Privacy Policy

1. Introduction

DiCornerUSA.com (“DiCorner”), hereinafter referred to as ‘we’, ‘us’ or ‘our’, is governed by the rules notified under applicable data protection laws.

This Privacy Policy highlights our privacy practices regarding collection, use, and disclosure of ‘Personal Information’ when you use our services.

Please check our website regularly for updates to this policy.

‘Personal information’ means information or an opinion about an identified individual, or an individual who is reasonably identifiable.

DiCorner’s Privacy Policy applies to personal information collected and/or held by DiCorner.

2. The Types of Personal Information We Collect and Hold

2.1.1 Information Obtained for Interaction Purposes

We collect information you provide when interacting with our platform, including account creation, API usage, and support requests.

Why it matters: This allows us to deliver our cognitive behavioral intelligence services and provide customer support.

Policy: We only collect information necessary to fulfill our service obligations and legal requirements.

2.1.2 Non-Personal Information Linked with Existing Personal Information

We may combine non-personal usage data (e.g., event logs, API calls) with your account information to improve service quality.

Policy: Combined data is treated with the same privacy protections as personal information.

2.1.3 Personal Information Not Intended for Collection

We do not intentionally collect sensitive personal information such as race, gender, health data, or financial information beyond billing details.

Policy: If we inadvertently collect such data, it is immediately deleted.

2.1.4 Information Provided Over Platforms Outside Our Control

If you contact us via third-party platforms (e.g., email, social media), those platforms’ privacy policies also apply. We minimize use of third-party platforms and encourage direct contact via our secure channels.

3. How We Collect Personal Information

3.1.1 Information That You Specifically Give Us

Data you provide directly through forms, API registration, or account setup. Examples include account details (username, password), contact details (email, phone), location details (name, proof of identity), financial information (processed via secure third-party processors), and user-generated content (support tickets, feedback).

Policy: All directly provided data is encrypted in transit (TLS 1.2+) and at rest (AES-256).

3.1.2 Information We Collect from Others

Data we receive from third-party services you have authorized (e.g., OAuth logins, API integrations). This includes basic details from OAuth providers and contact details from CRM integrations.

Policy: We only request minimum necessary permissions and never access data beyond authorized scopes.

3.1.3 Information We Collect as You Use Our Platform

Automatic data collection from your use of DiCorner services, including metadata (timestamps, API endpoint usage, error logs), device information (browser type, OS), location (IP-based country/region), and actions (events sent to our API, cognitive scores requested).

Policy: This data is used solely for service delivery, security, and platform improvement. Not sold to third parties.

3.1.4 Links to Other Sites

Our website may contain links to third-party sites. We are not responsible for the privacy practices of those sites. We encourage you to read their privacy policies before providing any personal information.

4. How We Use Personal Information

The information we collect is primarily used to provide you with the product or service you have requested. Specific uses include: providing the service, facilitating user contracts, providing technical support, communicating updates, answering inquiries, providing information about our products and services, debugging and improving our platforms, conducting data analysis and research, and complying with legal and regulatory obligations.

Lawful Processing Grounds: Consent, contractual necessity, legal obligations, vital interests, and legitimate interests that do not infringe on your rights.

5. Automated Decision Making

We use automated decision-making when helping you match with behavioral insights. The primary way this occurs is through our cognitive scoring engine, which produces deterministic, reproducible scores.

Transparency: You can request an explanation of any automated decision by contacting our Data Protection Officer.

6. Sharing of Personal Information

We do not sell your personal information to third parties.

We may share your information with:

• Service providers: Cloud hosting, payment processors, analytics (under strict data processing agreements)
• Legal requirements: When required by law or to protect our rights
• Business transfers: In the event of a merger, acquisition, or asset sale (you will be notified)

Policy: All third-party processors are contractually required to meet GDPR and CCPA standards.

7. Data Retention

We retain your personal information only as long as necessary for the purposes outlined in this policy or as required by law.

Retention Periods:

• Account data: Until account deletion (or 90 days after inactivity)
• Behavioral event data: 90 days default (customizable for Enterprise clients up to 2 years)
• Billing records: 7 years (legal requirement)
• Audit logs: 7 years (compliance requirement)

8. Your Rights

Depending on your location, you may have the following rights:

GDPR Rights (EU)

• 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
• Right to withdraw consent

CCPA Rights (California)

• Right to know what personal information is collected
• Right to know if personal information is sold or disclosed
• Right to opt-out of the sale of personal information (we do not sell data)
• Right to deletion
• Right to non-discrimination for exercising CCPA rights

To exercise your rights, contact: emily@dicornerusa.com

9. Security

We implement industry-standard security measures:

• Encryption: TLS 1.2+ for data in transit, AES-256 for data at rest
• Access Control: Role-based access, multi-factor authentication
• Monitoring: 24/7 security monitoring, intrusion detection
• Audits: Regular security audits, penetration testing

Incident Response: We will notify you of any data breach within 72 hours of discovery.

10. Cookie Policy

Our website and platform use cookies and similar tracking technologies to enhance your experience, analyze usage, and deliver our services effectively.

Types of Cookies We Use

• Essential Cookies: Required for the platform to function properly. These include authentication tokens, session identifiers, and security cookies. These cannot be disabled.
• Analytics Cookies: Help us understand how you use our platform so we can improve the experience. These collect aggregated, anonymized data about page visits, feature usage, and performance metrics.
• Preference Cookies: Remember your settings and preferences (e.g., dashboard layout, notification preferences) to provide a personalized experience.

Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to block or delete cookies. Please note that disabling essential cookies may affect the functionality of our platform.

For more information about cookies and how to manage them, visit allaboutcookies.org.

11. International Data Transfers

DiCorner operates globally and your data may be transferred to and processed in countries other than your own. We ensure adequate protection through Standard Contractual Clauses (EU), Privacy Shield Framework (if applicable), and explicit consent for transfers.

12. Children’s Privacy

DiCorner does not knowingly collect personal information from children under 13 (or 16 in the EU). If we discover we have collected such information, it will be immediately deleted.

13. Contact Our Privacy Officer

Email: emily@dicornerusa.com

Subject Line: Privacy Inquiry

For purposes of the Privacy Act and GDPR, our Privacy Officer is also our Data Protection Officer.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email notification, prominent notice on our website, and in-app notification.

Last updated: December 11, 2023