Last Updated: 5 October, 2021
About us
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.
Divi Labs And Technologies, S.A. is the data controller of all Personal Data collected via the Services. We have appointed an EU and UK representative for matters relating to our processing of Personal Data of individuals in the EEA and UK respectively. Their contact details are set out at the end of this Policy.
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.
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.
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, your email address, name, a username, and a profile picture. Please note that other users who know your phone number, email address, name or username will be able to search for your profile if you allow this.
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 providers: for subscription payments these are Stripe and Paypal; for bank transfers (and Fiat on-ramp) these are Simplex and Plaid, for conversions this is ChangeNow. 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.
We use the Personal Data we collect for the following purposes:
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.
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:
Divi Labs’ Services are global and your Personal Data will be sent to and used in Canada (where we host our servers) regardless of the country you reside in.
For individuals located in the EEA or UK, we are committed to protecting the privacy and confidentiality of your personal data where it is transferred. Canada has been deemed to provide an adequate level of protection for your personal data.
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 at this link.
Further information about our use of cookies and similar technologies and your choices in relation to them is in our Cookie Policy. You can also learn more about the specific cookies that we use and manage your cookie preferences by clicking here.
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.
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.
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 support@diviproject.org.
You have rights as an individual which you can exercise in relation to the Personal Data we hold about you under certain circumstances subject to applicable law. These rights are to:
If you have provided your consent to the processing of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
Exercising Your Rights. If you wish to exercise any of these rights, please contact us via the “Contact Information” section below.
You also have the right to make a complaint to a supervisory authority for data protection issues.
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 support@diviproject.org.
Individuals in the EEA or UK can also contact our EU or UK representative using the following details: We value your privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative and your point of contact.
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit: https://prighter.com/q/18078053891
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.
