Privacy Policy

Your Personal Information

What is Personal Information?

Personal Information is data that identifies, relates to, describes, or can be associated with you. It includes data that could be used to identify, locate, track, or contact you.

The Personal Information Diagon Collects and Sources

Payment Processing

Diagon does not process or store payment card information. Diagon uses Stripe as a payment processor to handle credit card payments and electronic funds transfers, including Automated Clearing House (ACH) payments.

How Diagon Uses Personal Information and Diagon's GDPR Legal Bases of Processing

• Our Purpose for Processing Personal Information
• Our GDPR Legal Basis
• Providing Diagon's products and services and managing your account with us.
• For Marketplace: Your consent. Our Website: Legitimate interest.
• Providing customer and technical support.
• Your consent; our legitimate interests.
• Communicating with you about your account and our services.
• Your consent; our legitimate interests.
• Provide our Movers & Makers Events.
• Your consent.
• Marketing and advertising our services (including direct marketing).
• Our legitimate interests.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Our legitimate interests.
• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy.
• Your consent.
• Debugging to identify and repair errors with our website, Marketplace, and services.
• Our legitimate interests.
• Comply with our legal obligations.
• Our legitimate interests.
• For other legitimate business purposes as permitted by law.
• Our legitimate interests.
• For other purposes when we have obtained your consent.
• Your consent.
• To create de-identified and aggregated Information. We will not seek to re-identify your personal information when we de-identify it. If we share de-identified information with third parties, we contractually require those third parties to refrain from seeking to re-identify data.
• Our legitimate interests.

Information We Collect Through Automatic Data Collection Technologies

Cookies and Online Tracking Technologies

Diagon uses cookies and tracking technologies to analyze website usage, estimate audience size, store preferences, and customize content.

When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email.

Third-Party Use of Cookies

Third parties (including social media companies) serve content and applications on Diagon's website and Marketplace. These parties may use cookies to collect information and associate it with personal data. They may use this information to provide interest-based advertising or targeted content. Diagon does not control third-party tracking practices.

Analytics

To understand how users and visitors use our website and Marketplace, we use analytics tools such as Google Analytics. Google Analytics uses cookies and pixels to help us understand how visitors use our website and to collect data on website activity.

Communication with You

Diagon may contact users about goods and services of interest. Marketing communications may be sent about services and relevant events.

How We Disclose Personal Information

Diagon does not sell personal information or share it with third parties for cross-contextual behavioral advertising. However, information may be disclosed to:

• Marketplace introduction: Agents share seller information with prospective buyers and buyer information with sellers
• Vendors and service providers: Companies and individuals assisting with business operations (website maintenance, email, document management, shipping, payment processing, security, marketing, customer relationships)
• Business transfers: In connection with mergers, consolidations, asset sales, bankruptcy, or corporate changes
• Legal requirements: When required by law, subpoena, legal process, national security, or law enforcement
• Rights protection: To protect rights, privacy, safety, property, employees, contractors, agents
• User consent: With explicit consent
• Fraud detection: When necessary to investigate fraud

Data Retention

We apply different retention periods depending on the type of Personal Information collected and the purposes for which we use it. We will keep your information for as long as is necessary to fulfill the purposes for which the information was collected.

Retention may extend when required by law, fraud prevention, or deceptive/illegal activity protection. Periods depend on information type and usage purposes.

How Diagon Protects and Secures Personal Information

We implement appropriate technical and organizational measures to help protect your information from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

Opting-Out of Marketing Communications from Diagon

Users may opt out of promotional communications via email, regular mail, or other methods by following unsubscribe instructions or contacting privacy@diagon.ai.

Do Not Track - Global Privacy Control

Our Website and Marketplace do not respond to Do Not Track requests, Global Privacy Control, or similar signals.

Data Transfers to the United States

Website

Diagon is US-based with servers in the United States. Users acknowledge that personal information will be transferred to the US and consent to that transfer. US privacy laws may be less stringent than users' home countries.

Marketplace

When creating a Marketplace account or when agents collect information, users are asked to consent to data collection, processing, and US transfer. If users do not consent to US transfer, they cannot use the Marketplace. Verbal consent is requested during phone, text, or video calls.

Data Subject Rights

Depending on location, users may have rights under privacy and data protection laws. Users may exercise rights by contacting privacy@diagon.ai. Rights are typically free; responses aim to meet legal timeframes.

Users have the right to:

• Access personal information
• Correct personal information
• Request deletion (subject to exceptions)
• Restrict processing (depending on legal basis)
• Object to processing when legal basis is legitimate interests
• Data portability (when processing is consent-based)

When requesting rights, users consent to having their request processed in the United States.

Additional Rights for U.S. Residents

California residents have the right to request categories of personal information collected or disclosed in the last 12 months, categories of sources, business/commercial purpose for collection, categories of third parties with whom information was shared, and specific pieces of personal information collected.

Identity Verification

Diagon must verify identity before processing rights requests. Additional personal information may be requested, requiring only the minimum necessary for verification.

Authorized Agent

Users may designate an authorized agent by providing written, signed permission and verifying identity directly with Diagon. Diagon accepts requests only with proof of authorization.

Appealing Requests

Users may appeal responses to rights requests by contacting privacy@diagon.ai.

Links to Other Websites

Diagon's website and Marketplace may contain links to third-party sites. Diagon does not control these sites and is not responsible for their privacy practices or content. Users should review third-party privacy statements.

Changes to this Privacy Policy

We may update portions of this Privacy Policy from time to time and will alert you that changes have been made by indicating the date it was last updated on the Privacy Policy.

Changes to Our Privacy Policy

Changes are posted on the Privacy Policy page. For Marketplace account holders, material changes to how user personal information is treated trigger email notification to the primary account email address. Users are responsible for maintaining current email addresses and periodically visiting the website and policy for updates.

Children Under the Age of 18

Our website, Marketplace, and services are not intended for children under 18. We do not knowingly collect Personal Information from children under 18.

If Diagon learns that personal information from a child under 18 without parental consent has been collected, it will be deleted. Contact privacy@diagon.ai if you believe Diagon has information from or about a child under 18.

Contact Information

For questions, comments, or complaints about this privacy policy and privacy practices, contact: privacy@diagon.ai