Privacy Policy

Last updated: October 30, 2024

1. Introduction

Different ("we," "our," or "us") respects your privacy and is committed to protecting your personal data. This privacy policy describes how we collect, use, process, and protect your personal information when you use our Different platform (the "Service"), including our website www.different.ai and all related applications, features, and services.

This policy aims to provide you with clear information about how we handle your data and your privacy rights. Please read this policy carefully to understand our practices regarding your personal data.

2. Information We Collect

2.1 Personal Information

We collect several types of information that you provide directly to us, including:

  • Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.

  • Professional information, such as your work history, city, state, country of residence, postal code, age and links to your profiles on social networks.

  • Account data, such as the username and password that you may set to establish an online account on the Services, biographical details, preferences, and any other information that you add to your account profile.

  • Communications that we exchange with you, including when you contact us through the Services, social media, by phone or video platform or otherwise, and recordings of the same.

  • Transactional data, such as information relating to or needed to complete your orders on or through the Services, including order numbers and transaction history.

  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

  • Payment information needed to complete transactions, including payment card information or bank account number.

  • Promotional information, including information you share when you enter a competition, promotion or complete a survey. Please note that if you participate in a sweepstakes, contest or giveaway through the Service, we may ask you for your Contact Data to notify you if you win or not, to verify your identity and/or to send you prizes. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each sweepstakes and contest that you enter.

  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

2.2 Automatically Collected Information

Our systems automatically collect the following information when you use our Service:

  • Device Information: Operating system, device type, device ID, browser type and version, screen resolution, and IP address.

  • Log Data: Access times, pages viewed, features used, clicks and navigation paths, and other system activity.

  • Usage Information: Your interactions with our Service, including time spent, preferences, settings, and feature usage patterns.

  • Location Data: Approximate location derived from IP address and any precise location if you grant permission.

  • Performance Data: Error reports, debug information, and performance metrics.

2.3 Cookies and Similar Technologies

We use cookies, web beacons, pixels, and similar tracking technologies to:

  • Maintain your login session and preferences

  • Understand how you use our Service

  • Remember your settings and choices

  • Analyze and improve our Service performance

You have the right to opt out of the sale or sharing of your personal information, including via cookies and similar tracking technologies. You may do so by emailing privacy@different.ai or by adjusting your browser's cookie settings.

However, disabling certain cookies may limit your ability to use some features of our Service.

2.4 Third-Party Data Integration and Processing

2.4.1 Third-Party Data Sources

Our Service allows customers to import and process contact information and other business data from third-party data providers, including but not limited to:

  • Third-party business data providers

  • Customer Relationship Management (CRM) systems

  • Marketing automation platforms

  • Customer's own databases and systems

2.4.2 Data Processing Roles

  • We act as a Data Processor for any data imported by our customers from third-party sources

  • Our customers, as Data Controllers, are responsible for:

    • Ensuring they have proper rights and permissions to use imported data

    • Maintaining compliance with applicable data protection laws

    • Obtaining necessary consents for data processing

    • Honoring data subject rights requests for imported data

2.4.3 Third-Party Data Handling

When processing third-party data imported by our customers, we:

  • Process data only according to customer instructions

  • Maintain appropriate technical and organizational security measures

  • Do not independently verify or validate the accuracy or source of imported data

  • Do not claim ownership of imported data

  • Do not use imported data for our own purposes

  • Delete or return imported data as specified in our service agreement

3. How We Use Your Information

We use your information for the following purposes:

3.1 Service Provision and Improvement

  • Operate, maintain, and improve our Service

  • Process your transactions and fulfill your requests

  • Provide customer support and respond to inquiries

  • Debug and fix issues

  • Develop new features and services

3.2 Communication and Marketing

  • Send administrative messages, updates, and security alerts

  • Provide information about new features and services

  • Send marketing communications (with your consent where required)

  • Respond to your comments and questions

3.3 Security and Protection

  • Verify your identity and prevent fraud

  • Monitor and prevent security incidents

  • Enforce our terms of service

  • Protect our legal rights and comply with laws

3.4 Analysis and Optimization

  • Analyze usage patterns and trends

  • Conduct research and development

  • Optimize service performance and user experience

  • Generate aggregate, non-identifying analytics

4. Information Sharing and Disclosure

4.1 Service Providers

We share information with trusted third-party service providers who help us operate our business, such as:

  • Cloud hosting providers

  • Payment processors

  • Analytics services

  • Customer support tools

  • Email service providers

  • Security and fraud prevention services

These service providers are contractually bound to protect your information and can only use it for specified purposes.

4.2 Legal Requirements

We may disclose your information if required by law, regulation, legal process, or governmental request. We may also share information to:

  • Enforce our terms of service

  • Detect, prevent, or address fraud and security issues

  • Protect against harm to our rights, property, or safety, or that of our users or the public

4.3 Business Transfers

If we are involved in a merger, acquisition, or sale of all or part of our assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or use of your information.

5. Data Security

We implement appropriate technical and organizational measures to protect your data, including:

  • Encryption of data in transit and at rest

  • Access controls and authentication requirements

  • Regular security assessments and penetration testing

  • Employee training on security and privacy practices

  • Monitoring for suspicious activity

  • Secure data backup procedures

  • Incident response plans

While we strive to protect your information, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

6. Your Rights and Choices

You have the following rights regarding your personal information:

  • Access: Request a copy of your personal data

  • Correction: Request corrections to inaccurate data

  • Deletion: Request deletion of your data (subject to certain exceptions)

  • Objection: Object to processing of your data

  • Restriction: Request limits on how we use your data

  • Portability: Request a copy of your data in a structured, machine-readable format

  • Withdrawal of Consent: Withdraw previous consent for data processing

To exercise these rights, contact us at privacy@different.ai. We will verify any requests before acting on the request and respond to all requests. We will respond to your request within a reasonable timeframe in accordance with applicable data protection laws.

7. Children's Privacy

Our Service is not directed to children under the age of 18, and we do not knowingly collect personal information from children. If we learn that we have collected personal information from a child without parental consent, we will take steps to delete that information.

If you believe we may have collected information from a child, please contact us at privacy@different.ai.

8. International Data Transfers

We may transfer your information to countries other than your country of residence. When we do so, we implement appropriate safeguards, including:

  • Standard contractual clauses approved by relevant data protection authorities

  • Data processing agreements with strict privacy and security requirements

  • Privacy Shield certification (where applicable)

  • Adequate level determinations by relevant authorities

9. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of any material changes by:

  • Posting the updated policy on our website

  • Sending an email to registered users

  • Displaying a prominent notice in our Service

Your continued use of the Service after such modifications constitutes your acknowledgment of the modified Privacy Policy.

10. Contact Us

For questions about this Privacy Policy or our privacy practices, please contact:

Email: privacy@different.ai

Address: 11100 Santa Monica Blvd. Ste #600, Los Angeles, CA 90025

11. Jurisdiction-Specific Provisions

11.1 European Users (GDPR)

If you are in the European Economic Area (EEA), you have additional rights under the GDPR:

  • Legal Basis for Processing: We process your data based on:

    • Your consent

    • Contract performance

    • Legal obligations

    • Legitimate interests

  • Data Transfers: Data collected through our Platform is stored in the United States. When transferring personal data outside of the EEA, we implement appropriate safeguards to ensure data protection rights are upheld. These safeguards may include the use of Standard Contractual Clauses (SCCs) approved by the European Commission or other lawful mechanisms as required by the GDPR.

  • Data Subject Rights: Under the GDPR, you have the right to request access, correction, deletion, restriction, or portability of your personal data. You also have the right to object to processing based on legitimate interests. To exercise these rights, please contact us at privacy@different.ai.

11.2 California Residents (CCPA)

Under the California Consumer Privacy Act (CCPA), California residents have additional rights:

  • Right to Know: Request categories and specific pieces of personal information collected

  • Right to Delete: Request deletion of personal information

  • Right to Opt-Out: Opt-out of the sale of personal information

  • Right to Non-Discrimination: Exercise rights without discrimination

We have collected the following categories of personal information in the past 12 months and may continue to do so:

  • Identifiers, including real names, aliases, mailing addresses, unique personal IDs, online identifiers, IP addresses, email addresses, account names, and similar identifiers;

  • Personal Information, such as education, employment details, and job history;

  • Commercial Information, including transaction records, purchase details, financial data, and payment information;

  • Internet or electronic activity data, such as browsing history, search history, and user interactions with websites, apps, or ads; and

  • Inferences based on the above categories of Personal Data.