Privacy Policy

By accessing our website, you agree to this Privacy Policy. Please read the information below:

This Privacy Policy describes the types of information we may collect from you, or you may provide to us when you visit the Diverge website located at https://www.diverge.vc/. This Privacy Policy applies to information we collect through our website and does not apply to any information collected via third-party sites that may be accessed through hyperlinks.

This Privacy Policy only addresses the use and disclosure of information Diverge collects from you. Our website may have hyperlinks to other third-party websites that may collect and disclose information in a manner not consistent with this Diverge’s Privacy Policy, and such collection and disclosure would be governed by that third-party’s website privacy policy. Diverge is not responsible for the information collected through any third-party websites.

By using our website and or interacting, requesting and opting into our content and information, you are agreeing to:

• The use of cookies, tracking pixels and similar technologies.
• The transfer of your data to the EEA, United States and countries that have received an adequacy determination by the European Commission under Article 45 of Regulation (EU) 2016/679.
• The processing of your data as described in this Privacy Policy.
• The use of e-mail notifications and subscriptions as a primary source of communication between you and Diverge.

INFORMATION WE COLLECT:

Diverge will never share your personal information with partners for their direct marketing purposes. Diverge collects data in the following circumstances:

Website Users:

When you use our website, Diverge and our partners may use a variety of technologies that collect information and data about your interactions with our site. This information may include cookies, tracking pixels and similar technologies. We use this data internally to enhance your user experience. We sometimes have partners that use these technologies to provide us with analytic services as well as optimize your online experience. Information collected could include your IP address, browser type, the server your computer is logged onto, the area code and zip code of your server and whether you responded to a particular piece of content. We may use vendors who use cookies to inform, optimize and serve ads based on your visits to our website.

Email Marketing:

When you subscribe to receive updates and/or information from Diverge, the information you submit is collected and stored by Diverge. These emails contain information that you have requested to receive. We may use Multipurpose Internet Mail Extensions in our marketing emails so we may understand the effectiveness of our content and your level of interest in our services and marketing efforts.

Users may unsubscribe from the Diverge mailing list at any time by navigating to the “Unsubscribe” link within these emails.

INFORMATION WE SHARE:

Diverge will never rent, sell or otherwise disclose your personal information to third parties for their direct marketing purposes. We may share your personal information only as follows:

• To third parties with your consent.
• To comply with any valid court order, law or legal process.
• In response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
• To enforce our agreements with you, including for billing/collection purposes.
• If we believe disclosure is necessary to prevent any harm or financial loss, or in connection with an investigation of fraudulent or illegal activity.

WHERE WE STORE YOUR DATA:

The data we collect is transferred to and stored at a destination outside the European Economic Area (“EEA”). It may be processed by staff operating outside the EEA who work for Diverge or by one of our service providers. Your information is maintained in servers located in the United States, and your data is processed by our team members within the United States.

Data handled by our service providers is maintained in the United States. Our team members may, on occasion, process personal data through a dedicated and encrypted connection to this data. By submitting your personal data, you agree to this transfer, storing and handling as noted in this Privacy Policy. Diverge will take all reasonable steps necessary to keep your data secure and in accordance with this Privacy Policy.

We retain personal data from subscribers for ten years from the date of last access or the end of subscription period, whichever is later, unless such data must be retained for the establishment, exercise, or defense of legal claims.

YOUR DATA RIGHTS:

You can unsubscribe from Diverge’s email updates by following the unsubscribe instructions included in the email you receive. Only Diverge will send you these emails. You may ‘unsubscribe’ from these messages, after which you will no longer receive them. We do not send unsolicited commercial emails or spam.

Diverge understands that EU and Swiss individuals have the right to access their personal information we maintain. An individual who wishes to correct, amend or delete data should direct their request to dataprivacy@henselphelps.com.

Unfortunately, no data transmission can be guaranteed secure. By using the Diverge website, you acknowledge:

• There are security and privacy limitations that are beyond Diverge’s control.
• The security, integrity and privacy of any information exchanged between you and Diverge through the website cannot be guaranteed and Diverge shall have no liability to you or any third party.
• Any information and data could be viewed or tampered with by a third party.

SPECIAL NOTICES: 

Special Notice to California Residents:

If you are a California resident and have provided Diverge with any Personally Identifiable Information (PII), California law gives you the right to request and receive from us, once per calendar year, information as to how we have shared your PII with third parties for their direct marketing purposes. However, as stated in this Policy, we do not share information with third parties for their direct marketing purposes.

Special Notice to EU Residents:

Diverge is subject to the investigatory and enforcement authority of the United States Federal Trade Commission. Diverge is obliged to disclose personal data pursuant to lawful requests.

Diverge commits to resolve complaints about our collection and use of your personal data. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Diverge at:

Hensel Phelps
Attn: Data Privacy
420 6th Ave
Greeley, CO 80631
970-352-6565
dataprivacy@henselphelps.com

CHANGES TO THIS PRIVACY POLICY:

Any revisions to the Diverge’s Privacy Policy will be posted directly to this webpage. The effective date of our Privacy Policy version is identified here: Privacy Policy last updated 9/1/18.

Your continued use of the Diverge website after any modifications will constitute your acknowledgment and agreement to the terms of the updated Privacy Policy.