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Privacy Policy
Last updated: 6 May, 2021

Divi Labs And Technologies, S.A. ("Divi Labs ," " we ," " our ," and/or " us") aims to solve the issues of usability and accessibility to cryptocurrencies by creating software solutions that make cryptocurrency easier to use and access for users of all levels. Divi Labs offers a cryptocurrency called 'Divi' along with a smart wallet called Divi Labs Wallet which works with Divi, as well as certain third party cryptocurrencies. Divi Labs Wallet is available as a desktop app which can be downloaded from our website (the "Desktop App"), and mobile apps available for iOS and Android (together, the "Mobile App") (the Desktop App and the Mobile App together being the "App").

This privacy policy (the "Privacy Policy") explains how we collect, use, and disclose Personal Data from users of our websites (including diviproject.org and diviwallet.com (the "Websites")), applications (including the Desktop App and Mobile App), and services that link to this Privacy Policy (collectively, our " Services"). For the purposes of this Privacy Policy, "Personal Data" means information that relates to an identified or identifiable natural person.

By using our Services, you confirm that you have read and understood our practices regarding the collection, use, and disclosure of your Personal Data as described in this Privacy Policy. Beyond this Privacy Policy, your use of our Services is also subject to our Terms of Service. If you are a California resident, please view our California Notice At Collection And Privacy Notice for information about your California privacy rights and how you can exercise those rights.

The Divi Labs Wallet is a non-custodial crypto asset software wallet. We do not require you to provide certain Personal Data (such as your name or email address) to sign up to the Divi Labs Wallet although please note that certain Personal Data relating to your mobile and desktop devices (for example, your IP address or device identifier) is collected automatically.

Certain third party services that we make available within the Divi Labs Wallet may require you to provide Personal Data to the providers of such services in order to use the Services and third party services. Personal Data collected by any such third party service is subject to the privacy policy of the third party provider of that service.

Table of Contents

  1. Jurisdiction-specific Disclosures
  2. Personal Data We Collect
  3. How We Use Personal Data
  4. How We Share and Disclose Personal Data
  5. Cookies and Similar Technologies
  6. Retention
  7. Third Parties
  8. Nevada Resident Rights
  9. Contact Information
  10. Changes to this Privacy Policy
  1. Jurisdiction-specific Disclosures
  2. If you are a resident of or located in certain states, regions or countries, there may be privacy laws that require different or additional disclosures which may apply to your use of our Services, as set forth below.

    • If you are a resident of the State of California, pleaseclick here for additional California-specific privacy disclosures.
    • If you are a resident of the State of Nevada, pleaseclick here for additional Nevada-specific privacy disclosures,
  3. Personal Data We Collect
  4. We may collect Personal Data from or about you or your devices from various sources, as described below.

    If you use our Mobile App

    Information You Provide to Us. When you sign up for our Mobile App you have the option to create a profile, and provide us with your phone number (other users who know your phone number will be able to search for your profile if you allow this), your email address (other users who know your email address will be able to search for your profile if you allow this), name, a username, and a profile picture.

    If you do choose to provide your phone number and/or email address, we require this information to be verified using third party providers (e.g. Twilio and Mailgun). Our providers keep your phone number and/or email address for up to 400 days and 30 days respectively as per their data retention policies.

    Please note that if you provide us with your email address at the sign-up stage, we will use your email address to send you service messages and marketing messages (where permitted by applicable law).

    When you provide payment information to use our paid Services or exchange currency for cryptocurrency via our Services, we keep a record of these transactions. Payments through our Mobile App are processed by our third-party payment provider, Stripe. We do not directly collect or process your payment card information or bank account details.

    If you contact our helpdesk (powered by Zendesk), you will need to provide a contact email address and details about the issue so that we can provide you with support. You do not need to provide other details such as your name although we ask for this in order to personalize our support service. We keep logs of helpdesk requests to help us track issues that occur.

    Information We Collect Automatically or Generate when You Use the Mobile App. We automatically collect some information about you and your devices when you use the Mobile App, such as device identifiers, your IP address and your location, and the app version you are using. We also collect information about how you use our Mobile App and process details about your account and transactions to and from your account.

    If you use our Desktop App

    Information You Provide to Us. When you sign up for our Desktop App you have the option to create a profile and provide us with your email address and a username.

    Please note that if you provide us with your email address at the sign-up stage, we will use your email address to send you service messages and marketing messages (where permitted by applicable law).

    When you provide payment information to use our paid Services or exchange currency for cryptocurrency via our Services, we keep a record of these transactions. Payments through our desktop App are processed by our third-party payment provider, PayPal. We do not directly collect or process your payment card information or bank account details.

    If you contact our helpdesk (powered by Zendesk), you will need to provide a contact email address and details about the issue so that we can provide you with support. You do not need to provide other details such as your name although we ask for this in order to personalize our support service. We keep logs of helpdesk requests to help us track issues that occur.

    Information We Collect Automatically or Generate when You Use the Desktop App. We automatically collect some information about you and your devices when you use the Desktop App, such as device identifiers, your IP address and your location, and browser type you are using. We also collect information about how you use our Desktop App and process details about your account and transactions to and from your account.

    If you visit our Websites

    Information You Provide to Us. We collect your email address when you sign up to receive our email newsletters.

    Information We Collect Automatically or Generate when You Use our Websites. We automatically collect some information about you and your devices when you use our Websites, such as device identifiers, your IP address and your location, and browser type you are using.

  5. How we use Personal Data
  6. We use the Personal Data we collect for the following purposes:

    • to allow you to send and receive cryptocurrencies globally;
    • to allow you to earn rewards for supporting the Divi network;
    • to facilitate subscription payments for the use of the Services, the exchange of currency for cryptocurrency and vice versa;
    • to allow other users of the App to find and interact with you;
    • to notify you when you receive cryptocurrencies or earn rewards or to send you other personalized notifications;
    • to communicate with you, provide you with updates and other service information relating to the Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
    • to help maintain the safety, security and integrity of the Services, technology assets, and our business;
    • to help us improve and enhance our Services, data analytics, identifying usage trends, and preventing fraud;
    • to respond to law enforcement requests and as required by applicable law, court order or governmental regulations, to enforce our corporate reporting obligations and our Terms of Service, or to comply with applicable laws;
    • to send you marketing information about our offers and Services;
    • to keep records of financial transactions;
    • to serve advertisements on third party networks.

    Marketing Communications. You may unsubscribe from any promotional emails via the link provided in the emails. Please note that if you opt out of receiving promotional messages from us, you will continue to receive administrative or service messages from us.

  7. How we Share and Disclose Personal Data
  8. In certain circumstances we may share your Personal Data with third parties where this is required in order for the performance of our contract with you, where it is required by law, where we have another legitimate interest in doing so, or otherwise with your consent, for the purposes described above as follows:

    • Affiliates. We may share any information we receive with our affiliates for any of the purposes described in this Privacy Policy.
    • Analytics Partners. We use analytics services such as Google Analytics, Google Firebase, BigQuery and DataStudio to collect and process certain analytics data.
    • Vendors and Service Providers. We may share your information with vendors and service providers retained in connection with the provision of our Services, such as Zendesk who operate our Help Center, and Mailchimp who send out emails for us.
    • Other App users. Where you have set your settings to allow yourself to be searchable by other App users who know your email address or phone number.
    • As Required by Law and Similar Disclosures. We may access, preserve, and disclose your Personal Data if we believe doing so is required or appropriate to: (i) comply with applicable laws; (ii) respond to law enforcement requests and legal process, such as a court order or subpoena; or (iii) protect the rights, property, and safety of Divi Labs, our employees, agents, customers, and others, including to enforce our agreements, policies, and Terms of Service.
    • Merger, Sale, or Other Asset Transfers We may transfer your Personal Data to advisors and other service providers, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merge with another company, or we sell, liquidate, or transfer all or a portion of our assets.
    • Advertising Partners We may share your Personal Data with advertising partners in order to serve targeted advertisements to users. Please refer to ourCookies Policy for further information about your choices and rights in relation to online advertising.
  9. Cookies and Similar Technologies
  10. We and service providers engaged by Divi or our partners use cookies, SDKs, web beacons, tracking pixels and other similar technologies to understand usage of our Services, improve our content and offerings and deliver advertisements in which you might be interested. These technologies are small data files downloaded to or stored on your computer, tablet, mobile phone or other internet-enabled device that enable us to record certain pieces of information whenever you interact with our Services.

    We permit third parties to use technologies on our Services to collect information about your device and your use of our Services to advertise products and services to you that are tailored to your perceived interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. For example, one such third party vendor, Google, shows our ads and uses cookies to serve ads based on a user's prior visits to our Services. We also use data analytics to serve ads based on a user's prior visits to our Services. More information about Google Ads is available atthis link.

    Further information about our use of cookies and similar technologies and your choices in relation to them is in ourCookies Policy.

  11. Retention
  12. We keep Personal Data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and our legitimate interests in maintaining such Personal Data in our records. In doing this we will take into account the amount, nature, and sensitivity of the Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and applicable legal requirements. Generally, we keep information relevant to our dealings with you for as long as you maintain your profile. Once you delete your profile, all of your Personal Data relating to your profile (any information that you have given to us such as your name, email address, profile picture, username, phone number, and your account and transaction data) is deleted.

  13. Third Parties
  14. Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy and advertising practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any Personal Data you disclose to these third parties. We encourage you to read their privacy policies before providing any Personal Data to them.

  15. Nevada Resident Rights
  16. You have the right to request that we do not sell your covered information (as those terms are defined under Nevada law) that we have collected or will collect about you. We do not sell your covered information at this time. If you would like additional information, please contact us at info@diviproject.org..

  17. Contact Information
  18. We welcome your comments or questions regarding our privacy practices. If you have questions about your privacy on the Services or this Privacy Policy, you may contact us at the address below info@diviproject.org

  19. Changes To This Privacy Policy
  20. We will post updates to the Privacy Policy on this page and, if you use our mobile App, notify you of updates, including if we make material changes to how we process your Personal Data previously collected from you through the Services, or as required by applicable law. The revised version will be effective when it is posted or as required by applicable law.

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