PRIVACY POLICY

We, us, our

Divi Official, LLC, its subsidiaries, and affiliated companies

16990 Dallas Pkwy, Ste 200

Dallas, Texas 75248

Our website

www.diviofficial.com

Our Data Protection Officer (“DPO”)

Bryce Washum

16990 Dallas Pkwy, Ste 200

Dallas, Texas 75248

[email protected]

Personal Information

Personal information and data that identifies you; identifies a particular individual; refers to personally identifiable information, personal information, or personal data; or identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household

Our Products and Services

The items and opportunities available to purchase or provided for free on our website.

Service Providers

A “Service Provider” under the CCPA, a “Processor” under the GDPR, or any natural person, legal entity, or other body that operates under a service-provider contract with us to process Personal Information from us under contractual obligations prohibiting the retention, use, or disclosure of Personal Information collected by us for any purpose other than the purpose specified in the contract or any other purpose permitted under any applicable Worldwide Data Privacy Laws (i.e. a person or entity who processes any Personal Information we collected on behalf of us)

Categories of Personal Information

Specific Types of Personal Information Collected

Identifiers (including potentially some Sensitive Personal Information or Data under some of the Worldwide Data Privacy Laws)

Name; addresses; telephone numbers; internet protocol (“IP”) address; electronic mail (“e-mail”) addresses; home, work, mailing, and billing addresses; social security number in the United States, SIN number in Canada, or the equivalent government-identification number in other countries; driver’s license number and information; passport number and information; date of birth; and online account names

Characteristics of protected classifications under some laws and regulations

Race, sex, color, religion, age, national origin, marital status, disability, veteran status, genetic information, sexual orientation, gender identity, and any other status protected by the laws or regulations in the locations where we operate

Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)

Purchase history, purchase data, Usage data, unique device identifiers for advertising (e.g., Google Advertiser ID or IDFA); and Tracking Technology

What we use your Personal Information for

Our reasons

To provide our products and services to you

For the performance of providing our products or services to you or to take steps at your request before performing of providing our products or services to you

To prevent and detect fraud against you or Divi

For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you

Conducting checks to identify account owners and customers and verify their identities

For our legitimate interests, i.e. to minimize data storage and fraud that could be damaging for us and for you

Screening for financial and other sanctions or embargoes

To comply with our legal or regulatory obligations

Other processing necessary to comply with professional, legal and regulatory obligations that apply to us

To comply with our legal or regulatory obligations

Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies

To comply with our legal or regulatory obligations

Ensuring business policies are adhered to, e.g. policies covering security and internet use

For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you and avoid a data breach

Operational reasons, such as improving efficiency, training and quality control

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information

Also, to comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, products or services range or other efficiency measures

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you

Preventing unauthorized access and modifications to systems

For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you

Also, to comply with our legal and regulatory obligations

Updating and enhancing account owners’ or customers’ records

For the performance of providing our products or services to you or to take steps at your request before performing providing our products or services to you

Also, to comply with our legal and regulatory obligations

And for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our account owners or customers to communicate and offer our products or services

Statutory returns

To comply with our legal and regulatory obligations

Ensuring safe working practices and staff administration and assessments

To comply with our legal and regulatory obligations

Also, for our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our products or services directly to account owners or customers

For our legitimate interests or those of a third party, i.e. to promote our products and services

External audits and quality checks, e.g. for accreditation and the audit of our accounts

For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards

Also, to comply with our legal and regulatory obligations

Disclosure of Personal Information We Collect About You

You have the right to know:

• The categories of Personal Information we have collected about you;
• The categories of sources from which the Personal Information is collected;
• Our business or commercial purpose for collecting or selling Personal Information;
• The categories of third parties with whom we share Personal Information, if any; and
• The specific pieces of Personal Information we have collected about you.

Please note that we are not required to:

• Retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information; or
• Provide the Personal Information collected to you more than twice in a 12-month period.

Personal Information Sold or Used for a Business Purpose

In connection with any Personal Information we may sell or disclose to a third party for a business purpose, you have the right to know:

• The categories of Personal Information about you that we sold and the categories of third parties to whom the Personal Information was sold; and
• The categories of Personal Information that we disclosed about you for a business purpose.

You have the right to opt-out of the sale of your Personal Information to third parties or Service Providers. If you exercise your right to opt-out of the sale of your Personal Information, we will refrain from selling your Personal Information, unless you subsequently provide express authorization for the sale of your Personal Information. To opt-out of the sale of your Personal Information, please update your Personal Information Preferences here https://www.diviofficial.com/pages/us-laws-compliance.

Right to Access

The right to be provided with a copy of your Personal Information (the right of access)

Right to Rectification or Correct Personal Information

The right to require us to correct any mistakes in your Personal Information

Right to be Forgotten or Deleted

The right to require us to delete your Personal Information

We may deny the request if the information is necessary to: 

• Complete providing a product or service requested or reasonably anticipated by the account owner or customer 
• Detect and protect against security incidents, malicious, deceptive, fraudulent, or illegal activity, or take action against those responsible for such activity 
• debug to identify and repair errors impairing intended functionality
• Engage in research in the public interest adhering to applicable ethics and privacy laws where the account owner or customer has provided informed consent 
• Enable solely internal uses reasonably aligned with the account owner’s or customer’s expectations based on the account owner’s or customer’s relationship with us
• Comply with any legal proceeding, court order, law, legal investigation, regulatory body, or other legal obligation
• Otherwise use the information internally in a lawful manner compatible with the context in which the account owner or customer provided the information

Right to Restriction of Processing

The right to require us to restrict processing of your Personal Information—in certain circumstances, e.g. if you contest the accuracy of the data

Right to Data Portability

The right to receive the Personal Information you provided to us

Right to Object

The right to object:

• At any time to your Personal Information being processed for direct marketing (including profiling)
• In certain other situations to our continued processing of your Personal Information, e.g. processing carried out for the purpose of our legitimate interests

Right Not to Be Subject to Automated Individual Decision-Making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

Right Not to Be Discriminated Against

You have the right to not be discriminated against by us because you exercised any of your rights. This means we cannot, among other things:

• Deny goods or services to you;
• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Provide a different level or quality of goods or services to you; or
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and services to you, if that difference is reasonably related to the value provided to our business by your Personal Information.

Right to Appeal the Denial of an Enforcement of Your Right by Us

You have the right to appeal the denial or failure of our DPO to enforce any request of your rights listed above by us. 

You can appeal any data privacy decision or indecision we make concerning your Personal Information by contacting in writing:

Personal Information Appeal Board

3229 Premier Drive

Dallas, Texas 75063

We will work to respond (or send a response) within 30 days of receipt of your appeal in writing at the address or email address provided in your appeal.

Right to Be Provided with a Supervisory Authority, if Known, to Complain to if Dissatisfied with Our Response to Your Change in Personal Information Preferences or Our Appeals Process

You have a right to know, if we know, who to complain to if you are dissatisfied with our response to your request to change your Personal Information Preferences or to your appeal of a decision we made in response to your request to change your Personal Information Preferences.

We have worked to list known local supervisory authorities or resources to find your local supervisory authority under the “Your Rights Under Local Data Privacy Laws” section below.

If you cannot find your supervisory authority in the section below, please contact our DPO at [email protected] with the subject “REQUEST TO IDENTIFY SUPERVISORY AUTHORITY” and the location of the supervisory authority sought, including city/state, country, and continent. Our DPO will do their best to get back to you within 30 days from receipt of your request in writing via email with either the known supervisory authority or an explanation that no known supervisory authority could be identified by us.

Right to Access

The right to be provided with a copy of your personal information (the right of access)

Right to Rectification

The right to require us to correct any mistakes in your personal information

Right to be Forgotten

The right to require us to delete your personal information—in certain situations

Right to Restriction of Processing

The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data

Right to Data Portability

The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

Right to Object

The right to object:

• at any time to your personal information being processed for direct marketing (including profiling);
• in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

Right Not to be Subject to Automated Individual Decision-Making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

Our Data Protection Officer (“DPO”)

Bryce Washum

3229 Premier Drive

Dallas, Texas 75063

[email protected]