Privacy Policy

 📝 Divan Policy

Thank you for using Taavia. Please read this Privacy Policy carefully before using our Services, to understand how we collect, use, disclose, and protect your personal data. This Policy also explains the legal bases on which we process your data, in compliance with applicable data protection laws (including GDPR).

Scope:

If you do not agree to this Privacy Policy, please do not access or use our Services.

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Supplementary Nature:

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Third-Party Services:

We are not responsible for the privacy practices of such third parties, and you should consult their respective privacy policies before using those services.

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Divan Privacy Policy

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I. How Do We Collect and Process Your Personal Data

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II. How Do We Use Your Personal Data

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III. How Do We Use Cookies and Similar Technologies

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IV. How Do We Disclose Your Personal Data

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V. How’s Your Personal Data Transferred Globally

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VI. How Do We Retain Your Personal Data

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VII. How Do We Protect Your Personal Data

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VIII. How Do We Process Children’s Personal Data

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IX. Your Rights to Your Personal Data

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X. How to Update the Privacy Policy

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XI. How to Contact Us

Data Type	Description	Source
Account Information	Includes name, email address, or similar data provided when signing up or requesting services.	Information directly provided by you.
User Content	Any data you upload or provide when using our Services, including prompts, text, files, images, or audio (if any).	Information directly provided by you.
Feedback	Ideas, suggestions, or rating responses (e.g., thumbs up/down) which are stored as part of your usage history.	Information directly provided by you.
Communication Information	Messages you send via email or social media channels, including name, contact details, and message contents.	Information directly provided by you.
Log Data	Automatically collected device and usage information such as device brand/model, IP address, browser type, and timestamps.	Information automatically collected during your use of the Services.
Usage Data	Includes types of content viewed, features used, session details, location (by country), device type, and browser/system details.	Information automatically collected during your use of the Services.
Cookies	Used to enhance your experience. See Section III of this Privacy Policy for full details.	Information automatically collected via cookies and similar technologies.
SNS Login Data	If logging in with platforms like Google or GitHub, we may collect info (name, email, profile picture) as permitted by your SNS privacy settings.	Information received from third parties with your consent.

Thank you for using Divan. Please read this Privacy Policy carefully before using our Services, to understand how we collect, use, disclose, and protect your personal data. This Policy also explains the legal bases on which we process your data, in compliance with applicable data protection laws (including GDPR).

This Privacy Policy applies to your access and use of services provided by Taavsystem Inc. through Divan.ai and related digital platforms. By accessing the Services or clicking “Agree” during registration, you consent to the collection, use, processing, and sharing of your personal data by Divan and its authorized representatives as described herein.

This Privacy Policy does not supersede or replace any prior consents you may have given us regarding your personal data. All consents granted here are cumulative and without prejudice to our other lawful bases for processing under applicable law.

This Policy does not apply to products or services independently provided by third parties via our Services (e.g., external links or search results).

This Privacy Policy helps you understand how we handle your personal data. It is organized into the following sections:

This section explains how we collect your personal information and the processes involved in its handling to provide services and features of the Divan platform.

This section describes how we use your personal data for various purposes such as providing services, improving performance, and enhancing your experience with the Divan platform.

This section details how we use cookies and similar technologies to gather information about your interaction with Divan’s services and digital platforms.

This section explains the conditions and circumstances under which we may share your personal data with others, such as service providers and legal authorities.

This section outlines the processes for transferring your personal data across countries and ensures that legal requirements are met during such transfers.

This section describes the data retention policies and practices for storing your personal information and the duration for which it is retained based on business and legal requirements.

This section provides details about the security measures and technical safeguards implemented to protect your data from unauthorized access, alterations, or unlawful deletion.

This section outlines the policies regarding the collection and processing of personal data from children (under 18 years) and the specific conditions applied to such data.

This section explains the various rights you have concerning your personal data, such as access, correction, deletion, and restriction of processing.

This section explains how and why the privacy policy may be updated and how you will be notified of these changes.

This section provides contact details for Divan’s support team for any inquiries or requests related to privacy.

Third-Party Personal Data

1. Explicit Consent for Providing Third-Party Data:

If you provide us with any personal data relating to a third party (e.g., your spouse, children, parents, or friends), by doing so you represent and warrant to Divan that:

• You have obtained the explicit consent of such third party to provide us with their personal data.
  
  

• The third party is informed of and agrees to the purposes outlined in this Privacy Policy.
  
  

• The third party consents to the collection, use, and disclosure of their personal data by or for the benefit of the parties referenced herein.
  
  

2. Accuracy and Update of Data:

You must ensure that all personal data you submit to us is complete, accurate, true, and up-to-date. Failure to do so may result in our inability to provide you with the products and/or services you have requested.

Purpose/Activity:

1. To provide, maintain, and facilitate our Services:

• Types of Personal Data: Account Info, User Content, Feedback, Communication Info, Log Data, Usage Data, Cookies
  
  

• Lawful Basis for Processing: To perform a service contract with you
  
  

2. To send marketing communications (where subscribed):

• Types of Personal Data: Account Info, Communication Info
  
  

• Lawful Basis for Processing: Consent (where required under applicable law)
  
  

3. To prevent fraud, illegal activity, or misuse, and protect the security of our systems:

• Types of Personal Data: Account Info, User Content, Log Data, Usage Data, Cookies
  
  

• Lawful Basis for Processing: Legitimate interests (security) / Legal obligation
  
  

4. To provide technical support and improve our Services:

• Types of Personal Data: Account Info, Feedback, Log Data, Usage Data, Cookies
  
  

• Lawful Basis for Processing: Legitimate interests (security & maintenance)
  
  

5. To improve the accuracy and quality of our services (including AI models):

• Types of Personal Data: User Content, Feedback
  
  

• Lawful Basis for Processing: Legitimate interests (better user experience)
  
  

6. To comply with legal obligations and protect rights, privacy, and safety:

• Types of Personal Data: All relevant data categories
  
  

• Lawful Basis for Processing: Legitimate interests and legal obligations
  
  

Divan Privacy Policy

In addition to the purposes described above, and where permitted under applicable law, we may also collect, use, and disclose your personal data for the following purposes:

1. Responding to, processing, and handling your queries, feedback, or suggestions, and providing customer support:

We may collect and use your information to respond to your queries, feedback, or suggestions, and provide the necessary customer support.

2. Verifying your identity:

We may use your personal information to verify your identity.

3. Managing the administrative and business operations of Divan and complying with internal policies:

Your information may be used for managing Divan’s internal and business operations, including compliance with internal policies and regulations.

4. Facilitating business asset transactions, such as mergers, acquisitions, or sales:

If necessary, your information will be used to facilitate business transactions such as mergers or asset purchases and sales.

5. Issuing media statements and responding to press inquiries:

Your information may be used to issue public statements or respond to media inquiries.

6. Managing legal claims, documentation, and dispute resolution processes, including legal advice and contract enforcement:

We may use your information to manage legal claims, documentation related to them, and dispute resolution processes, including legal advice and contract enforcement.

7. Managing and preparing reports of incidents and accidents:

Your information may be used for preparing reports related to incidents and accidents.

8. Any other purpose reasonably related to or necessary for the above activities:

We may use your data for any other purpose reasonably related to or necessary for the above activities.

Additionally, subject to applicable law, you will be deemed to have consented to the collection, use, and disclosure of your personal data in the following situations:

1. Where you voluntarily provide your personal data in response to a specific request for an identified purpose, and it is reasonable to assume your intention was to share that data.

2. Where the collection, use, and/or disclosure is reasonably necessary for the formation or performance of a contract between you and us (or a third party requested by you), even if such third parties are not specifically named in this Privacy Policy.

In certain cases involving specific products or services, we may notify you of additional purposes for which your data is being processed. Where so notified, we will process your data accordingly.

Divan Privacy Policy – Cookies and Similar Technologies

We may use cookies and similar technologies to gather information resulting from your access and/or use of the Divan platform. These technologies may include:

1. Cookies or Browser Cookies:

Cookies are small text files stored on your device when you visit our website or platform, helping us retain information such as your preferences.

Cookies can be either:

• Persistent Cookies: These remain across sessions.
  
  

• Session Cookies: These are deleted when you close your browser.
  
  

We may use both types for the purposes listed below:

Cookie Types

Cookie Type	Duration	Administered By	Purpose
Necessary / Essential Cookies	Session	Divan	Required for proper functioning of our Services, used to authenticate users and prevent fraudulent use.
Cookies Policy / Notice Acceptance Cookies	Persistent	Divan	Detects whether the user has accepted the use of cookies.
Functionality Cookies	Persistent	Divan	Remembers choices like login details, language preferences, to enhance user experience.

Use of Cookies and Similar Technologies:

Additionally, we may use cookies and similar tracking technologies to:

• Analyze user trends: To analyze user behavior and improve services.
  
  

• Manage our platform: For platform maintenance and performance improvements.
  
  

• Track engagement and navigation: To analyze how users engage with our platform.
  
  

• Enhance service quality: To continuously improve the quality of our services.
  
  

The information collected may include your IP address, browser type, ISP, referring/exit pages, files viewed (e.g., HTML, graphics), operating system, timestamp, and clickstream data.

Divan Privacy Policy – Web Beacons and Cookie Management

1.2 Web Beacons

Some parts of our Services may contain small electronic files known as web beacons (also called clear gifs, pixel tags, or single-pixel gifs). These help us:

• Count how many users have visited certain pages.
  
  

• Analyze the popularity and usage of certain features and content.
  
  

• Improve the performance and reliability of our Services.
  
  

2. Clear or Disable Cookies

You may manage cookies through your browser settings. We will respect your cookie preferences and only use cookies and similar technologies accordingly.

🔔 Please note that some functions of our Services rely on cookies. If you do not accept or disable cookies, some features may not work as intended.

Here are links to documentation for common browsers (for reference only – Divan is not liable for accuracy or updates):

• Microsoft Internet Explorer
  
  

• Microsoft Edge
  
  

• Mozilla Firefox
  
  

• Google Chrome
  
  

• Safari for macOS
  
  

• Safari for iOS
  
  

3. More Information About Cookies

To learn more about cookies, including how to accept, delete, or disable them, you may visit:
🌐 www.allaboutcookies.org

Divan Privacy Policy – Disclosure of Personal Data

We may disclose your personal data to the following categories of recipients:

1. Our affiliated companies within the Divan Group, and/or their designated service providers:

Our affiliated companies within the Divan Group, and/or their designated service providers, who process personal data to help us provide our Services to you.

2. Third-party service providers and business partners:

Third-party service providers and business partners, who process data on our behalf for purposes outlined in this Privacy Policy or as required for the delivery of our Services.

3. Analytics providers, search engine operators, or similar third-party platforms:

Analytics providers, search engine operators, or similar third-party platforms that assist in improving, optimizing, or operating our websites, platforms, or services.

4. Any business partner, investor, assignee, or transferee:

Any business partner, investor, assignee, or transferee (actual or prospective) in the context of a business transaction involving a merger, acquisition, or asset/debt transfer involving Divan or any of its entities.

5. Competent law enforcement agencies, regulators, courts, government bodies, or our professional advisors:

Competent law enforcement agencies, regulators, courts, government bodies, or our professional advisors, where disclosure is necessary:

• (i) under applicable laws and regulations,
  
  

• (ii) to establish, exercise or defend our legal rights or those of third parties,
  
  

• (iii) to protect your vital interests or those of another individual;
  
  

6. Any other party, where you have explicitly consented to such disclosure.

Divan Privacy Policy – International Data Transfers

Depending on your location and the features of the Services you access or use, your personal data may be transferred to and processed in countries outside your jurisdiction, such as to a Divan Group affiliate or third-party service provider (as outlined in Section IV).

These countries may have different data protection laws from those in your country (and in some cases, may not offer the same level of protection).

🔐 Nevertheless, we implement appropriate safeguards to ensure that your personal data remains protected in accordance with this Privacy Policy and applicable law. We only transfer personal data internationally in compliance with relevant data protection laws and using legally valid data transfer mechanisms.

📍 Generally, our Services are operated from Canada, and our group companies and service providers are primarily based in Canada and/or Germany. Therefore, your personal data is typically processed in one or both of these jurisdictions.

Divan Privacy Policy – Data Retention

We retain your personal data only for as long as we have a legitimate business or legal reason to do so—such as to fulfill a service you have requested or to comply with applicable legal, tax, or accounting obligations.

In some situations, we may also retain your personal data after your account has been deleted, including:

• Where we are legally obligated to do so (e.g., by court order)
  
  

• To respond to user complaints or requests
  
  

• For ongoing legal proceedings or regulatory compliance matters
  
  

⏳ The retention period depends on the nature of the personal data, its purpose, and any legal requirements associated with it.

🗑 Once we no longer need to retain your personal data, we will securely delete it or anonymize it so that it can no longer be associated with you.

Divan Privacy Policy – Data Security

We implement appropriate technical and organizational measures to safeguard the personal data we collect, use, disclose, and process. These safeguards are designed to provide a level of security appropriate to the risk of the data processing involved.

Our security measures include:

1. Encrypting your personal data both in transit and at rest:

We encrypt your personal data both while it is being transferred and when it is stored.

2. Developing and implementing an Information Security Programme based on recognized industry standards:

We have developed and implemented an information security program based on best industry standards to protect your data.

3. Using advanced malware protection tools:

We use advanced malware protection tools to safeguard against malicious attacks and protect your data.

4. Applying reasonable security measures, including vulnerability management, access controls, and recovery/resilience protocols:

We implement reasonable security measures, including vulnerability management, access controls, and recovery/resilience protocols, to protect data and systems.

5. Security limitations notice:

However, no method of data transmission over the Internet or any wireless network is completely secure. Therefore, while we strive to protect your data, we cannot fully guarantee the security of any personal data you transmit to us, and you do so at your own risk.

We also do not guarantee the security of your devices, accounts, or personal data when using our Services. If you create an account with us and choose a password, you are solely responsible for keeping that password secure and confidential.

Divan Privacy Policy – Your Rights to Your Personal Data

Depending on the jurisdiction in which you reside, you may have the following rights concerning your personal data:

1.1 Access your personal data and information regarding its processing:

You have the right to access your personal data and information about how it is processed.

1.2 Request deletion or erasure of your personal data:

You can request the deletion or erasure of your personal data.

1.3 Request updates or corrections to your data:

You have the right to request updates or corrections to your personal data.

1.4 Request a copy of your data in a portable format (Data Portability):

You can request a copy of your personal data in a portable format.

1.5 Restrict or object to the way we process your personal data:

You may request restrictions or object to the way we process your personal data.

1.6 Withdraw previously given consent:

If you have previously provided consent for the processing of your personal data, you can withdraw it.

1.7 File a complaint with the data protection authority in your country:

You can file a complaint with the data protection authority in your country.

📌 Some of these rights may be exercised directly via your account on the Divan Services.

If you are unable to exercise them through your account, please contact us at:

📮 DPO@Flexinexa.com

We will review and respond to all data rights requests in accordance with applicable data protection laws.

Divan Privacy Policy – Updates and Changes

We may update this Privacy Policy from time to time in response to legal, regulatory, technical, or business developments.

✅ Any changes to this Privacy Policy will be communicated by updating the version available through our Services. The revised Privacy Policy becomes effective immediately upon update or on a specified effective date.

At our discretion, we may also provide notice of significant changes through channels such as email (to the email address in your account) or via notifications within the Divan platform before the changes take effect.

📌 To the extent permissible by law, you agree to be bound by the latest version of this Privacy Policy as updated from time to time. Please review this policy regularly to stay informed about how your personal data is being handled.

🕓 You can check when this Privacy Policy was last updated by referring to the “last updated” date shown at the top of this document.

Divan Privacy Policy – User & Organization Data Deletion

Divan provides both end-users and enterprise clients the ability to request account deletion and removal of their associated data at any time.

Users may initiate this process via their settings panel or by contacting our support team. The deletion process includes:

• Removal of personally identifiable information (PII) from active databases
  
  

• Deletion of stored conversations (upon request)
  
  

• Termination of access to all related services
  
  

For enterprise clients, Divan is committed to erasing relevant data within 30 business days of receiving a formal request, unless retention is legally required.

Divan Privacy Policy – Contacting the Data Protection Officer (DPO)

If you have any questions about this Privacy Policy, or if you have any complaints, inquiries, or requests concerning your personal data, you may contact our Data Protection Officer (DPO) via the following contact information:

📨 Attention: Data Protection Officer (DPO)
Company: Flexinexa (Divan Platform)
Address: [To be inserted: official registered address of Divan]
Email: DPO@Flexinexa.com

📌 Please note: If your personal data was submitted to us by a third party, you should contact them directly for any requests, feedback, or access/correction actions on your behalf.

📌 You may withdraw your consent at any time in accordance with applicable law. However, depending on the nature of your withdrawal, this may affect our ability to continue providing services to you, maintain existing contracts, or fulfill ongoing obligations. This may result in termination of your agreements or a breach of contract on your part. All legal rights of Divan remain expressly reserved.