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Last updated: May 29th 2024
PRIVACY POLICY
1. Introduction
Divinfi Marketing Management LLC (“DIVINFI,” “we,” “us,” or “our”) is committed to protecting your privacy and ensuring that your personal data is handled in a safe and responsible manner. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website [https://divinfi.com] (“Website”) or use our services (“Services”).
2. Scope of This Policy
This Privacy Policy applies to all information collected through our Website, mobile applications, and any other related services, sales, marketing, or events (collectively referred to as “Services”). It does not apply to third-party websites or services that we do not own or control, including those linked from our Services.
3. Information We Collect
We may collect and process the following categories of personal data:
3.1. Information You Provide to Us:
3.2. Information We Collect Automatically:
3.3. Information from Third Parties:
4. How We Use Your Information
We use your personal data for the following purposes:
4.1. To Provide and Improve Our Services:
4.2. For Security and Compliance:
4.3. For Communication and Marketing:
4.4. For Analytics and Research:
5. Legal Basis for Processing Your Information
We process your personal data based on the following legal grounds:
5.1. Consent: Where you have given us explicit consent to process your personal data for specific purposes. 5.2. Performance of a Contract: Where the processing is necessary for the performance of a contract to which you are a party, such as providing our Services to you. 5.3. Legal Obligations: Where the processing is necessary to comply with our legal obligations, such as anti-money laundering (AML) and know-your-customer (KYC) requirements. 5.4. Legitimate Interests: Where the processing is necessary for our legitimate interests, such as improving our Services, ensuring security, and conducting marketing activities, provided that your interests and fundamental rights do not override those interests.
6. Sharing Your Information
We may share your personal data with the following categories of recipients:
6.1. Service Providers: We may share your information with third-party service providers that perform services on our behalf, such as identity verification, payment processing, data analysis, and customer support. 6.2. Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions. 6.3. Legal and Regulatory Authorities: We may disclose your information to law enforcement, regulatory agencies, or other authorities if required by law or to protect our rights and comply with legal obligations. 6.4. Affiliates and Subsidiaries: We may share your information with our affiliates and subsidiaries for business purposes and to provide our Services to you. 6.5. Corporate Transactions: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of the transaction.
7. Data Security
We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, use, disclosure, alteration, or destruction. These measures include encryption, access controls, and regular security assessments. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.
8. Data Retention
We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including to comply with legal, regulatory, accounting, or reporting requirements. When your personal data is no longer required for these purposes, we will securely delete or anonymize it.
9. Your Rights
You have the following rights regarding your personal data:
9.1. Access: You have the right to request access to your personal data and obtain a copy of the information we hold about you. 9.2. Rectification: You have the right to request the correction of inaccurate or incomplete personal data. 9.3. Erasure: You have the right to request the deletion of your personal data in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected. 9.4. Restriction: You have the right to request the restriction of processing of your personal data in certain circumstances, such as when you contest the accuracy of the data. 9.5. Data Portability: You have the right to request the transfer of your personal data to another organization, where technically feasible. 9.6. Objection: You have the right to object to the processing of your personal data based on legitimate interests or for direct marketing purposes. 9.7. Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw your consent at any time.
To exercise these rights, please contact us using the contact details provided below. We will respond to your request in accordance with applicable data protection laws.
10. Children’s Privacy
Our Services are not intended for children under the age of 18, and we do not knowingly collect personal data from children under 18. If we become aware that we have collected personal data from a child under 18, we will take steps to delete such information promptly. If you believe that we might have collected information from a child under 18, please contact us immediately.
11. International Data Transfers
Your personal data may be transferred to and processed in countries outside of your country of residence, including countries that may not provide the same level of data protection as your home country. We ensure that appropriate safeguards are in place to protect your personal data when transferred internationally, such as standard contractual clauses approved by relevant regulatory authorities.
12. Third-Party Websites
Our Website may contain links to third-party websites or services that are not owned or controlled by DIVINFI. This Privacy Policy does not apply to these third-party websites or services. We are not responsible for the privacy practices or the content of such third-party websites or services. We encourage you to review the privacy policies of any third-party websites or services that you visit.
13. Cookies and Similar Technologies
We use cookies and similar tracking technologies to collect and use personal data about you, including to serve interest-based advertising. For more information about the types of cookies we use, why we use them, and how you can control cookies, please see our Cookie Policy.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.
15. Contact Us
If you have any questions or concerns about this Privacy Policy, or if you would like to exercise your rights regarding your personal data, please contact us at:
DIVINFI Marketing Management LLC
Office 57, Block J06,
Saih Suhaib 2,
Dubai Industrial City, UAE
Email: [email protected]
16. Your California Privacy Rights
If you are a California resident, you have specific privacy rights under the California Consumer Privacy Act (CCPA). These include the right to know what personal information we collect, use, disclose, and sell about you, the right to request the deletion of your personal information, the right to opt-out of the sale of your personal information, and the right to non-discrimination for exercising your privacy rights.
16.1. Categories of Personal Information Collected: We collect the following categories of personal information:
16.2. Categories of Personal Information Disclosed for a Business Purpose: In the past 12 months, we have disclosed the following categories of personal information for a business purpose:
16.3. Your Rights and Choices: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. You also have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. To exercise your rights, please contact us using the contact information provided above.
17. European Economic Area (EEA) Residents
If you are a resident of the EEA, you have specific privacy rights under the General Data Protection Regulation (GDPR). These include the right to access, correct, update, or request deletion of your personal information. You also have the right to object to processing, request the restriction of processing, or request portability of your personal information.
17.1. Legal Basis for Processing: We process your personal information based on the following legal bases:
17.2. Data Protection Officer: We have appointed a Data Protection Officer (DPO) to oversee compliance with this Privacy Policy. If you have any questions or concerns about our data protection practices, you can contact our DPO at:
Data Protection Officer
DIVINFI Marketing Management LLC
Office 57, Block J06,
Saih Suhaib 2,
Dubai Industrial City, UAE
Email: [email protected]
18. Data Protection Rights for EEA Residents
18.1. Right to Access: You have the right to request access to the personal data we hold about you. This includes information about the categories of data, the purposes of processing, and any third parties with whom we share your data. 18.2. Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal data we hold about you. 18.3. Right to Erasure: You have the right to request the deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected. 18.4. Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data in certain situations, such as when you contest the accuracy of the data. 18.5. Right to Data Portability: You have the right to request that your personal data be transferred to another data controller in a structured, commonly used, and machine-readable format, where technically feasible. 18.6. Right to Object: You have the right to object to the processing of your personal data based on legitimate interests or for direct marketing purposes. 18.7. Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw your consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
19. Complaints
If you are not satisfied with our response to any complaint or believe our processing of your personal data does not comply with data protection laws, you can make a complaint to the data protection authority in your country of residence or where you believe a breach may have occurred.
20. International Data Transfers
We may transfer your personal data to countries outside the EEA, including countries that may not provide the same level of data protection as your home country. When we transfer your personal data internationally, we ensure that appropriate safeguards are in place to protect your information. These may include standard contractual clauses approved by the European Commission or other mechanisms recognized under GDPR.
21. Data Anonymization and Aggregation
We may anonymize and aggregate your personal data so that it can no longer be used to identify you. This anonymized and aggregated data may be used for various purposes, including data analysis, improving our Services, and research purposes.
22. Automated Decision-Making
We may use automated decision-making processes to improve our Services and provide a better user experience. You have the right not to be subject to decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affect you. If you are subject to automated decision-making, you can request human intervention, express your point of view, and contest the decision.
23. Marketing Communications
With your consent, we may send you marketing communications about our products and services, special offers, and other news that we think may interest you. You can opt-out of receiving marketing communications at any time by following the unsubscribe instructions provided in the communication or by contacting us directly.
24. Behavioral Advertising
We may use your personal data to provide you with personalized advertisements based on your interests and browsing behavior. This process is known as behavioral advertising. You can control your preferences regarding behavioral advertising through your browser settings and other tools provided by our partners.
25. Social Media Features
Our Services may include social media features, such as the Facebook “Like” button and widgets, such as the “Share” button or interactive mini-programs that run on our Website. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing them.
26. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. When we make changes to this Privacy Policy, we will update the “Effective Date” at the top of this page. If we make material changes to this Privacy Policy, we will provide you with notice as required by law.
27. Contact Information
If you have any questions or concerns about this Privacy Policy or our data protection practices, please contact us at:
DIVINFI Marketing Management LLC
Office 57, Block J06,
Saih Suhaib 2,
Dubai Industrial City, UAE
Email: [email protected]
29. Language
This Privacy Policy may be provided in languages other than English. In the event of any inconsistencies or conflicts between the English version and versions in other languages, the English version shall prevail.
30. Final Provisions
This Privacy Policy is governed by and shall be construed in accordance with the laws of the Republic of Lithuania, without regard to its conflict of law principles. Any disputes arising under or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of the Republic of Lithuania.
Divinfi is an ecosystem simplifying and securing your crypto investments, and helping you to to achieve financial and personal freedom.
Divinfi MM LLC
Office 57, Block J06 saih suhaib 2 Dubai Industrial City,
Dubai, U.A.E
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