Privacy policy

Last version dated October 1, 2024

I.- General information

This Privacy Policy describes how ON DIVERSITY LLC and OD CLOUD LIMITED collect, use, and share information in connection with your use of the following websites:

And also the services, and applications (collectively, the “Services”). This Privacy Policy does not apply to information our customers may process when using our Services. We may collect and receive information about users of our services from various sources, including:

Information you provide through your user account on the services.
If you register for the services.
Your use of the Services.
From third-party websites, services, and partners.

We recommend that you read this Privacy Policy in full, including the Additional Disclosures referenced at the bottom of this document, to ensure you are fully informed. If you have any questions about this Privacy Policy or ON DIVERSITY’s data collection, use, and disclosure practices, please contact us at [email protected].

II.- Information we collect

1. Information that you provide

Account registration: When you register for an account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number. If you choose to refer a friend to our services, we may also collect your friend’s email address so that we may send them a referral or promotional code to sign up for our Services.
Payment information: When you add your financial account information to your account, that information is directed to our third-party payment processor. We do not store your financial account information on our systems; however, we have access to, and may retain, subscriber information through our third-party payment processor.
Personal data: This means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a user in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. “Personal Data” includes equivalent terms in other Data Protection Law, such as the CCPA-defined term “Personal Information,” as context requires.
User content: Our private community feature allows you to publicly post content on our services. By registering for our community, you agree that your profile information and the content you post may be viewed and used by other users and third parties we do not control.
Communications: If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. We may also receive a confirmation when you open an email from us. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

2. Information that we collect when you use our services

Cookies and other tracking technologies: As is true of most websites, we gather certain information automatically and store it in log files. In addition, when you use our services, we may collect certain information automatically from your device. This information may include internet protocol (“IP”) addresses, browser type, internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, clickstream data, landing page, and referring URL. To collect this information, a cookie may be set on your computer or device when you visit our services. Cookies contain a small amount of information that allows our web servers to recognise you. We store information that we collect through cookies, log files, and/or clear gifs to record your preferences. We may also automatically collect information about your use of features of our services, about the functionality of our services, frequency of visits, and other information related to your interactions with the services. We may track your use across different websites and services. In some countries, including countries in the European Economic Area (“EEA”), the information referenced above in this paragraph may be considered personal data under applicable data protection laws.
Usage of our services: When you use our services, we may collect information about your engagement with and utilisation of our services, such as processor and memory usage, storage capacity, navigation of our services, and system-level metrics. We use this data to operate the services, maintain and improve the performance and utilisation of the services, develop new features, protect the security and safety of our services and our customers, and provide customer support. We also use this data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business.

3. Information that we receive from third-parties

Third-party accounts: If you choose to link our services to a third-party account, we will receive information about that account, such as your authentication token from the third-party account, to authorise linking. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options.

III.- How we use information

We use the information we collect in various ways, including to:

Provide, operate, and maintain our services.
Improve, personalise, and expand our services.
Understand and analyse how you use our services.
Develop new products, services, features, and functionality.
Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the service, and for marketing and promotional purposes.
Process your transactions.
Send you text messages and push notifications.
Find and prevent fraud.
For compliance purposes, including enforcing our Terms of Service, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

We may share the information we collect in various ways, including the following:

Vendors and service providers: We may share information with third-party vendors and service providers that provide services on our behalf, such as helping to provide our services, for promotional and/or marketing purposes, and to provide you with information relevant to you such as product announcements, software updates, special offers, or other information.
Aggregate information: Where legally permissible, we may use and share information about users with our partners in aggregated or de-identified form that can’t reasonably be used to identify you.
Advertising: We work with third-party advertising partners to show you ads that we think may interest you. These advertising partners may set and access their own cookies, pixel tags, and similar technologies on our services, and they may otherwise collect or have access to information about you which they may collect over time and across different online services. Some of our advertising partners are members of the Network Advertising Initiative or the Digital Advertising Alliance. To learn more about these programs, or opt-out of personalised ads, visit the Digital Advertising Alliance’s Self-Regulatory program for Online Behavioural Advertising at www.aboutads.info, or the Network Advertising Initiative at www.networkadvertising.org.
Third-party partners: We also share information about users with third-party partners in order to receive additional publicly available information about you.
Information we share when you signup through a referral. If you sign up for our services through a referral from a friend, we may share information with your referrer to let them know that you used their referral to sign up for our services.
Analytics: We use analytics providers such as Google Analytics. Google Analytics uses cookies to collect non-identifying information. Google provides some additional privacy options regarding its Analytics cookies at http://www.google.com/policies/privacy/partners/.
Business transfers: Information may be disclosed and otherwise transferred to any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
As required by Law and similar disclosures: We may also share information to: (1) satisfy any applicable law, regulation, legal process, or governmental request including requests made by public authorities to meet national security or law enforcement requirements; (2) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof; (3) detect, prevent, or otherwise address fraud, security, or technical issues; (4) respond to your requests; or (5) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

V.- Legal basis for processing personal information

Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it.

However, we will normally collect personal data from you only:

Where we need the personal data to perform a contract with you.
Where the processing is in our legitimate interests and not overridden by your rights
Where we have your consent to do so.

We have a legitimate interest in operating our services and communicating with you as necessary to provide these services, for example when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities.

In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person.

If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data).

VI.- Security

DIVERSITY is committed to protecting your information. To do so, we employ a variety of security technologies and measures designed to protect information from unauthorised access, use, or disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data. Please note that no service is completely secure. While we strive to protect your data, we cannot guarantee that unauthorised access, hacking, data loss or a data breach will never occur.

VII.- Data retention

We retain personal data we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements). When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

VIII.- Access

If you are a registered user, you may access certain information associated with your account by logging into our services or emailing [email protected]. If you terminate your account, any public activity on your account prior to deletion may remain stored on our servers and may remain accessible to the public.

To protect your privacy and security, we may also take reasonable steps to verify your identity before updating or removing your information. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business for disaster recovery purposes. Your ability to access and correct your information may be temporarily limited where access and correction could: inhibit DIVERSITY’s ability to comply with a legal obligation; inhibit DIVERSITY’s ability to investigate, make or defend legal claims; result in disclosure of personal data about a third party; or result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to DIVERSITY or a third party.

If you are a resident of the EEA, Switzerland, or the United Kingdom (“UK”), you have the following data protection rights:

If you wish to access, correct, update, or request deletion of your personal information, you can do so at any time by emailing [email protected].
To exercise your rights to deletion of your personal data under the GDPR or other data protection laws, you can do so at any time by emailing [email protected]. All account data will be deleted within 90 days of purging.
In addition, you can object to the processing of your personal data, ask us to restrict the processing of your personal data, or request portability of your personal data. Again, you can exercise these rights by emailing [email protected].
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing, please contact us by emailing [email protected].
Similarly, if we have collected and process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

X.- Changes to this Privacy Policy

This Privacy Policy may be modified from time to time, so please review it frequently. Changes to this Privacy Policy will be posted on our websites. If we materially change the ways in which we use or share personal data previously collected from you through our services, we will notify you through our services, on this page, by email, or other communication.

XI.- International data transfers

With respect to Personal Data of Data Subjects located in the EEA, Switzerland, or the United Kingdom that Customer transfers to DIVERSITY or permits DIVERSITY to access, the parties agree that by executing the DPA they also execute the Standard Contractual Clauses, which will be incorporated by reference and form an integral part of the DPA. The parties agree that, with respect to the elements of the Standard Contractual Clauses that require the parties’ input, Schedules 1-3 contain all the relevant information.

DIVERSITY complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF (“UK Extension”), and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. DIVERSITY has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension. DIVERSITY has also certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (together with the EU-U.S. Data Privacy Framework Principles, the “DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the DPF Principles, the DPF Principles will govern. To learn more about the Data Privacy Framework (“DPF”) program, and to view our certification, please visit https://www.dataprivacyframework.gov/. DIVERSITY’s compliance with the EU-U.S. DPF, UK Extension, and Swiss-U.S. DPF is subject to the investigatory and enforcement powers of the Federal Trade Commission.

DIVERSITY complies with the DPF Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions.

DIVERSITY commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF should first contact DIVERSITY using the details provided below.

DIVERSITY also commits to referring unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension, and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-data-privacy-framework for more information or to file a complaint. The services of JAMS are provided at no cost to you.

For complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found in Annex 1 of the DPF Principles.

XII.- Contact us

If you have any questions or concerns about this Privacy Policy, please email us at [email protected] or write to us at:

For customers and vendors in the Americas (North, Central, and South America):

ON DIVERSITY LLC
312 West 2nd Street
Suite A3100
82601 Casper, WY
United States

For customers and vendors in the European Union and other countries:

OD CLOUD LIMITED
30 Churchill Place
E14 5EU, East London
United Kingdom

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DIVERSITY, Unity in DIVERSITY and all DIVERSITY logos are a trademark registered in Spain and other countries.
Make with in UK, USA, Madrid & Tallinn.