1. Introduction
Welcome to DevolApp (“we,” “our,” or “us”). We are a mobile app development company based in Cambodia, providing custom application development services through our website www.devolapp.com.
This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our services, or communicate with us. We respect your privacy and are committed to protecting your personal data in accordance with Cambodia’s data protection standards and international best practices.
By accessing or using our services, you agree to the terms of this Privacy Policy. If you do not agree with our policies and practices, please do not use our services.
2. Information We Collect
2.1 Personal Information
We may collect the following types of personal information:
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Identity Data: Name, username, or similar identifiers
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Contact Data: Email address, phone number, business address, and other contact details
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Technical Data: Internet protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform
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Usage Data: Information about how you use our website and services
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Communication Data: Your preferences in receiving marketing communications from us and our third parties
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Project Data: Information related to your mobile app development projects
2.2 Methods of Collection
We collect information through:
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Direct interactions when you fill in forms on our website
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Automated technologies or interactions through cookies and similar tracking technologies
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Third parties or publicly available sources (such as business directories)
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Communications via email, phone, or other channels
2.3 Legal Basis for Collection
We collect your personal information based on:
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Your consent
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Necessity for performing our contract with you
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Compliance with legal obligations
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Our legitimate interests (such as business development)
3. How We Use Your Information
3.1 Purpose of Data Processing
We use your personal information for the following purposes:
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To provide and maintain our services
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To notify you about changes to our services
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To allow you to participate in interactive features of our services
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To provide customer support
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To gather analysis or valuable information to improve our services
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To monitor the usage of our services
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To detect, prevent, and address technical issues
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To provide you with news, special offers, and general information about other services we offer
3.2 Marketing Communications
We may use your data to form a view on what services may be of interest to you. You will receive marketing communications from us if you have requested information from us, purchased services from us, or if you provided us with your details when registering for a promotion.
You can opt out of receiving marketing communications at any time by following the opt-out links on any marketing message sent to you or by contacting us directly.
4. Data Sharing and Disclosure
4.1 Third-Party Service Providers
We may share your information with:
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IT and system administration service providers
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Professional advisers including lawyers, bankers, auditors, and insurers
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Regulatory authorities and other organizations when required by law
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Business partners who provide services as part of our mobile app development process
4.2 International Data Transfers
We may transfer your personal data to countries outside Cambodia. When we do, we ensure a similar degree of protection is afforded to your data through appropriate safeguards, such as:
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Using specific contracts approved for data transfers
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Ensuring countries have adequate data protection laws
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Obtaining your explicit consent for the transfer
4.3 Google Ads
We use Google Ads to promote our services. When you interact with our Google Ads:
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Google may collect information about your interactions
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We receive aggregated data about the effectiveness of our advertising
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We implement Google’s data protection requirements for advertisers
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We obtain appropriate consent for personalized advertising
5. User Rights
5.1 Your Rights Under Cambodian Law
While Cambodia is still developing comprehensive data protection legislation, we respect internationally recognized data protection rights. You have the right to:
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Access your personal data
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Correct inaccurate personal data
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Delete your personal data under certain circumstances
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Object to processing of your personal data
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Request restriction of processing your personal data
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Request transfer of your personal data
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Withdraw consent where we rely on consent to process your personal data
5.2 How to Exercise Your Rights
To exercise any of these rights, please contact us using the details provided in the “Contact Us” section. We will respond to your request within 30 days.
5.3 No Fee Usually Required
You will not have to pay a fee to access your personal data or to exercise any of your other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.
6. Data Security
6.1 Security Measures
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. These measures include:
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Encryption of sensitive data
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Secure server infrastructure
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Regular security assessments
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Access controls and authentication procedures
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Staff training on data protection
6.2 Data Retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider:
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The amount, nature, and sensitivity of the personal data
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The potential risk of harm from unauthorized use or disclosure
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The purposes for which we process your personal data
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Whether we can achieve those purposes through other means
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The applicable legal requirements
6.3 Data Breach Procedures
In the event of a data breach that may affect your personal information, we will notify you and any applicable regulator when we are legally required to do so.
7. Cookies and Tracking Technologies
7.1 What Are Cookies
Cookies are small text files that are placed on your device when you visit our website. They allow us to recognize your device and store certain information about your preferences or past actions.
7.2 Types of Cookies We Use
We use the following types of cookies:
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Essential Cookies: Required for the operation of our website
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Analytical/Performance Cookies: Allow us to recognize and count visitors and see how visitors move around our website
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Functionality Cookies: Used to recognize you when you return to our website
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Targeting Cookies: Record your visit to our website, the pages you have visited, and the links you have followed
7.3 Managing Cookies
Most web browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may impact your overall user experience.
8. Google Ads Privacy Compliance
8.1 Data Collection for Advertising
When you interact with our Google Ads:
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We collect data about ad impressions, clicks, and conversions
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Google may use cookies to personalize ads based on your browsing behavior
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We implement data minimization principles for advertising data
8.2 User Consent Requirements
We obtain appropriate consent for personalized advertising in accordance with Google’s advertising policies and applicable laws. This includes:
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Clear disclosure about data collection for advertising purposes
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Option to opt out of personalized advertising
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Compliance with Google’s 2025 policy updates regarding user engagement verification and privacy enhancement
8.3 Opt-Out Options
You can opt out of personalized advertising by:
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Adjusting your Google Ad Settings
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Using browser privacy controls
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Contacting us directly to request exclusion from targeted advertising
9. Cambodia-Specific Legal Compliance
9.1 E-Commerce Law (2019)
We comply with Cambodia’s E-Commerce Law (2019), which includes provisions related to:
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Electronic communications
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Consumer protection
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Data protection in commercial transactions
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Requirements for online business operations
9.2 Draft Law on Personal Data Protection
While Cambodia’s comprehensive Law on Personal Data Protection (LPDP) remains in draft form, we align our practices with its core principles, including:
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Lawfulness, fairness, and transparency in data processing
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Purpose limitation
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Data minimization
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Accuracy
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Storage limitation
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Integrity and confidentiality
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Accountability
9.3 Sub-Decree No. 252
We respect the provisions of Sub-Decree No. 252 (December 2021) regarding the management of personal identification data, though it primarily applies to data managed by the Ministry of Interior.
10. Children’s Privacy
Our services are not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe your child has provided us with personal information, please contact us, and we will take steps to delete such information.
11. Third-Party Links
Our website may contain links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy policy of every website you visit.
12. Policy Updates
12.1 Changes to This Privacy Policy
We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Last Updated” date at the top of this Privacy Policy.
12.2 Notification of Changes
If we make material changes to this Privacy Policy, we will notify you either through the email address you have provided us or by placing a prominent notice on our website.
13. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us at:
DevolApp
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Email: contact@devolapp.com
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Phone: (+855) 15 996 296
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Address: Phum Wat Bo, Sala Kamreuork, Siem Reap, Cambodia.
14. Definitions
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Personal Data: Any information relating to an identified or identifiable natural person.
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Processing: Any operation performed on personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination, or otherwise making available.
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Data Controller: The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
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Data Processor: A natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
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Consent: Any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they signify agreement to the processing of personal data relating to them.
This Privacy Policy was last updated on March 22, 2025. It is effective as of this date.