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Privacy Policy

Last Updated Date: January 20, 2025

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Thank you for choosing to be part of our community and welcome to the website (the “Site”) of Diem Enterprises Inc. (“Diem,” “we,” “us,” or “our”). Diem provides a social search engine to exchange information with communities (collectively, including the Site and any related mobile applications, the “Service”).

 

This Privacy Policy explains what Personal Data (defined below) we collect via the Service, how we use and share that data, and your choices concerning our data practices.

 

Before using the Service or submitting any Personal Data to Diem, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, you may not access the Site or otherwise use the Service.

 

1. PERSONAL DATA WE COLLECT

We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows:

 

Personal Data You Provide: We collect Personal Data when you register to use the Service and in connection with your use of the Service. The Personal Data collected during these interactions may vary based on what you choose to share with us, but it will generally include your name, preferred pronoun, email address, phone number, and state and country where you are located. If you choose to use Apple Sign In, we will collect your Apple ID.

 

Personal Data We Collect Through Our Social Media Pages: We have pages on social media sites like Instagram Facebook, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

 

Personal Data We Receive Automatically From Your Use of the Service: When you visit, use and interact with the Service, we may receive certain information about your visit, use or interactions. For example, some of our sessions are recorded so that they can be viewed by other members later; if comment or ask a question during one of those sessions, whatever you say will be in the recording. If you do not want to be recorded, you may choose not to participate. Additionally, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Google Chrome, Safari, Microsoft Edge, etc.), and broad geographical information. In particular, the following information may be created and automatically logged in our systems:

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● Log data: Information that your browser automatically sends whenever you visit the Site (“log data”). Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site.

● Cookies: Please see the “Cookies” section below to learn more about how we use cookies.

● Device information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.

● Usage Information: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities.

 

Cookies: We use cookies to operate and administer our Site, gather usage data on our Site and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.

 

Cookie Preferences and Consent: To respect your privacy and provide greater transparency, we offer a mechanism for managing your cookie preferences upon your first visit to our Site. When you visit the Site, you will see a cookie banner that provides you with the option to accept all cookies, decline non-essential cookies, or customize your cookie preferences. This banner allows you to choose which categories of cookies you consent to, such as those used for analytics or targeted advertising, while ensuring that essential cookies necessary for the proper functioning of the Site remain enabled. You can update your preferences at any time by accessing the cookie settings link available in the footer of the Site. For more details on the types of cookies we use, please refer to the "Cookies" section of this Privacy Policy.

 

Analytics: We use Google Analytics a web analytics service provided by Google, Inc. (“Google”) and FullStory, Inc. (“FullStory”). Google Analytics and FullStory use cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google and FullStory use this data, go to www.google.com/policies/privacy/partners/ and https://www.fullstory.com/legal/privacy-policy/.

 

Online Tracking and Do Not Track Signals: We and our third party service providers may use cookies, pixels or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

 

Your Choices. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

 

● Microsoft Edge

● Mozilla Firefox

● Google Chrome

● Apple Safari

 

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

 

Advertising networks may collect Personal Data through the use of cookies. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

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2. HOW WE USE PERSONAL DATA

We may use Personal Data for the following purposes:

 

  • To provide and facilitate your engagement with the Service;

  • To respond to your inquiries, comments, feedback or questions;

  • To send administrative information to you, for example, information regarding the Service, and changes to our terms, conditions, and policies;

  • To analyze how you interact with our Service;

  • To maintain and improve the content and functionality of the Service;

  • To develop new products and services;

  • To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture and networks; and

  • To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.

 

Legal Bases for Processing Personal Data. 

If you are accessing our Service from the European Economic Area (EEA), United Kingdom, or other regions with laws governing data collection and use, we process your Personal Data under the following legal bases, as required by the General Data Protection Regulation (GDPR):

 

  • Consent: We process your Personal Data when you have provided explicit consent for specific purposes. For example, we may seek your consent before sending marketing communications or using cookies that are not strictly necessary for the operation of the Site.

  • Contract Performance: We process your Personal Data when it is necessary to fulfill a contract with you or to take steps at your request before entering into a contract. This includes processing your data to provide access to the Service, respond to your inquiries, or manage your account.

  • Legitimate Interests: We may process your Personal Data where it is necessary for our legitimate interests, provided that these interests are not overridden by your data protection rights. This includes processing data for improving our Service, ensuring its security, preventing fraud, and analyzing usage patterns.

  • Legal Obligations: We process your Personal Data where it is necessary to comply with legal obligations, such as record-keeping, tax, and regulatory requirements.

  • Protection of Vital Interests. In rare cases, we may process your Personal Data to protect your vital interests or those of another person, such as in emergencies where the safety of individuals is at risk.

 

Aggregated Information. We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.

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Marketing. We may use your Personal Data to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists you will no longer receive marketing communications, but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.

 

3. SHARING AND DISCLOSURE OF PERSONAL DATA

In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:

 

  • Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, cloud services and other information technology services providers, event management services, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and web analytics services (for more details on the third parties that place cookies through the Site, please see the “Cookies” section above). Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Data.

  • Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.

  • Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability. We take the privacy of our users seriously and have procedures in place to carefully review and challenge legal requests for Personal Data. Our team assesses each request to ensure it complies with applicable legal standards, is properly issued by a competent authority, and is narrowly tailored to seek only the information necessary to fulfill the legal purpose.

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For sensitive data, such as information related to reproductive health, gender identity, and marital status, we will vigorously resist any disclosure request unless legally required to comply after exhausting all legal remedies. Unless prohibited by law or when providing notice would be ineffective or pose a risk of harm, we will make reasonable efforts to notify affected users before disclosing their Personal Data.

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  • Affiliates: We may share Personal Data with our affiliates, meaning an entity that controls, is controlled by, or is under common control with Diem. Our affiliates may use the Personal Data we share in a manner consistent with this Privacy Policy.

 

4. DATA RETENTION

We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is longer.

 

5. UPDATE YOUR INFORMATION

Please log in to your account or contact us if you need to change or correct your Personal Data.

 

6. CHILDREN

Our Service is not directed to children who are under the age of 18. Diem does not knowingly collect Personal Data from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Data to Diem through the Service please contact us and we will endeavor to delete that information from our databases.

 

7. LINKS TO OTHER WEBSITES

The Site may contain links to other websites not operated or controlled by Diem, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

 

8. SECURITY

You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to Diem via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.

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9. YOUR CHOICES

In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Services, you may be unable to use those features. You can also contact us to ask us to update or correct your Personal Data.

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10. INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States and other countries. If you are accessing our Service from the United Kingdom, European Economic Area (“EEA”), or other regions with laws governing data collection and use, please note that your Personal Data will be transferred to and stored in the United States as necessary for the purposes described in this Privacy Policy, and Personal Data may be transmitted to our service providers supporting our business operations (described above). The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located.

 

10. YOUR RIGHTS UNDER CCPA

If you are a resident of California, you have specific rights regarding your Personal Data under the California Consumer Privacy Act (“CCPA”). This section describes your rights and how to exercise them.

 

  • Right to know. You have the right to request information about the categories of Personal Data we collect, the sources of that data, the purposes for collecting it, the categories of third parties with whom we share it, and the specific pieces of Personal Data we hold about you.

  • Right to delete. You have the right to request that we delete your Personal Data, subject to certain exceptions. These exceptions may include information that we must retain to: complete the transaction for which the information was collected, provide a good or service you requested, or reasonably anticipate within the context of our ongoing business relationship; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; comply with a legal obligation or exercise legal claims.

  • Right to opt out of sale of Personal Data. Diem does not sell Personal Data as defined by the CCPA. However, if this practice changes in the future, we will provide a clear mechanism for you to opt out of the sale of your Personal Data.

  • Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Specifically, we will not deny you access to our services, charge different prices, or provide a different level or quality of services for exercising your rights under the CCPA.

 

To exercise any of the rights above, please contact us at info@askdiem.com. Please include the subject line: "CCPA Rights Request" in your email or letter. To process your request, we will need the following information to verify your identity: (i) full name; (ii) email address associated with your account; and (iii) any additional information that may help us locate your Personal Data (e.g., user ID, date of last interaction with our Service)

 

Once we receive your request, we will begin the verification process. If you have a password-protected account with us, we may verify your identity by confirming details from your account. If you do not have an account, we may ask for additional verification information, such as a government-issued ID or details about recent interactions with our Service. This verification process is necessary to protect your privacy and prevent the unauthorized disclosure of your Personal Data.

 

We will acknowledge receipt of your request within 10 business days and provide a response within 45 calendar days. If we require additional time (up to 90 calendar days total), we will notify you of the extension and the reason for the delay.

Upon successful verification, we will provide you with the categories of Personal Data we have collected about you, the categories of sources from which the Personal Data was collected, the purposes for collecting the Personal Data, the categories of third parties with whom we shared the Personal Data, and specific pieces of Personal Data we have collected about you, if requested.

 

Please note that we may decline to provide certain information where disclosure poses a significant risk to the security or privacy of the data, or where disclosure would conflict with legal obligations. If we deny your request, we will provide you with an explanation.

 

11. INTERNATIONAL PRIVACY RIGHTS

 If you reside in Canada, the European Economic Area, or certain other jurisdictions you may have the right to exercise certain privacy rights available to you under applicable data protection laws, including one or more of the rights listed below. We will process your request in accordance with applicable data protection laws, provided that may need to retain certain information for record-keeping purposes or to complete transactions that you began prior to requesting any deletion.

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  • Right not to provide consent or to withdraw consent. We may seek to rely on your consent in order to process certain Personal Data. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.

  • Right of access and/or portability. You may have the right to access the Personal Data that we hold about you and, in some limited circumstances, have that data provided to you so that you can provide or “port” that data to another provider.

  • Right of erasure. In certain circumstances, you may have the right to the erasure of Personal Data that we hold about you (for example if it is no longer necessary for the purposes for which it was originally collected).

  • Right to object to processing. You may have the right to request that we stop processing your Personal Data and/or to stop sending you marketing communications.

  • Right to rectification. You may have the right to require us to correct any inaccurate or incomplete Personal Data.

  • Right to restrict processing. You may have the right to request that we restrict processing of your Personal Data in certain circumstances (for example, where you believe that the Personal Data we hold about you is not accurate or lawfully held).

  • Right to lodge a complaint to your local Data Protection Authority. If you are an EEA resident, you have the right to submit a complaint to a data protection authority about our collection and use of your Personal Data.

 

How to Exercise Your Rights. To exercise any of the rights above, contact us at info@askdiem.com. Please identify yourself and specify your request. If you have a password protected account, we may generally use your account information to verify your identity. If not, we may ask you to provide additional verification information. What we request will depend on the nature of your request, how sensitive the information is, and how harmful unauthorized disclosure or deletion would be.

 

We use commercially reasonable efforts to delete your Personal Data as required but may retain records necessary to comply with a governmental authority or applicable federal, state, or local law. Where legally permitted, we may decline to process requests, including requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others.

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12. CHANGES TO THE PRIVACY POLICY

The Service, and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

 

13. CONTACT US

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at info@askdiem.com.

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