Our Privacy Policy

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At DIGEN, we are committed to maintaining robust privacy protections for our customers, users and website visitors. This notice summarizes how we collect, use and safeguard the information you provide to us and what choices you have with respect to your privacy.

This notice applies to the data processing of DIGEN OÜ, and its relevant Affiliates (as specified below) in relation to the DIGEN Services and the DIGEN websites (such as digen.ai). This notice does not to any third-party applications or software integrated with the Services ("Third-Party Services"), or to the privacy practices of any other third-party products, services or businesses. Unless defined otherwise, capitalized terms in this notice will have the same meaning as in the Terms of Service.

1 What type of personal data do we process?

1.1 Information that you provide to us, including when you register and communicate with us directly

1.1.1 Registration data: When you register to our Services, you need to provide us with your email address, password and username. The data that we request at the time of registration is necessary for the provision of our Services.

1.1.2 Billing information: If you subscribe to a paid Service, you also need to provide certain billing information (such as your name, address and VAT number). You might also provide payment information, such as payment card details, which we collect via a secure payment processing service, Stripe Inc. This data is necessary to provide you with the DIGEN Services.

1.1.3 Additional data provided by you: You may decide to share further information, including personal data, with us when you contact us, provide feedback to us regarding the Services or otherwise communicate with us. It is solely your decision to share any other data with us during such communications, so our processing of such data will be based on your consent.

1.2 Content that you upload to our Services

1.2.1 If you decide to get a Custom Avatar and your Service Plan allows it, you may upload CustomerMaterials including personal data (such as your voice or picture).

1.3 Information that we collect about you when you use our Services, including technical information about your interactions

1.3.1 Logs: As most websites and services provided through the Internet, we gather certain information and store it in log files when you interact with our Services. This information includes internet protocol (IP)address, as well as browser type and online identifiers.

1.3.2 Data on how you use DIGEN: When you visit our websites or Services, we collect information about your URL clickstreams (the path you take through our site), products/services viewed, how and how often certain functions are used, etc.

1.4 Information that we collect about you when you visit our websites

1.4.1 Cookie information: When you access our websites and Services, we use cookies and other information gathering technologies for a variety of purposes. These technologies may provide us with personal data, information about devices and networks you utilize to access our website, and other information regarding your interactions. For detailed information about the use of cookies, please see our Cookie Notice.

1.5 Information that we collect from third-parties

Our partners: We receive information about you and your activities on our website from third-party partners, such as advertising partners. Upon your consent, such partners provide us with information about your engagement with our website and online advertisements. If you want to learn more, please see section about “Why and how do we use cookies?”.

2 Why do we process your data?

We may process your personal data for several purposes. How we use your personal data depends on your on how you use the DIGEN Services and your preferences you have communicated to us.

2.1 Services: We will use some of your personal data for the provision and maintenance of your account, and for authentication purposes. E.g. We use your email address to enable you to login to our Services.

2.2 Billing: We will process certain information, such as financial data for billing purposes, i.e. to complete transactions, and send you purchase confirmations and invoices.

2.3 Communication: We will send you information regarding the Services, such as administrative messages, to your email address provided to us. Please be aware that you cannot opt out of receiving certain service messages from us, including necessary security alerts and legal notices.

2.4 Customer support: If needed, we may connect personal information to information gathered in our log files as necessary to provide better customer experience and to improve our services.

2.5 Developing Services: We use analytics to better understand the behavior of our users to grow our business. For this purpose, we collect certain information, such as how often our Services are used, and the events that occur while using our websites. We use this aggregate information to identify usage patterns and trends.

2.6 Marketing: Upon your consent, we may use your email address to send you marketing communications. In order to understand how our users interacts with our Services, and to measure and understand how well an online marketing or email campaign performed, we perform analyses.

2.7 Security: We use information about you to secure your profile, verify accounts, to monitor suspicious or fraudulent activity and to identify violations of our Terms of Service or Acceptable Use Policy.

2.8 Protecting our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of our business.

2.9 Other: We may also process your data for any other purposes for which we obtain your consent where necessary or otherwise in accordance applicable law and this policy.

3 What is the legal basis of our data processing? (for EEA users)

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. This means we collect and use your information only where:

3.1 It is necessary in order to provide you the Services, including to set up and maintain an account for you, to provide customer support;

3.2 It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, and to protect our legal rights and interests;

3.3 You give us consent to do so for a specific purpose;

3.4 It is needed to comply with a legal obligation.

4 How do you use your personal data?

In connection with certain Service Plans, you may decide to upload Customer Materials used in your CustomerCreated Videos that may include personal data (such as your voice or picture). Please remember that if you useour Service to share your Customer Created Videos with someone, your personal data might be shared with such third party.If your account is part of a business plan, our Services are provided to your organization, the ultimate decisions regarding your personal data will be made by your company that qualifies as “Customer”. In such case, your company will be considered as a controller and DIGEN will act as a processor, acting upon the instructions of such organization.

5 How long will we process your data?

We will retain your personal data as long as it is needed to fulfill the purposes specified above (for example, to provide you with our Services), unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it in accordance with our deletion policy.

6 Do we share your data with third parties?

We never sell your personal data to third parties. However, in certain cases we need to share your personal data with our Affiliates and third parties. In any case, we will share your personal data only in accordance with applicable laws and this notice, and in the following cases:

6.1 Legal compliance: We may transmit personal data if the applicable legal provisions so require, or when such action is necessary to comply with any laws, e.g. with criminal authorities if we are required to cooperate for such purposes. We may also need to share personal data for the protection of our right sand interests, to protect your safety or the safety of others or to investigate fraud, in accordance with the applicable laws.

6.2 Third-party service providers: In certain cases, we use DIGEN affiliates and third parties as service providers or business partners to process personal data and support our business. These services may help us keep DIGEN running by storing or processing your data on our behalf. We use third-party service providers to assist in providing the DIGEN services, for example to provide infrastructure, or to provide technologies integrated with our services, and to help us provide customer support and email notifications. We may also contract with companies to provide certain services, such as authentication, analytics, and marketing services. If you purchase through our website, your payment and subscription information will be processed by Stripe Inc, a payment processing service, in accordance with its PrivacyPolicy.

We may share your data with professional advisers acting as service providers, processors, controllers, or joint controllers - including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your data.

7 Data transfers

Our website and Services are hosted in the United States. If you access our website or Services from any other region of the world with laws or other requirements governing personal data collection, use, or disclosure that differ from applicable laws in the United States, then through your continued use of our sites and Services, you are transferring your data to the United States, and you agree to have your data transferred to and processed in the United States.

8 How do we protect your data?

We implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password. You should never disclose your password to others and it is recommended that you log out of your account after each use. We also protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Service, you acknowledge that you understand and agree to assume these risks.

9 Your privacy rights

You may ask us to:

9.1 provide information to you about the personal data that we or our processors process about you,

9.2 correct inaccuracies or amend your personal data,

9.3 stop processing your personal data and/or to stop sending you marketing communications,

9.4 delete your personal data.

If you are from a country where the EU GDPR applies, you may have additional rights such as:

9.5 In certain circumstances, you may have a broader right to erasure of your personal data. For example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.

9.6 You may have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is inaccurate or unlawfully held).

9.7 In certain circumstances, you may have the right to be provided with your personal data in a structured, machine readable and commonly used format and to request that we transfer the personal data to another data controller without hindrance.

You can request this by send an email to [email protected]. We will respond to your request within thirty calendar days. Please note that, we may ask you to verify your identity before complying with the request.

You also have the right to complain to a data protection authority or claim damages before the court if necessary. A list of contact details for the EU data protection authorities is available here.

10 Children’s privacy

Our Site and the Service are not directed to anyone under the age of 13. The Site does not knowingly collect or solicit information from anyone under the age of 13, or allow anyone under the age of 13 to sign up for theService. In the event that we learn that we have gathered information from anyone under the age of 13without the consent of a parent or guardian, we will delete that information as soon as possible. If you believe we have collected such information, please contact us at [email protected].

11 Changes

We reserve the right to change this notice from time to time. If there are any material changes to this policy, you will be notified by sending a notice to the primary email address specified in your account or by placing a prominent notice on our site. Any material changes will go into effect 30 days following such notification. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of our website or our Services constitutes your agreement to be bound by such changes to this notice. Your only remedy, if you do not accept the terms of notice, is to discontinue use of our Website andServices.

12 Any further questions?

If you have any further questions in relation to the processing of your data, please contact support@digen.ai.


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