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DIVI LABS
CALIFORNIA NOTICE AT COLLECTION AND PRIVACY NOTICE

Last Updated: 5 October, 2021

This Divi Labs California Notice at Collection and Privacy Notice (“Notice”) should be read in conjunction with the Divi Labs Privacy Policy. 

This Notice applies to information we collect or otherwise process about you when you use the Divi Labs Wallet desktop app and mobile application (together, the “App”).  This Notice explains how we process Personal Information from users of our websites (including diviproject.org and diviwallet.com (the “Websites”)), applications (including the App), or services that link to this Privacy Policy (collectively, our “Services”).  We have adopted this Notice pursuant to the California Consumer Privacy Act (CCPA) which applies to residents of the State of California (“you”).

  1. Notice at Collection

We may collect the following categories of Personal Information about you:

  • Identifiers, such as name, email address, phone number, photograph, IP address or mobile device identifier and temporary device identifiers.
  • Internet or Other Electronic Network Activity, such as website or mobile application interactions.
  • Geolocation data (through your IP address).

We may use your Personal Information 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 use of the Services.    
  • To allow other users of the Services to find and interact with you.
  • To notify you when you receive cryptocurrencies, earn rewards, or for other similar purposes.
  • 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 facilitate the connection of third-party services or applications.
  • For the internal operations of the Services, such as data analytics, audits, fraud prevention, enhancing the Services, improving the Services, including by developing new features, and identifying usage trends.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations and enforce our corporate reporting obligations and our Terms of Use, or to comply with applicable laws.
  • To send you marketing information about our offers and Services.
  • To keep records of financial transactions.
  • To contract with service providers to perform services on our behalf, including providing customer service, verifying customer information, providing analytic services, or providing similar services on behalf of the business.
  • To serve advertisements on third party networks.
  1. Collection, Use, and Disclosure of Personal Information

The tables below sets out the categories of Personal Information that we collect from you, the sources from which we have obtained your Personal Information, the purpose for which it is collected and the categories of third parties and other entities with whom we have shared your Personal Information. The tables below set out our relevant practices over the last 12 months. Our collection, use and disclosure of Personal Information depends on your relationship with us and your interaction with the Services, including the App.

If you use our mobile App

Category of Personal Information

Categories of Sources

Business or Commercial Purpose  

Categories of Third Parties and Other Entities With Whom We May Share

Identifiers, such as name, email address, phone number, photograph, IP address or mobile device identifier and temporary device identifiers.

  • Directly from you.
  • Indirectly from your browser or device.
  • Our business partners (including analytics providers) and affiliates.
  • To allow users to send and receive cryptocurrencies.
  • To allow users to earn rewards.    
  • To facilitate subscription payments for use of the Services.    
  • To allow users of the Services to find and interact with each other.
  • To notify users when they receive cryptocurrencies, earn rewards, etc.
  • To communicate with users.
  • To help maintain the safety, security, and integrity of the Services.
  • To facilitate the connection of third-party services or applications.
  • For the internal operations of the Services, such as data analytics, audits, fraud prevention, etc.
  • To respond to law enforcement requests and as required by applicable law.
  • To send you marketing information about our offers and Services.
  • To keep records of financial transactions.
  • Our affiliates.
  • Service providers and third-parties we engage, including analytics and technical support providers.
  • Legal authorities as required by law or to protect our rights.
  • Affiliated and nonaffiliated third parties as may be permitted or required by law (such as in connection with the sale or restructuring of all or part of our business).

Internet or Other Electronic Network Activity, such as website or mobile application interaction, App version, etc.

  • Indirectly from your browser or device.
  • Our business partners (including analytics providers) and affiliates.
  • To notify users when they receive cryptocurrencies, earn rewards, etc.    
  • To communicate with users.
  • To facilitate the connection of third-party services or applications.
  • For the internal operations of the Services, such as data analytics, audits, fraud prevention, etc.
  • To respond to law enforcement requests and as required by applicable law.
  • To send you marketing information about our offers and Services.
  • To keep records of financial transactions.
  • To contract with service providers to perform services on our behalf.
  • To serve advertisements on third party networks.
  • Our affiliates.
  • Service providers and third-parties we engage, including analytics and technical support providers.
  • Legal authorities as required by law or to protect our rights.
  • Affiliated and nonaffiliated third parties as may be permitted or required by law (such as in connection with the sale or restructuring of all or part of our business).

Geolocation data (IP address).

  • Indirectly from your browser or device.
  • Our business partners (including analytics providers) and affiliates.
  • To allow users to swap  cryptocurrencies.
  • To send you marketing information about our offers and Services.
  • To keep records of financial transactions.
  • To contract with service providers to perform services on our behalf.
  • To serve advertisements on third party networks.    
  • Our affiliates.
  • Service providers and third-parties we engage, including analytics providers.
  • Legal authorities as required by law or to protect our rights.
  • Affiliated and nonaffiliated third parties as may be permitted or required by law (such as in connection with the sale or restructuring of all or part of our business).

     If you use our desktop App

Category of Personal Information

Categories of Sources

Business or Commercial Purpose  

Categories of Third Parties and Other Entities With Whom We May Share

Identifiers, such as, email address, phone numbers, or IP address.

  • Directly from you.
  • Indirectly from your browser or device.
  • Our business partners (including analytics providers) and affiliates.     
  • To allow users to send and receive cryptocurrencies.
  • To allow users to earn rewards.    
  • To facilitate subscription payments for use of the Services.    
  • To allow users of the Services to find and interact with each other.
  • To notify users when they receive cryptocurrencies, earn rewards, etc.
  • To communicate with users.
  • To help maintain the safety, security, and integrity of the Services.
  • To facilitate the connection of third-party services or applications.
  • For the internal operations of the Services, such as data analytics, audits, fraud prevention, etc.
  • To respond to law enforcement requests and as required by applicable law.
  • To send you marketing information about our offers and Services.
  • To keep records of financial transactions.
  • To contract with service providers to perform services on our behalf.
  • Our affiliates.
  • Service providers and third-parties we engage, including analytics and technical support providers.
  • Legal authorities as required by law or to protect our rights.
  • Affiliated and nonaffiliated third parties as may be permitted or required by law (such as in connection with the sale or restructuring of all or part of our business).

Internet or Other Electronic Network Activity, such as website or mobile application interaction, browser type, etc.

  • Indirectly from your browser or device.
  •      Our business partners (including analytics providers) and affiliates.     
  • For the internal operations of the Services, such as data analytics, audits, fraud prevention, etc.
  • Our affiliates.
  • Service providers and third-parties we engage, including analytics and technical support providers.
  • Legal authorities as required by law or to protect our rights.
  • Affiliated and nonaffiliated third parties as may be permitted or required by law (such as in connection with the sale or restructuring of all or part of our business).

Geolocation data (IP address).

  • Indirectly from your browser or device.
  •      Our business partners (including analytics providers) and affiliates.     
  • For the internal operations of the Services, such as data analytics, audits, fraud prevention, etc.
  • To send you marketing information about our offers and Services.
  • To keep records of financial transactions.    
  • Our affiliates.
  • Service providers and third-parties we engage, including analytics providers.
  • Legal authorities as required by law or to protect our rights.
  • Affiliated and nonaffiliated third parties as may be permitted or required by law (such as in connection with the sale or restructuring of all or part of our business).

If you use our Websites

Category of Personal Information

Categories of Sources

Business or Commercial Purpose  

Categories of Third Parties and Other Entities With Whom We May Share

Identifiers, such as, email address, online identifiers, or IP address.

  • Directly from you.
  • Indirectly from your browser or device.
  • To communicate with you and provide you with newsletters and other materials that you’ve requested from us.
  • For the internal operations of the Services, such as data analytics, audits, fraud prevention, etc.
  • To send you marketing information about our offers and Services.
  • To keep records of financial transactions.    
  • Our affiliates.
  • Service providers and third-parties we engage, including analytics providers.
  • Legal authorities as required by law or to protect our rights.
  • Affiliated and nonaffiliated third parties as may be permitted or required by law (such as in connection with the sale or restructuring of all or part of our business).

Internet or Other Electronic Network Activity, such as website interaction.

  • Indirectly from your browser or device.
  • To communicate with you and provide you with newsletters and other materials that you’ve requested from us.
  • For the internal operations of the Services, such as data analytics, audits, fraud prevention, etc.
  • To send you marketing information about our offers and Services.
  • To keep records of financial transactions.
  • Our affiliates.
  • Service providers and third-parties we engage, including analytics providers.
  • Legal authorities as required by law or to protect our rights.
  • Affiliated and nonaffiliated third parties as may be permitted or required by law (such as in connection with the sale or restructuring of all or part of our business).

Geolocation data (IP address).

  • Indirectly from your browser or device.
  • To communicate with you and provide you with newsletters and other materials that you’ve requested from us.
  • For the internal operations of the Services, such as data analytics, audits, fraud prevention, etc.
  • To send you marketing information about our offers and Services.
  • To keep records of financial transactions.
  • Our affiliates.
  • Service providers and third-parties we engage, including analytics providers.
  • Legal authorities as required by law or to protect our rights.
  • Affiliated and nonaffiliated third parties as may be permitted or required by law (such as in connection with the sale or restructuring of all or part of our business).

How We Share Personal Information

We do not “sell” Personal Information to third parties as that term is term is defined in the CCPA.

  1. Your Rights

To Exercise Your Right to Know or Right to Deletion

Right to Know: California residents may make up to two requests to know within a 12-month period. If you would like to exercise your rights, contact us at support@diviproject.org or call us at +1 (855) 348-4084.

Right to Deletion: California residents may contact us at support@diviproject.org or call us at +1 (855) 348-4084 to request that we delete your Personal Information.

Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising any of the rights described above.

Verification: We will need to verify your identify before processing your request. In order to verify your identity, we will generally either require you to login to your account or we must be able to match certain information you provide us to the information we maintain about you. Certain requests may require us to obtain additional Personal Information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

Minors Under Age 16

We do not “sell” the Personal Information of consumers we know to be under 16 years of age.

Requests Submitted by Authorized Agents

In certain circumstances, you are permitted to use an authorized agent, as that term is defined by the CCPA (“Authorized Agent”) to submit a request to know or request to delete. An Authorized Agent can make a request on your behalf by providing proof that you gave the Authorized Agent signed permission to submit the request. In addition, we may also require you to (1) verify your own identity directly with us, or (2) directly confirm with us that you have provided the Authorized Agent permission to submit the request.

Financial Incentives

From time to time, we may run offers and promotions, including earning rewards for supporting the Divi Network, (collectively, “Programs”) that may be deemed “financial incentives” in relation to our collection of Personal Information under the CCPA.  Please refer to the terms and conditions of each Program for additional information about the Program, including how eligible consumers can opt-in or opt-out of the Program at any time. In order to enter a Program, you may be required to provide us or a service provider acting on our behalf with certain Personal Information, such as identifiers like your email address and telephone number (“Rewards Data”). If you submit your entry in accordance with the applicable Program’s rules, you may be entered into the Program and will get a chance to receive a gift, coupon or receive another benefit from us. The value of Rewards Data is related to the value of your information and the costs associated with offering the Program.    

California “Shine the Light”

In addition to the rights described above, California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure, if any, of certain categories of Personal Information to third parties for their direct marketing purposes during the immediately preceding calendar year. We do not share your Personal Information with any third parties for their direct marketing purposes.

  1. Do Not Track Signals

Some web browsers may transmit “Do Not Track” signals to websites with which the user communicates. We currently do not respond to “Do Not Track” signals.

  1. Updates to this Notice

We will update this Notice from time to time.  We will post updates on this page, including if we make material changes to how we process your Personal Information 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.

  1. Contact Us

If you have any questions in connection with this Notice or other privacy-related matters, please send an email to support@diviproject.org or see the Contact Us section of our Privacy Policy.

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