For the purposes of the General Data Protection Regulation and all other relevant legislation, Diversifi (‘we’ or ‘us’) is the ‘data controller’ (i.e. the company that is responsible for and controls the processing of your personal data).
PERSONAL DATA WE MAY COLLECT ABOUT YOU
Personal information about you (such as your name, email address, phone number, legal documents, etc.) will be obtained, whenever you complete forms, create an account, work with Diversifi’s application, send feedback, upload documents, contact us, sign up to a service, share information, complete a survey, report a problem and make a purchase.
We may ask you to provide sensitive personal data from time to time. If such data is requested, you will be given additional information as to why the sensitive personal data is being requested and how it will be used. We may retain a record of any contact you make with us.
PERSONAL INFORMATION ABOUT OTHER INDIVIDUALS
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
• give consent on his/her behalf to the processing of his/her data;
• receive on his/her behalf and data protection notices;
• give consent to any transfer of his/her data;
INFORMATION FROM THIRD PARTIES
Occasionally we may receive information about you from other sources, which will be added to the information already held about you in order for us to help supply our services and products to you.
INFORMATION THAT WILL BE COLLECTED AUTOMATICALLY
Device information: we may collect information about your device each time you use the website or the application.
Information on your device: we may collect information that is stored on your device each time you use the website or the application.
Location data: we may collect information to determine your location using GPS technology or such other location tracking software we may use from time to time. Some of the features of the website or the application may require access to such location data to work. If you would like to use any such feature, you will be asked to consent to provide such location information.
HOW YOUR PERSONAL DATA WILL BE USED
We will use your personal data for the following purposes:
• helping identify you and any accounts you hold at the website or the application;
• research, statistical analysis, and behavioral analysis;
• customer profiling and analyzing your preferences;
• marketing—see ‘Marketing and opting out’, below;
• fraud prevention and detection;
• customizing the website or the application and their content to your particular preferences;
• notifying you of any changes to the website or the application or to our services or products that may affect you;
• improving our services and products.
WHAT IS OUR LAWFUL BASIS OR GROUND FOR USING YOUR PERSONAL DATA?
Under laws that are designed to protect your personal data, we need to have what is called a lawful basis or ground each time we use, share or otherwise process your personal data.
We may also need to process your personal data to comply with any legal obligations which may be applicable. Likewise, we may process your personal data where this is in the public interest or it is to protect your vital interests, but this will only be in rare circumstances.
In most cases, our processing of your personal data is necessary for the performance of our services to you.
Certain uses of your personal data, or other processing activities, may not be strictly necessary to perform our services to you, however, they may be necessary for the purposes of our legitimate interests or the legitimate interests of a third party. They may also be in your interest.
When we say “legitimate interests”, we mean our (or a third party’s) interests in enabling us to provide our services to you as efficiently and securely as possible. For example, we may choose to use a third party to store your personal data; we may do this in part because our use of that service means that your personal data is more secure.
If you have provided your consent to receive news, special offers, or promotions from us, we may contact you by mail, telephone, SMS, text/picture/video message to email about products, services, promotions, special offers, and charitable causes that may be of interest to you.
We may share your personal data with organizations who are our business partners and they may contact you (unless you have asked us or them not to do so) by mail, telephone, SMS, text/picture/video message, email, about products, services, promotions, special offers, and charitable causes that may be of interest to you. If you prefer not to receive any further direct marketing communications from us or our business partners, you can opt-out at any time. See further ‘Your Rights’, below.
DISCLOSURE OF YOUR PERSONAL DATA
We may disclose your personal data to:
• other companies that become partners or part of a group with Diversifi;
• a third party who acquires Diversifi or acquires substantially all of its assets, in which case the personal data shall be one of the acquired assets;
• our service providers;
• law enforcement and regulatory agencies in connection with any investigation to help prevent unlawful activity or as otherwise required by applicable law.
KEEPING YOUR DATA SECURE
We will use technical and organizational measures to safeguard your personal data where you create an account on the Website or App, this will be controlled by a password and username that are unique to you;
We will store your personal data on secure servers;
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason, we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet.
TRANSFERS OF DATA OUT OF THE EEA
All information you provide to us is stored with secure data processors. Please note that we review all processors we utilize and ensure that there are adequate safeguards in place to protect your personal data, such as adherence to binding corporate rules or compliance with the EU-US Privacy Shield Framework, which is a mechanism that ensures compliance with EU data protection requirements when transferring personal data from the European Union to the United States.
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason, we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us using our contact details at the bottom of this policy.
We may monitor and record communications with you (such as emails) for the purpose of quality assurance, training, fraud prevention, and compliance.
You have the right to access your personal records or other information that we hold about you. There is no administrative charge for this service.
You have the right to rectify any errors in the data we hold about you. If any data or information we hold about you is inaccurate, or out of date, please contact us and we will correct this immediately.
You have the right to have the data we hold about you erased.
If you wish us to continue to store your information but wish us to keep your data separate and not process it in any way, please let us know.
You have the right to ask us to stop processing your personal data for direct marketing purposes. You may also specify that you object to direct marketing by particular channels such as by email or telephone. If this is the case, please specify the channels you are objecting to in your communications with us.
You have the right to data portability. If you wish to obtain your data for your own purposes across different services, we will provide this information to you. There is no administrative charge for this service.
You have the right to object to any direct marketing.
To assert any of your rights set out above, you should send your request in writing to us using our email: [email protected]
You will need to provide proof of identity and address (e.g. a copy of your driving license, ID or passport, and a recent utility or invoice); and specify the personal data you want access to, to be amended or be removed.
HOW LONG WE STORE YOUR DATA
We will store your data for as long as necessary for the purpose of processing. The data may be deleted in the following circumstances:
• you have withdrawn your consent to data processing;
• the original purpose for processing the data is no longer relevant or cannot be performed anymore;
• the data is no longer up to date or accurate.
Diversifi offers services to individuals over the age of 18.
• keep track of the items stored in your shopping basket and take you through the checkout process;
• recognize you whenever you visit the website or application (this speeds up your access to the website or application as you do not have to log on each time);
• obtain information about your preferences, online movements, and use of the internet;
• carry out research and statistical analysis to help improve the website or application content, products, and services and to help us better understand our visitor and customer requirements and interests;
• target our marketing and advertising campaigns and those of our partners more effectively by providing interest-based advertisements that are personalized to your interests;
• make your online experience more efficient and enjoyable.
CONSENT (NOTIFICATION ON HOME PAGE)
We work with third-party suppliers who may also set cookies on the website or application. These third-party suppliers are responsible for the cookies they set on our Website. If you want further information, please go to the website for the relevant third party. You will find additional information in the table below.
DESCRIPTION OF COOKIES
The cookies that we utilize on our website or application are placed only to make it functional and have no function as sharing content with a range of networking and sharing platforms, or for analyzing purposes.
HOW TO TURN OFF COOKIES
If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of the website and application.
We may change this Policy from time to time. You should check this policy frequently to ensure you are aware of the most recent version that will apply each time you use the website and application.