Privacy Policy

Last updated: May 2025

1. Introduction

Welcome to Diveri, operated by Twolf ("we," "our," or "us"). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and services.

As a company based in the Netherlands, we comply with the General Data Protection Regulation (GDPR) and Dutch data protection laws.

2. Information We Collect

2.1 Personal Information

We collect personal information that you provide to us, including but not limited to:

Name and username
Email address
Profile information (bio, interests, etc.)
Location data (with your permission)
Communications and messages within the app

2.2 Automatically Collected Information

When you use our app, we automatically collect certain information:

Device information (type, operating system, unique device identifiers)
Usage data (features used, time spent, interactions)
IP address and general location
Crash reports and performance data

3. How We Use Your Information

We use the collected information for various purposes:

To provide and maintain our services
To match you with compatible community members
To send you notifications about your account and activities
To improve and personalize your experience
To ensure safety and prevent abuse
To comply with legal obligations

4. Information Sharing and Disclosure

We may share your information in the following situations:

With other users: Your profile information and content you share in Circles
With service providers: Third parties who help us operate our services
For legal reasons: When required by law or to protect rights and safety
With your consent: When you explicitly agree to sharing

We never sell your personal information to third parties.

5. Data Security

We implement appropriate technical and organizational security measures to protect your personal information in accordance with GDPR requirements. However, no method of transmission over the Internet or electronic storage is 100% secure.

While we strive to protect your personal information, you acknowledge that: (i) there are security and privacy limitations inherent to the Internet which are beyond our control; and (ii) security, integrity, and privacy of any information exchanged between you and us cannot be guaranteed.

6. Your Rights and Choices

You have the following rights regarding your personal information:

Access: Request a copy of your personal data
Correction: Update or correct inaccurate information
Deletion: Request deletion of your account and personal data
Portability: Receive your data in a machine-readable format
Opt-out: Unsubscribe from marketing communications

7. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we learn we have collected such information, we will promptly delete it.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place to protect your information in accordance with this Privacy Policy.

9. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date.

10. Data Retention

We retain your personal information for as long as necessary to provide our services and fulfill the purposes outlined in this Privacy Policy. When you delete your account, we will delete or anonymize your personal information within 90 days, except where we are required to retain it by law or for legitimate business purposes.

11. Third-Party Services

Our Service may contain links to third-party websites or services that are not owned or controlled by Diveri. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services.

12. California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

Right to know what personal information is collected, used, shared or sold
Right to delete personal information
Right to opt-out of sale of personal information (we do not sell personal information)
Right to non-discrimination for exercising privacy rights

13. European Privacy Rights

As we are based in the Netherlands, all users have rights under the General Data Protection Regulation (GDPR):

Right to access your personal data
Right to rectification of inaccurate data
Right to erasure ("right to be forgotten")
Right to restrict processing
Right to data portability
Right to object to processing
Rights related to automated decision-making
Right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens)

To exercise these rights, please contact our Data Protection Officer at dpo@diveri.app.

14. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us at:

Twolf - Privacy Team
Email: privacy@diveri.app
Email: support@diveri.app

Data Protection Officer
Email: dpo@diveri.app

Twolf is a company registered in the Netherlands. We do not provide a physical address for privacy and security reasons. All privacy-related correspondence should be directed to our privacy email address.

For complaints, you may also contact the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at www.autoriteitpersoonsgegevens.nl.