This Privacy Policy along with the Terms and Conditions available on this Website sets out how personal data collected from you through this Website will be processed.

By accessing and using the Website, you acknowledge and accept the privacy practices described in this Privacy Policy and adopted and provided on this Website.

This Website is owned and operated by Technology Divines Ltd. registered at 22 Anton Chekhov, fl. 1, ap. 16 1113, Sofia, Bulgaria.

Technology Divines Ltd. is the data controller & processor of the information that we collect from you through this Website.

All references to “end user”, “you”, “yours” and/or “your”, in this Privacy Policy refers to any user which accesses the information and services on this Website or through our services and applications.

Information We Collect

Information You Provide to Us: When you register to our Services, download any of our software or applications, communicate with our customer service team, or send us an email, you’re giving us information that we collect.

That information may include your IP address, name, physical address, email address, phone number and other demographic information. By giving us this information, you consent to your information being collected, used, disclosed, and stored by us.

• List and Email Information: When you add a contact List or create an Email with the Service, we have access to the data on your list and the information in your Email.
• Information from your Use of the Service: We may get information about how and when you use the Services. This information may include your IP address, time, date, browser used, and actions taken by you within the application.
• Your personal data will be processed automatically with the aim of evaluating certain personal aspects (profiling). We use profiling for the purposes of complying with our anti-money laundering and funding of terrorism obligations. As  a rule, we do not make decisions based solely on automated processing as defined in Article 22 of the GDPR to establish and implement the business relationship, as there is always an element of human involvement in such decisions. If we use these procedures in individual cases, we will inform you of this separately, provided this is allowed by law.

If you have any questions about this Privacy Policy, including any requests to exercise your rights as a data subject, please contact us using the below provided email: [email protected]

Use of Your Personal Information

We may use and disclose your Personal Information only as follows:

• To promote use of our Services. It can happen if you use any of our Services, and we think you might benefit from using another Service we offer, we may send you an email with information about it.
• To bill and collect money owed to us. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments.
• To send you System notifications. i.e, we may let you know about temporary or permanent changes to our Services, like planned outages, new features, version updates, releases, abuse warnings, and changes to our Privacy Policy.
• To impose compliance with our Terms of Use and applicable law. This may include developing tools and algorithms that help us prevent violations.
• To provide you customer service.
• To protect the rights of our Members and third parties, as well as our own.
• To meet legal requirements like complying with court orders and valid subpoenas.
• To support and improve the Services we offer. This includes adding features that compare Members Emails.
• To communicate with you about your account for informational, not promotional, reasons.
• To transfer your information in the case of a sale, merger, consolidation, or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Policy.

Purposes of Collecting and Processing the Information

We collect, store and use your information to provide you with a safe, smooth, efficient, and customized experience.

Disclosing your Personal Data

Your personal data will be disclosed to the third parties set out below for the purposes listed in the table above.

We shall only disclose your personal data to third parties where lawful to do so including where we:

• Need to in order to provide you with the service;
• Need to in order to obtain services from third parties in order to provide you with the service;
• Have a legitimate interest for the purposes of litigation or asserting and defending our legal rights and interests;
• Have a legitimate business interest to do so for managing risk;
• Have been instructed by you to do so;
• Are required to disclose the information in response to legal process (for example, a court order, search warrant or subpoena);
• Believe that our Website and its content is being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud or money-laundering protection;
• Have a reasonable and good faith belief that there is an emergency that poses a threat to the health, life and/or safety of you, another person or the public generally;

and

We will disclose your personal data to third parties which include:

• Regulators and other authorities as may be required by law or by courts of law;
• Law enforcement, government, courts, dispute resolution bodies, regulators and any party appointed or requested by regulators to carry out investigations or audits of our activities;

We will disclose your personal data to external service providers and third-party vendors. We shall only disclose the personal data which is necessary for such third parties to deliver the required service.We will disclose your personal data to external service providers and third-party vendors. We shall only disclose the personal data which is necessary for such third parties to deliver the required service.

Where you are disputing payments or losses charged on your account, we shall disclose your KYC Data, Bank Account Data, Usage and Account Data to your bank to settle the dispute.

Relevant authorities, employees of Divine Technologies Ltd.., in particular Customer support agents and other employees with relevant roles shall also have access to your personal data for the purpose of executing their duties and providing you with assistance and the service.

Marketing

We would like to send you information about our services which may be of interest to you. If you have consented to receive marketing, you have a right at any time to opt out from receiving such marketing material. You may opt out at any time as set out below:

• Email [email protected] and say that you would like to opt out

Security

We are committed to ensuring that your information is secure. We have implemented measures and procedures to prevent unauthorized access or disclosure of your information. Likewise, we seek to keep confidential all information you send to us.

This site uses Secure Sockets Layer (SSL) to ensure secure transmission of your personal data. You should be able to see the padlock symbol in the status bar on the bottom right hand corner of the browser window. The URL address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your PC and the connecting server.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any personal data breach and will notify you and the relevant regulator of a breach where we are legally required to do so.

Rights & Data Subject Requests

Right to Transparent Information – you have the right to be informed in a clear manner on any personal data pertaining to you that may be processed by us. Such information is being provided to you in this Privacy Policy.

Right of Access to Information – you have the right to request confirmation from us whether personal data relating to you is being processed and if so to access such personal data.

To lodge a request, contact our DPO on the details above. If you would only like to receive information on a specific category of data, please indicate such category e.g. ‘Identity Data’ or ‘Contact Data’.

Right to Rectification – you have the right to request from us the rectification, without delay, of any inaccurate personal data pertaining to you.

You may change your data in the following manner:

• Through your Profile: by accessing the ‘Account Details’ page on the platform;
• By email: by emailing: support@technologydivines.com

Please note that your username may not be changed.

Right to Be Forgotten – you have the right to request from us the erasure of all personal data pertaining to you without delay, where the data has been processed with your consent as the basis for processing and/or where the processing is no longer lawful.

Right to Restrict Processing – you have the right to request from us the restriction of processing if: processing is unlawful; you are contesting the accuracy of data; the data is no longer required by the controller but you require us to keep it in order to establish, exercise, or defend a legal claim; or if you have previously objected to the processing. Once data is restricted, we cannot process it in any way other than to store it unless: we have your consent; or if it is required for the establishment, exercise, or defence of legal claims; or if it is for the protection of the rights of other persons; or if it is for reasons of important public interest.

Please note that this does not extend to personal data which is inferred or derived by us.

Right to Data Portability – you have the right to receive from us personal data which you have provided to us and to transmit that data to another controller without hindrance from us. This right applies where the data is being processed with your consent, or for the performance of a contract, and when processing is carried out by automated means.

Right to Object – you have the right to object at any time to the processing of personal data pertaining to you where the processing is based: on our legitimate interest; or the performance of a task in the public interest/exercise of official authority; or on direct marketing (including profiling); or on processing for purposes of scientific/historical research and statistics.

You also have the right to object to profiling based on our legitimate interests or on the performance of a task in the public interest/exercise of official authority.

You also have the right to object to automated decision making, including profiling, and therefore to not be subject to a decision which is based solely on automated processing, including profiling, which produces legal effects or significantly affects you.

What we will need from you

Whenever we receive a request in line with the above rights, we might need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Keeping your data updated

We have an obligation to keep your data updated, and for this reason you may be asked about changes to your personal data at various intervals. You may help us in this process by informing us whenever your data has changed. You are entitled to ask us to modify your personal data if you ascertain that the personal data which we hold is not accurate or updated.

Am I obliged to provide You with my Personal Data?

Since we require your data for the purposes of accepting and carrying out a relationship with you and fulfilling our contractual and legal obligations, should you choose not to provide us with such data,  we might not be in a position to enter into a business relationship with you and fulfill the Terms and Conditions applicable between us and our obligations thereunder. Anti-money laundering obligations require us to verify your identity at certain intervals, for example, by means of your passport and to record your personal details. In order for us to be able to comply with this statutory obligation, we will ask you to provide us with the necessary information and documents and notify us without undue delay of any changes that may arise during the course of the business relationship. Should you choose not to provide us with such data, we might not be in a position to enter into or continue our business relationship and fulfill the Terms and Conditions applicable between us and our obligations thereunder as we would be in breach of our anti-money laundering and funding of terrorism obligations.

Reference is made to the Terms and Conditions whereby you have undertaken to provide us with certain personal data, including documentation, and to inform us of any changes to such data. In these circumstances, the provision of personal data is a contractual requirement.

You are never obliged to provide us with any data which we request on the basis of your consent.

Processing Data Through Consent

The processing of data highlighted above, with the exception of processing for marketing purposes does not require your consent as it relies on another legal basis.

We may however also request to process additional personal data on the basis of your consent. You are not obliged to give us your consent. Once you have granted us consent to the processing of personal data for an identified specific purpose, the processing becomes lawful on the basis of such consent. You can withdraw your consent at any time. Withdrawal of consent does not affect the legality of data processed prior to withdrawal.

You can withdraw your consent at any time by: [email protected]

At the time of withdrawal of consent, we may determine that there is another legal ground allowing us to process your data and we shall inform you accordingly.

Surveys & Contests

From time-to-time we collect information via surveys or for participation of any contests organized by us on the Site. Participation in these surveys and/or contests is completely voluntary and any information provided to us will be provided on the basis of your consent. You may choose whether or not to participate and thereby disclose any information about you. There will be no detriment towards you for not participating in such surveys and contests. You may wish to revoke your consent at any time.

By agreeing to participate in the survey, you agree to provide us with any such required information.

Survey information will be used only for purposes of improving the use and customer satisfaction of the Site.

Changes to Privacy Policy

We retain the right to change our Privacy Policy at any time in case update is needed. Any new change shall apply from the date we publish them.

Any further updates will be listed on this web page, so please check back periodically.

Contact Us

If you are unhappy with the way in which we have processed your personal data, you may contact our Data Protection Officer/Data Protection Representative on the below details.

Email Address: [email protected]