Dive is a global app, and your information will be sent to and used in the United States regardless of the country you reside in. This Policy explains how we protect your personal data when we transfer it overseas, so please read very carefully!
If you have any questions or comments about this Policy, please feel free to contact us email@example.com
When you download the App and create an account ("Account"), we may collect certain information ("Registration Information") about you, such as:
The information we collect helps to enhance the App and verify our Users. Registration Information such as your name and username may be visible to the public on your profile page.
We may ask you to provide your full name, address and email address. Such details may be shared with third parties for purposes relating to, for example, any [loyalty programs, sending gifts or delivery of merchandise].
We may also collect additional information in connection with your use of Dive, for example if you use the electronic messaging function.
If you contact our Customer Support team, we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you).
We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers' license details and other sensitive information on your profile which is open to abuse and misuse.
Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. You may also choose to add sensitive information about yourself when you add certain Dive [NAME OF DEFAULT INFO DESIGNATIONS] to your profile, such as your religion and political leanings. While you may voluntarily provide this information to us when you create your profile, including your sexual preferences, there is no requirement to do so. Please remember that photographs that you post on Dive may reveal information about yourself as well. Where you do upload and choose to tell us sensitive information about yourself, including through adding certain [NAME OF DEFAULT INFO DESIGNATIONS] to your profile, you are explicitly consenting to our processing of your information and making this public to other Users.
When you post information about yourself or use the messaging function, the amount of personal information you share is at your own risk. Please see Section 4 below for more information on who can access what you post on Dive. If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate your Account.
For safety and security and to ensure you have the best possible user experience, we require users to verify their accounts. We want to avoid fake Dive accounts being created which can be used for malicious activities and cybercrime – they threaten the Dive network and ruin it for everyone.
It is your responsibility to ensure that the details in your Account are current. If your details change, please ensure that you update your Account.
To prevent abuse of the app/site, Dive uses automated decisions and moderators to block accounts as part of its moderation procedures. In order to do this, we check accounts and messages for content that indicates breaches of our Terms and Conditions of Use. This is done through a combination of automated systems and our team of moderators. If an account or message meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached, the relevant account will automatically be blocked. All users of accounts that have been blocked will be notified that their account has been blocked and affected users can contact Dive to contest the decision.
Dive also uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behavior that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. Where a transaction is blocked, the user will be notified that their transaction cannot be processed and affected users can contact Dive to contest the decision.
If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.
We process some limited data (demographics and information that you have optionally provided us with via Dive [NAME OF DEFAULT INFO DESIGNATIONS]) to drive targeted advertising in our legitimate interest, via promo cards and ads on our App. We also process limited data (device identifiers) and share this with third party advertising networks which host our ads. You can stop targeted advertising within the [“Contact & FAQ” page accessible via your profile]. If you opt-out of targeted advertising you will still see adverts though they will be less relevant to you. Through your device’s security settings you also have the option to prevent or limit device identifiers being shared with third party advertisers and what use is made of the device identifiers. If you would like more information about this practice and to know your choices about not having this information used by these companies, please visit this page.
Finally, we want to keep in touch with you to make sure you know about the great promotions and offers we have available. If you’ve told us it’s OK, we will use your email address to send you information on these. You can withdraw this consent at any time via Settings in the App.
For users who are California residents, the data we may collect falls within the following categories of “personal information,” as defined by the California Consumer Privacy Act (CCPA):
By using the App, you acknowledge that Dive is a global app operating through servers located in a number of countries around the world, including the United States. If you live in a country with data protection laws, the storage of your personal data may not provide you with the same protections as you enjoy in your country of residence.
If you turn these features on, when you use your mobile, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device's coordinates to offer certain features to you. This information helps us identify your physical location and we may use it to personalize the App and make it easier to confirm your location, to check-in and begin interacting with other Users, by enabling the information to be displayed and shared with other users.
If you have enabled location services, but wish to turn them off, you can do so by the following methods:
Please note that by turning off location services, you will be unable to connect with and interact with other Users.
Log and Usage Data
We keep your personal information only as long as we need it for legitimate business purposes (as set out in Section 11 below) and as permitted or required by applicable law.
In practice, we delete or anonymize your information upon deletion of your Account (following the safety retention window), unless:
Where Dive uses machine learning, for example, to help us detect and prevent fraudulent card transactions, and to detect and prevent spam communications on the App (as explained above), we may need to keep personal information for a longer period than the retention periods explained above, to enable the machine learning to work properly. Where this is the case, we always seek to minimize the amount of personal information that is used and we ensure that it is ring-fenced and kept securely from other user personal information. We regularly review the period for which personal information is required for machine learning purposes and delete any identifiable information when it is no longer required.
We may collect information about your device when you use the App including the unique device identifier, device model, operating system, and MAC address. In addition, if you permit us to do so, the App may access your device's address book solely in order to add someone to your contacts.
We may keep track of how you interact with links available on Dive including third party services and clients by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.
Cookies are small data files that are transferred to your computer's hard disk and are basically a tool that stores information about website visits, recognizes you and your preferences each time you visit Dive, and ensures site functionality and enables us to provide the services our users request.
The cookies we collect enable us to learn how people interact with Dive, which in turn helps us make a better product. Cookies store information about your website visits and can recognize you and your preferences each time you visit the Dive site. They help us to provide a better service.
Below is a table to explain Dive’s cookie functions and why they’re used.
If for any reason you decide that you do not want all of your Dive activities to be stored you may set your browser and mobile settings to block cookies and local storage devices, but please remember that if you do so, you may not be able to access all of the features Dive offers.
We use the following types of cookies:
|Cookie Functions||Cookie Purposes|
|Performance||We need to use certain cookies and save data to your local storage devices to ensure our members have the best possible experience. They assist with your navigation of our site, ensuring pages load quickly and respond promptly to your requests.|
The following are informational resources about cookies:
Our goal is to ensure your experience on Dive is enjoyable. In order to deliver an enjoyable experience, we may use your Registration and other information to:
Our policy is to not disclose your Registration Information, except in the limited circumstances described here:
|Circumstances where data may be disclosed||Disclosed data|
|Your Consent – If you consent, we may share or disclose your Registration Information, such as when you use a third party web client or application to access your Account.||This could include all data, including all CCPA Categories listed above|
|Service Providers - We engage certain trusted third parties to perform functions and provide services to us. We may share your Registration Information with these third parties, but only for the purposes of performing these functions and providing such services e.g. information technology companies (hardware and software) which provide services to support our products and help us with information security matters.||This could include all data, including all CCPA Categories listed above|
|Moderators – To monitor activity on the apps and approve content.||Name and user registration details, profile information, content of messages and photographs (CCPA Categories A, B, C, E, and H)|
|Payment Processing and Telecommunications Companies – To facilitate payments for our premium services.||Cardholder name, cardholder address, card number, payment amount, transaction date/time (CCPA Categories A, B, and D)|
|Law and Harm - As we mentioned in the Terms & Conditions, it is important that all users behave while using the App. We will cooperate with all third parties to enforce their legal rights, including but not limited to their intellectual property rights. We will also cooperate with law enforcement enquiries from within or outside your country of residence where we are required to by law, where there is an investigation into alleged criminal behavior or to protect the vital interests of a person. This may include preserving or disclosing any of your information, including your Registration Information, if we believe in good faith that it is necessary to comply with a law or regulation, or when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal request; to protect the safety of any person; to address fraud, security or technical issues e.g. through anti-spam providers to protect the service from criminal activity or to protect our rights or property or those of third parties. In such cases we may raise or waive any legal objection or right available to us.||This could include any personal data that Dive holds about you, depending on the nature of the request or the issue that we are dealing with, including all CCPA Categories listed above|
|Business Transfers -In the event that Dive or any of our affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organization, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.||This could include all personal data that Dive holds about you, including all CCPA Categories listed above|
|Advertising Partners – To serve targeted advertisements to users.||Device ID, geolocation data, demographic data (CCPA Categories C, F, and G)|
|Anti-Spam and Anti-Fraud -Your data may be shared with other Dive companies, for example, to block accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures.||Email address, IP address and IP session information, social network ID, username, user agent string, and transaction and payment data (CCPA Categories B, F and D).|
Aggregated Information – We may share aggregated information with third parties that includes your personal data (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling. You may opt-out of receiving marketing messages by using the opt-out mechanisms and links provided in each email.
We ensure these parties must adhere to strict data protection and confidentiality provisions that are consistent with this Policy. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible.
Dive does not sell your data and has not sold your personal data in the previous 12 months.
Our App is designed to make it easy for you to connect with other Users and to interact with them. If you register or log in to the App using your Facebook account, you are authorizing us to access certain Facebook account information, including information you make available via Facebook, your friends list, current location and those friends you have in common with other users. You also understand that your Dive profile and other information you make available via the App, including information you provide directly or indirectly through Facebook (i.e., your Facebook photos, your name, age, approximate location, friends you have in common with other users and other profile information), may be viewed and shared by users with individuals who may or may not be Users or via third party applications in such users’ discretion. For example, a User may recommend you as a match to his or her Facebook friends by sharing your picture, regardless of whether such friend(s) is also a User of the App. You might share information like the photos and messages you send or upload any metadata provided with those messages, along with any comments or information you provide in connection with your photos.
When using Dive, you should assume that everything you post or submit on the App may be publicly-viewable and accessible, both by Users of the App and non-Users of the App. We want our users to be careful about posting information that may eventually be made public.
If you log in to or access Dive through your Facebook profile, remember to log off Facebook when you leave a device in order to prevent other users from accessing your Account.
You may access or modify your Registration Information at any time.
When your Account is deactivated, we make reasonable efforts to make sure it is no longer viewable on the App. For up to 30 days after deactivation of your Account, you have the option to restore your Account. After 30 days, we begin the process of deleting your Account from our systems. We are not responsible for any information, pictures, comments, or other content that is deleted from our systems resulting from the deactivation of your Account.
To prevent abuse and/or misuse of Dive by a User following termination or deletion of a/an profile/Account we may retain any information we deem, in our sole discretion, may be necessary to ensure that a User does not open a new Account and profile in breach of our Terms and Conditions of Use and to ensure compliance with all applicable laws and regulations.
Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by other Users or to the extent such information has been shared with search engines. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information they may retain such information to the extent permitted under their terms of service and/or privacy policies.
Removed and deleted information may persist in backup copies for up to 30 days to enable restoration, but will not be available to others in the meantime.
You must be at least 18 years of age to use the App.
Dive does not knowingly collect any information about or market to children, minors or anyone under the age of 18. If you are less than 18 years of age, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person's registration and delete their Registration Information from Dive. If we do delete a profile because you violated this rule, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new profile.
Here at Dive we pride ourselves on taking commercially reasonable security measures to help protect your information against loss, misuse and unauthorized access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.
No website or Internet transmission is completely 100% secure and, as such, we cannot and do not guarantee that unauthorized access, hacking, data loss or other breaches will not occur. Below is guidance on how to protect your data:
Do not share your social media password with anyone.
If you suspect someone has accessed your social media account or had access to your social media password, please report it to the relevant social media platform and change your password immediately. We cannot and do not guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk.
WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ANY BREACHES OF SECURITY, DAMAGE TO YOUR DEVICE, OR ANY LOSS OR UNAUTHORIZED USE OF YOUR REGISTRATION INFORMATION OR OTHER DATA.
If you registered with Dive using a third party social media platform, such as Facebook, your Dive profile will be available to all Users of Dive whether via our App or our partners' websites.
Remember that when you register with a third party, you are also giving them personal information, so we recommend that you read their privacy policies as Dive does not control how they use information.
If you have registered on one of these third party websites, such as Facebook, or you have verified your Account via a third party website, we may connect your Dive profile with your profile on such website. We may do this by way of new products and applications which we introduce from time to time, including new products powered by our companies.
If you created a Dive profile through a third party website and you do not want to link your Dive profile to your profile on the third party website, Dive cannot amend these settings. Please visit the application settings on your third party website profile and follow the instructions to remove the Dive access permissions.
We only use the APIs, OAuth Tokens, Widgets, or other means provided by the applicable Social Media Account to integrate your Social Media Account with our App. As such, we only receive the limited information that each Social Media Account permits to be transferred.
For users who are California residents, you have the following rights (in addition to those listed in section 11 below) under the California Consumer Privacy Act (the “Act”):
California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can write to us at [EMAIL].
If you consent, we may, from time to time, disclose your contact information to third parties to allow them to market their products or services to you or for other marketing purposes. This may be information we received from you offline and online. If you want us to stop further sharing your email contact information with third parties (if we have your email contact information), you may notify us at [EMAIL]. Please follow the instructions provided to you by third parties to unsubscribe from their messages. If you have opted-out as described above, and thereafter you choose to use a service or promotion that requires us to contact you or share your information with a third party, then your previous opt-out preferences will not apply to such service.
In addition, under California law, operators of online services are required to disclose how they respond to "do not track" signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users' personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users' online activities over time and across different online services when the users use the operator's service. We do not knowingly permit third parties to collect personal information about an individual user's online activities over time and across different online services when using the App.
Under UK and EU law, you have the right to lodge a complaint with data protection regulators, and the Information Commissioners’ Office (ICO) is the UK’s lead regulator. You can find out how to raise a concern with the ICO by visiting their website at www.ico.org.uk. If you’re within the EU, you may also get in touch with your local Data Protection Regulator who may liaise with the ICO on your behalf.
You have a number of rights under European Data Protection law as detailed below.
Dive has designated a [TITLE] and they can be reached by emailing [EMAIL] or by post at the following address:
[ADDRESS IN EU]
If you would like to exercise any of your rights listed above please visit [LINK TO PAGE] or email us at [EMAIL]. You can also contact us by post at the address above.
How does Dive protect my personal data?
Dive has implemented appropriate security measures to protect and prevent the loss, misuse, and alteration of the information under our control, including your personal data. Our technical experts at Dive work hard to ensure your secure use of our site.
While we take reasonable precautions against possible security breaches of our website, user database and records, no website or Internet transmission is completely secure and we cannot and do not guarantee against unauthorized access, hacking, data loss, or other breaches. We urge you to take steps to keep your personal data safe (including your password) and to log out of your Account after each use. If you lose your password or share it, or another service provider that you use suffers a data breach and you have used the same credentials with that service provider as you have with Dive, your personal data may be compromised. If that happens, please report it to Support via [WEBSITE/EMAIL/CONTACT INFO].
Where is my personal data kept?
To enable us to provide the Dive service around the world, we operate a global network of servers including in the US & ForeignTerritories. The hardware is located in third-party data centers. Data collected by advertising partners may also be held outside the European Economic Area. We ensure that the data is adequately protected by ensuring that valid, legal mechanisms are in place such as: EU approved model clauses, and implementing robust contractual standards. If you want more information relating to the nature of the safeguards we have in place, please email firstname.lastname@example.org.
Does Dive collect any other personal data about me?
If you contact our Customer Support team, we will receive your email address, and may track your IP address, as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other users (and from other users about you) for 6 years after deletion of your Account.
Does Dive use my personal data for any other purpose?
We may use material that you post on the open access areas of Dive in advertising and promotional materials on our partner sites and partner products. We believe these uses are in line with our legitimate interests in enabling us to improve our site and better tailor your online experience. If we intend to do this, we will contact you for your prior consent.
From time to time we may run surveys for research purposes and we may contact you to find out if you would like to take part. We may also contact you to find out if you would like to take part in marketing campaigns. Such surveys and marketing campaigns are optional and more information will be provided at the point of contact. We may also contact you for feedback purposes. If you do not wish to be contacted to take part in a survey or marketing campaign, please contact our Customer Support Team.
We use your personal data to resolve disputes, troubleshoot problems and enforce our Terms and Conditions of Use.
Under EU and UK data protection laws, we are only permitted to use your data when we have a lawful basis to do so. The table below provides an overview of the legal basis that we rely on to use your data. Where the legal basis is consent, you can withdraw consent at any time. Where the legal basis is legitimate interests, you have a right to object to our use of your data. We explain in the relevant sections in this Policy how you can withdraw consent or opt-out of certain data uses (where applicable).
|Purpose for which data is used||Data||Source||Legal basis|
|To provide you with the Dive social networking service||Name, email address, date of birth, location (CCPA Categories A and B)||You provide your name, email address and date of birth to us. We obtain location data from the device that you use to access the service||Contractual necessity|
|To facilitate networking opportunities on the Dive site||Optional information that you choose to provide in your profile, including through adding Dive [NAME OF DEFAULT INFO DESIGNATIONS], which may include information about your sexual preferences, non-binary gender, religion, ethnic background, photos etc. (CCPA Categories C, H, I, J)||You provide this information to us||Consent|
|To verify your identity and prevent fraud and to ensure the safety and security of Users||Email address (CCPA Category B)||You provide this information to us||Legitimate interests – it is in our legitimate interests to ensure that accounts are not set up fraudulently and to safeguard Users of the site|
|To take payment for premium services||Payment card details (CCPA Categories B and D)||You provide this information to us||Contractual necessity and legitimate interests – we have a legitimate interest in receiving payment for our premium services|
|To send you marketing information about our offers and services||Email address (CCPA Category B)||You provide this information to us||Legitimate interests – it is in our legitimate interests to promote our products and services|
|To show “nearby” location information to you and other users of the App||Wifi access points and location data when you use the App (CCPA Category G)||We obtain this information from the device that you use to access the service||Legitimate interests – it is in our legitimate interests to provide this functionality as part of the services|
|To carry out research and analysis to help us improve the App||Log and usage data, including IP address, browser type, referring domain, pages accessed, mobile carrier and search terms (CCPA Category F)||We obtain this information from the device that you use to access the service||Legitimate interests – it is in our interests to analyze the way in which Users are accessing and using our services so that we can further develop the App and improve the service|
|To respond to correspondence and queries that you submit to us, including social media queries||Email address and IP address, social media name, (CCPA Categories B and F)||You provide your email address, and social media name to us when you contact us and we obtain your IP address from the device that you use to contact us||Legitimate interests – it is in our legitimate interests to respond to your queries to ensure that we provide a good service to Users and troubleshoot problems|
|To block accounts as part of our anti-spam procedures||Email address, IP address and IP session information, social network ID, username, user agent string (CCPA Categories B and F)||You provide your email address, and username to us. We obtain the other information from the device that you use to access the service||Legitimate interests – it is in our legitimate interests to prevent unauthorized behavior and to maintain the safety and security of our services|
|To enable users to create their Dive profile and log into the app via Facebook||Data from Facebook, including email address, name and profile picture, date of birth, friends who use the app, pages liked, location and photos (CCPA Categories A, B, C, and H)||We obtain this information from Facebook||Legitimate interests – it is in our legitimate interests to facilitate access to our services|
|To block payment transactions as part of our anti-fraud procedures||Name, IP address, email address, mobile number, cardholder name, payments received, type of payment, user ID, country (CCPA Categories, A, B, and D)||You provide your name, email address, mobile number and card details to us. We obtain your IP address from the device that you use to contact us. We obtain your payment information from your interactions with our service||Legitimate interests – it is in our legitimate interests to prevent fraudulent transactions and to maintain the security of our services|
|To serve promo cards and advertisements on the App||Demographic, location data, email address (CCPA Categories A, B, C and G)||We obtain demographic data from you, and location data from the device that you use to access the service. You provide your email address to us||Legitimate interests – it is in our legitimate interests to target advertisements so that users see relevant advertisements and to allow us to generate income from advertising revenue|
|To serve advertisements on third party networks||Device identifiers (IDFA and GAID) (CCPA Category F)||We obtain this information from the device that you use to access the service||Legitimate interests – it is in our legitimate interests to serve advertisements and to promote our products|
|To contact you in order to run surveys for research purposes and to obtain feedback, and to find out if you want to take part in marketing campaigns||Email address (CCPA Category B)||You provide this information to us||Legitimate interests – it is in our legitimate interests to carry out research so that we can further develop the app and improve the service|
|To defend legal claims, protect legal rights and to protect people from harm||This could include any information that is relevant to the issue||This information may be obtained directly from you, from your device or from third parties, depending on the information involved||Legitimate interests – it is in our legitimate interests to protect our legal rights, defend legal claims and to protect our users and third parties from harm|