Privacy and Security Policies
Updated: November 9th, 2021
This Privacy and Security Policy governs the manner in which Alluresoft, LLC, a Missouri limited liability company (“Company”) collects, uses, maintains and discloses information collected from users (each, a “User”) of its https://divvyhq.com website and any derivative or affiliated websites on which this Privacy and Security Policy is posted (collectively, the “Website”). Company reserves the right, at its discretion, to change, modify, add or remove portions of this Privacy and Security Policy at any time by posting such changes to this page. You understand that you have the affirmative obligation to check this Privacy and Security Policy periodically for changes, and you hereby agree to periodically review this Privacy and Security Policy for such changes. The continued use of the Website following the posting of changes to this Privacy and Security Policy constitutes an acceptance of those changes.
User Privacy Notice
Company believes that every User should know how it utilizes the information collected from Users. Users can also object to certain uses of information and can access and update certain information that we may obtain. But note that the Website is intended for use by organizations. Where the Website is made available to you through an organization (e.g. your employer), that organization is responsible for the account(s) of which it has control. Account administrators maintain the control to invite, restrict, suspend or terminate access for Users of the Website, and thus consent to data transfer and processing on your behalf. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy.
The Website is not directed at children under 13 years of age, and Company does not knowingly collect personally identifiable information from children under 13 years of age online.
Please note that the Website may contain links to other websites. These linked sites may not be operated or controlled by Company. Company is not responsible for the privacy practices of these or any other websites, and you access these websites entirely at your own risk. Company recommends that you review the privacy practices of any other websites that you choose to visit.
Transfer of Personal Data
Company is based, and the Website is hosted, in the United States of America. If User is from the European Economic Area (EEA) or other regions of the world with laws governing data collection and use that may differ from U.S. law and User is registering an account on the Website, visiting the Website, purchasing products or services from Company or the Website, or otherwise using the Website, please note that any personally identifiable information that User provides to Company will be transferred to the United States. Any such personally identifiable information provided will be processed and stored in the United States by Company or a service provider acting on its behalf. By providing your personally identifiable information, User hereby specifically and expressly consents to such transfer and processing and the uses and disclosures set forth herein.
Legal Bases for Processing (for EEA Users)
If you are a User in the EEA, we collect and process information about you only where we have legal bases for doing so under applicable EU laws. This means we collect and use your information only where:
- We need it to provide you access to the Website, including to operate the Website, provide customer support and personalized features and to protect the safety and security of the Website;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Website and to protect our legal rights and interests;
- It is necessary for the performance of a contract to which the User is party or in order to take steps at the request of the User prior to entering into a contract;
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Website.
The Information Company Collects
Users browsing the Website without registering an account or affirmatively providing personally identifiable information to Company do so anonymously. Otherwise, Company may collect personally identifiable information from Users in a variety of ways. Personally identifiable information may include, without limitation:
- (i) contact data (such as a User’s name, mailing and e-mail addresses);
- (ii) demographic data (such as a User’s country, state and zip code);
- (iii) financial information collected to process purchases made from Company via the Website or otherwise (such as credit card, debit card or other payment information); and
- (iv) other information requested during the account registration process (such as job title).
Company may also collect information about how Users use the Website, for example, by using Analytics technologies, or the domains and IP addresses from which Users originate. While not all of the information that Company collects from Users is personally identifiable, it may be associated with personally identifiable information that Users provide Company through the Website or otherwise.
Our platform does not support, nor require, the collection of data that the GDPR defines as special category data. As such, any special category data that may be added into our platform is done so at the full discretion of our Users.
How Company Uses Information
Company may use personally identifiable information collected through the Website for the specific purposes for which the information was collected, to process purchases and sales of products or services offered via the Website, to contact Users regarding products and services offered by Company, its parent, subsidiary and other related companies and its trusted affiliates, independent contractors and business partners, and otherwise to enhance Users’ experience with the Website, Company and such affiliates, independent contractors and business partners.
Company may also use information collected through the Website for research regarding the effectiveness of the Website and the business planning, marketing, advertising and sales efforts of Company, its trusted affiliates, independent contractors and business partners.
Disclosure of Information
Company may disclose personally identifiable information collected from Users to its parent, subsidiary and other related companies, trusted affiliates, independent contractors and business partners who will use the information for the purposes outlined above, as necessary to provide the services offered by Company and to provide the Website itself, and for the specific purposes for which the information was collected. See our list of Third-Party Subprocessors here.
Company may also disclose personally identifiable information for any of the following:
- At the request of law enforcement or governmental agencies or in response to subpoenas, court orders or other legal process, to establish, protect or exercise Company’s legal or other rights or to defend against a legal claim or as otherwise required or allowed by law
- In order to protect the rights, property or safety of a User or any other person
- To investigate or prevent a violation by User of any contractual or other relationship with Company or the perpetration of any illegal or harmful activity.
Company may also disclose aggregate, anonymous data based on information collected from Users to investors and potential partners.
Finally, Company may disclose or transfer personally identifiable information collected from Users in connection with or in contemplation of a sale of its assets or business or a merger, consolidation or other reorganization of its business.
Personal Information Provided as Part of User Content
If a User includes personally identifiable information as part of a piece of User Content that has been stored within the Website, such information may be made available to any parties that are associated under the same DivvyHQ account. Company does not edit or otherwise remove such information from User Content before it is posted on the Website. If a User does not wish to have such User’s personally identifiable information made available in this manner, such User must remove any such information from the User Content before posting. User contact information (which may include, without limitation, a User’s username and email address) may be included with any User Content that a User posts via the Website. Company is not liable for any damages caused or incurred due to personally identifiable information made available in the foregoing manners.
Security of Information
Information about Users that is maintained on Company’s systems is protected using generally accepted industry security standards. However, no security measures are perfect or impenetrable, and Company cannot guarantee that the information submitted to, maintained on or transmitted from its systems will be completely secure. Company is not responsible for the circumvention of any privacy settings or security measures relating to the Website by any Users or third parties.
Correcting, Updating, Accessing or Removing Personal Information
If a User’s personally identifiable information changes (such as a User’s zip code), or if a User no longer desires to receive non-account specific information from Company, Company will endeavor to provide a way to correct, update and/or remove that User’s previously-provided personal data. This can be done by emailing a request to Company at email@example.com. Additionally, you may request access to the personally identifiable information as collected by Company by sending a request to Company as set forth above.
Please note that in certain circumstances, Company may not be able to completely remove a User’s information from its systems. For example, Company may retain a User’s personal information for legitimate business purposes, if it may be necessary to prevent fraud or future abuse, for account recovery purposes, if required by law or as retained in Company’s data backup systems or cached or archived pages. All retained personally identifiable information will continue to be subject to the terms of the Privacy and Security Policy to which the User has previously agreed. Please note that you may access and manage your account via the “My Account” link available within the DivvyHQ application.
If you have any questions or comments about this Privacy and Security Policy, you may contact Company via any of the following methods:
PO Box 414897
Kansas City, MO 64141
Your California Privacy Rights
California Civil Code Section 1798.83 permits Users that are residents of California to request certain information regarding Company’s disclosures of personally identifiable information to third parties for such third parties’ direct marketing purposes. If User is a California resident and would like to make such a request, please email Company at firstname.lastname@example.org or write Company at PO Box 414897, Kansas City, Mo 64141.