checkout, analytics and plugins comply with applicable privacy, consumer protection and cookie rules.
7. Who may receive personal data
We may share personal data with the following categories of recipients where necessary:
- hosting, server, security and infrastructure providers;
- email, contact form, CRM or support ticket providers;
- payment processors and billing tools;
- analytics providers, only where enabled and legally permitted;
- AI, development, debugging or productivity service providers;
- subcontractors or collaborators involved in a client project, where authorised or necessary;
- accountants, legal advisors, tax advisors or professional service providers;
- public authorities, courts or regulators where legally required.
We do not sell personal data.
8. International data transfers
Some providers may process data outside the European Economic Area. Where this happens, we will use appropriate safeguards such as adequacy decisions, Standard Contractual Clauses or other mechanisms recognised by applicable data protection law.
9. How long we keep personal data
We keep personal data only for as long as necessary for the purpose for which it was collected, unless a longer retention period is required or permitted by law.
As a general rule:
- contact enquiries may be kept for the time necessary to respond and follow up;
- customer, account, licence and purchase data may be kept while the customer relationship remains active and for the period required for legal, accounting and tax obligations;
- invoices and accounting records are kept according to applicable Spanish legal requirements;
- support communications may be kept to provide continuity, improve products and defend possible claims;
- project materials are kept during the project and for the agreed support, warranty or maintenance period, unless a different retention period is agreed;
- marketing data is kept until you unsubscribe or withdraw consent;
- security logs may be kept for a limited period to protect systems and investigate incidents;
- backup copies are deleted according to normal backup rotation cycles.
When data is no longer needed, we will delete it, anonymise it or securely restrict access to it.
10. Security measures
We apply technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure, loss or destruction.
These measures may include access controls, password protection, encrypted connections, secure hosting, backups, limited access permissions, software updates, security monitoring and internal confidentiality practices.
No online service can be guaranteed to be completely secure. You are responsible for using strong passwords, protecting your own systems and avoiding the unnecessary transmission of sensitive or confidential information.
11. Your rights
You may exercise the following rights under applicable data protection law:
- right of access;
- right to rectification;
- right to erasure;
- right to restriction of processing;
- right to data portability;
- right to object;
- right to withdraw consent at any time, where processing is based on consent;
- right not to be subject to solely automated decisions that produce legal or similarly significant effects.
To exercise your rights, contact us at contact@devagent.es and clearly identify the right you wish to exercise.
We may need to verify your identity before responding to your request. We will respond within the legally required timeframe.
You also have the right to lodge a complaint with the Spanish Data Protection Agency, Agencia Española de Protección de Datos (AEPD), through its official website.
12. Cookies
Our website may use technical cookies that are necessary for the website to function. We may also use analytics, preference or marketing cookies where legally permitted and, when required, after obtaining your consent.
You can manage or withdraw cookie consent through the cookie settings available on the website.
More information will be provided in our Cookie Policy.13. Commercial communications
We will only send newsletters or commercial communications when we have a lawful basis to do so.
You can unsubscribe from marketing communications at any time by using the unsubscribe link in the email or by contacting us at contact@devagent.es.
Even if you unsubscribe from marketing communications, we may still send transactional, contractual, support, billing, licence or security-related messages where necessary.
14. Children
Devagent’s website, products and services are intended for professionals, companies and adult users. We do not knowingly collect personal data from children through this website.
If you believe that a child has provided personal data to us without appropriate authorisation, please contact us so that we can review and delete the information where appropriate.
15. Third-party links
The website may contain links to third-party websites, platforms, repositories, marketplaces, documentation, payment providers or services.
We are not responsible for the privacy practices, content or security of third-party websites. You should review their privacy policies before providing personal data to them.
16. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our website, products, services, providers or legal obligations.
When we make significant changes, we will update the “Last updated” date and, where appropriate, provide additional notice.
17. Contact
For questions about this Privacy Policy or the processing of your personal data, contact:
Devagent
Email: contacto@devagent.es
Website: devagent.es