Privacy Policy

Updated: 2 March 2021


Introduction

Moltend Core AB (collectively the “Company,” “we,” “us,” or “our”), is dedicated to protecting your personal information. This Privacy Policy applies to your use of divly.com and any Company-owned websites, software, and/or associated services (collectively, the “Website”). Our Privacy Policy discloses our privacy practices and explains how we use, collect, store, transfer, and share your personal information. Additionally, if you are a European user or EU citizen, our Privacy Policy addresses additional rights you may have to your personal information. Please review this Privacy Policy periodically as we may revise it from time to time without notice. If you do not agree with or accept our Privacy Policy in its entirety, you must not access or use the Website.

Information Collected

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed or otherwise anonymized.

Personal Information Collected Voluntarily Provided

You will not be required to provide us with any personal information when you visit our Website. However, portions of our Website may require us to collect personal information about you. During your use of the Website we may collect your name, email, address, telephone number, personal identification number, and username. If you report a problem or issue with Divly, we may keep that information indefinitely in case we need to contact you in relation to the issue for which you contacted us, for operational performance improvement and/or nuisance caller management. Any personal information you submit via the Website shall be used and disclosed in accordance with this Privacy Policy.

Personal Information Automatically Collected

Whenever you use our Website, we may collect non-identifying information from you, such as your IP address, interactions with the Website, query information, location information, pricing data, research history, location and GPS information, referring URL, browser, application interaction, mobile provider information, operating system, data usage, data transferred, and Internet Service Provider.

Types of Personal Data

The following types of personal data will be collected by the Company through the Website:

Registration: You, as a user of the Website, may be asked to register an account to use the Website or access any of the services thereon. During the process of your registration, you will be asked to provide your email address, a password, your Google credentials (if you opt for registration through Google), your Coinbase credentials (if you opt for registration through Coinbase), and any cryptocurrency wallets that you would like to disclose. We use these personal data to provide the services to you and ensure the security of the Website.

Billing: If you elect to use any of our paid services, you will be asked to provide billing information, such as, but not limited to, your credit card number and billing address. This personal data will be used specifically for providing you with the services you have purchased. The payment and billing information may be stored for the time period as required by applicable law for lawful purposes (e.g., accountancy records).

Cypto and Financial Information: Depending on how you choose to interact with the Website services, you may be asked to provide your cryptocurrency wallet and general portfolio information and other information that will assist us in providing the services to you. You may also be asked for API access for certain accounts which may be aggregated for you on the Website.

Use: Through your use of the Website, you may be asked questions about how to improve the Website or you may, at some point, communicate with representatives of the Website. We will receive your email address, as well as the contents of your communications, answers to questions and any other form of contact between you and the Website. We will use personal data contained in such communications only for the purposes of providing you with the requested information and for improving the services.

Automatic Collection: We may collect information from you through automatic tracking systems on your device or through the Website application programming interface, or API, or other web and mobile analysis software. We may also receive certain usage data, such as your IP address and referral source. We use this information for our legitimate business interests, including analyzing usage of the Website.

Combined or Aggregated Information: We may combine or aggregate some of your personal data in order to better serve you and to better enhance and update the Website for your and other consumers’ use, or to create public posts about insights or trends in the domain.

Anonymized Data

Please be aware that we me may collect and aggregate personal information from our Website and may anonymize that information for our own research or internal purposes. Once such data has been anonymized, it cannot be traced back to you, the user.

Sharing and Use of Your Information

This section explains how we plan on sharing and using your personal information. You consent to our use of your personal information for the following purposes:

Feedback: We may use your personal information to: Ask you about your experience with us.

Access and Communications to Our Website and Services: We may use your personal information to: (1) interact with you through our Website (e.g. software updates, Website announcements, etc.): and/or (2) manage and respond to your questions (e.g. technical, commercial, or administrative) or requests for maintenance and support.

Use of the Website: We may use your personal information to: (1) enable you to enjoy the use of, and easily navigate the Website; and/or (2) better understand your needs and interests. The legal basis is Art. 6(1)(f) of the EU General Data Protection Regulation (“GDPR”).

Allowing Downloads from the Website: We may use your Personal Information to allow you download data or content from the Website including some tax reports.

Training and Improvements: We may use your personal information to: (1) to allow for a better Website experience; and/or (2) improve the Website.

Direct Marketing and Inquiries: We may use your personal information to: (1) contact you for additional products and services that you may be interested in; (2) sending you a newsletter; (3) profiling; (4) delivering you targeted information regarding promotions related to the Website; and (5) responding to inquiries You may opt out from receiving communications from us at any time by following the "unsubscribe" instructions provided in the communications or contacting us at legal@divly.com.

Correspondence: We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. The Website will generate the metadata associated with communications made using the Website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business and communications with visitors.

Legal Process: We may share your information: if we believe that disclosure is reasonably necessary to comply with a law, regulation, legal or governmental request; to respond to a subpoena, court order, warrant, or other legal process; to enforce applicable Terms of Use or this Privacy Policy, including investigation of potential violations thereof; to protect the safety, rights, or property of the public, any person, or Company; to detect, prevent, or otherwise address, security, or technical issues or illegal or suspected illegal activities (including fraud); or as evidence in litigation in which we are involved, as part of a judicial or regulatory proceeding.

Retention of Personal Information

Company will only retain your Personal Information for as long as required. We will keep your personal information:

  • For any legally required duration.
  • Until we no longer have a valid reason to keep or use your personal information. We retain the personal information we collect for so long as reasonably necessary to fulfill the purposes for which the information was collected, to perform our contractual and legal obligations, and for any applicable statute of limitations periods for the purposes of bringing and defending claims.
  • Until we receive a request to eliminate, delete, or modify any of your personal information stored with us.

Legal Basis for Processing Information

Your information collected through the Website may be stored and processed in Sweden, or any other country in which Company or its subsidiaries, affiliates, or service providers maintain facilities. We may transfer information that we collect about you, including personal information, to affiliated entities, or to other third- parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. We process and use your personal information, where required by law, for the following purposes:

  • as necessary to fulfill this Privacy Policy or our Terms of Use or Cookies Policy;
  • consistent with your consent, which you can revoke at any time;
  • as necessary to comply with our legal obligations;
  • occasionally to protect your vital interests, or those of others;
  • as necessary in the public interest; and
  • as necessary for our (or others') legitimate interests, including our interests in providing a safe and profitable services to our users and partners.

Accessing and Editing Your Information

When using our Website you may be able to access and edit some of your personal information via the Website dashboard. If at any time, you have any questions or wish to review, change, or edit any additional personal information collected by us, please contact us at legal@divly.com.

Removal of Information

If you wish to have any of your personal information stored within the Company Website removed, please contact us at legal@divly.com. Please be aware that removal requests are not processed instantaneously. There may be a reasonable delay in removing any personal information requested.

You may make a removal request by email at legal@divly.com. If you require additional details regarding the deletion or retention of your personal information please contact us. All removal or deletion requests are subject to Section 6 and subject to any applicable laws. Additionally, we will retain and use your personal information (even after a removal or deletion request), where required, so that we may fulfill our legal obligations, resolve disputes, and enforce our agreements.

Third-Party Service Providers

We may employ other companies and individuals to perform functions on our behalf. Examples include hosting the Website, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), and providing customer service. They have access to personal information needed to perform their functions, but may not use it for other purposes.

We do not sell, trade, or transfer your personal data to third parties not indicated in this Privacy Policy, unless we obtain your prior explicit consent. Please note that some non-personal data may be provided to third parties for marketing, advertising, or other uses. We also allow third-party behavioral tracking which may include non-personal data.

Business that We Do Not Control

The Website may include third-party advertising and links to other websites. We are not responsible for actions of third parties that are not mentioned in this Privacy Policy and with whom you share your personal data, and we have no authority to manage or control third party solicitations.

Cookies

We currently use cookies, please see our Cookies Policy.

Opting Out and Do Not Track

If you decide to provide us with your contact information, you agree that we may send you communications via text and email where you have consented. However, you may opt out of any communications and you may opt out of certain personal information submission where applicable. If you wish to opt out of certain communications or information collection, please contact us at legal@divly.com. “Do not track” is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable “Do not track” by visiting the “preferences” or “settings” page of your web browser.

Third Parties

Company may post links to third-party websites on our Website, which may include information that we have no control over. When accessing a third-party website through our Website, you acknowledge that you are aware that such third-party websites are not screened for privacy or security issues by us. Company bears no responsibility for the information collected or used by any advertiser or third-party website that you have visited through a link on our Website. You must review that third-party’s terms of service and privacy policy to understand how their information collection and retention practices work.

Security Measures

We make reasonable attempts to protect your information by using physical and electronic safeguards in accordance with industry standards. However, as our Website is hosted electronically we can make no guarantees as to the security or privacy of your information. For this reason, we recommend that you use anti-virus software, routine credit checks, robust passwords, firewalls, and other precautions to protect yourself from security and privacy threats. We are not liable for any loss, theft, unauthorized access, disclosure, copying, use, or modification of your personal data that occurs outside our reasonable control.

Your California Privacy Rights

Company permits residents of the State of California to use its Website, and complies with the California Business and Professions Code §§ 22575-22579. If you are a California resident you may request certain information regarding our disclosure of personal information to any third parties for their direct marketing purposes. Various provisions throughout this Privacy Policy address requirements of the Californian privacy statutes. Although we do not disseminate your information to third-parties without permission, you must presume that we collect electronic information from all Website visitors. You may contact us at legal@divly.com with any questions regarding your California Privacy Rights.

Age Compliance

We intend to fully comply with American and international laws respecting children’s privacy. Therefore, we do not collect or process any information for any persons under the age of 18. If you are under 18 you are prohibited from accessing the Website.

Transfer of Your Information to the United States

Please be aware that if you are located outside of the United States, your personal information shall be transferred and processed in the United States. If you are a citizen or resident of the European Economic Area (“EEA”), Company shall ensure that your Personal Information shall have an adequate level of protection, which may include executing Data Protection Agreements with our processors and that process your information. These data transfers are necessary to provide the Website to you. Where we transfer your Personal Information outside of the EEA we may utilize standard contract clauses, the Swiss-US Privacy Shield, and other data protection mechanisms approved by the European Commission.

Merger and Acquisition

In the event that Company is involved in a bankruptcy, merger, acquisition, reorganization, or sale of assets, your personal information may be sold or transferred as part of that transaction. Please be aware that once the information is transferred your privacy rights may change.

Amendments

Like our Use and Cookies Policy, we may amend this Privacy Policy from time to time. When we amend this Privacy Policy, we will modify the date listed on this Agreement or we may contact you. You must agree to the amendments as a condition of your continued use of our Website. If you do not agree, you must immediately cease using our Website and notify us of your refusal to agree by e-mailing us at legal@divly.com.

Privacy Notice for European Citizens

Company respects the rights of citizens or persons living within the EEA and the rights afforded to them under the GDPR this section addresses the privileges of EEA users. If you live in a country in the EEA the services are provided by Molten Core AB, the data controller responsible for your information when you use our Website. The GDPR affords the following rights to EEA citizens and persons residing in EEA territories:

The right to be informed

Company wishes to keep you informed as to what we do with your personal information. We strive to be transparent about how we use your data.

The right to access

You have the right to access your information at any time. Please contact us at legal@divly.com if you wish to access the personal information that Company holds about you.

The right to rectification

If the information Company holds about you is inaccurate or not complete, you have the right to ask us to rectify it. If that data has been passed to a third-party with your consent or for legal reasons, then we must also ask them to rectify the data.

The right to erasure

Sometimes called ‘the right to be forgotten.’ You have the right to request that Company to erase any and all of your personal data.

The right to restrict processing

You have the right to ask Company to restrict how we process your data. This means we are permitted to store the data but not further process it. We will only keep enough data to ensure that we can accommodate any additional requests.

The right to data portability

Company must allow you to port and reuse your personal data for your own purposes across different platforms. Please contact our team at legal@divly.com if you wish to receive additional information on how to port your data elsewhere. This right only applies to personal data that you have provided to us as a data controller.

The right to object

You have the right to object to Company processing your data even if our processing is due to legitimate purposes as described in our Privacy Notice.

The right to withdraw consent

If you have given us your consent to process your data but change your mind later, you have the right to withdraw your consent at any time, and Company must stop processing your data. You may withdraw your consent at any time.

You may exercise these rights by contacting us at legal@divly.com if we process your information based on our legitimate interests or those of a third-party, or in the public interest, you can object to this processing, and we will cease processing your information, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us at legal@divly.com. Additionally, if you are a European resident we note that we are processing your information in order to fulfill a contact request from you (for example, if you use a contact form on the Website or otherwise contact us), or otherwise to pursue our legitimate business interests. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States of America.

Contacting Us

If you would like to contact us to understand more about this Agreement or wish to contact us concerning any matter relating to it, you may send an email to legal@divly.com.