Privacy Policy

At Dvina Inc. ("Dvina"), we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use, and share your information as described in this Privacy Policy.

Remember that your use of Dvina's Services is at all times subject to our Terms of Service. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.

If you have a disability, you may access this Privacy Policy in an alternative format by contacting hi@dvina.ai.

Privacy Policy Table of Contents

• What this Privacy Policy Covers
• Personal Data
• Categories of Personal Data We Collect
• Categories of Sources of Personal Data
• Our Commercial or Business Purposes for Collecting Personal Data
• How We Share Your Personal Data
• Tracking Tools and Opt-Out
• Data Security and Retention
• Personal Data of Children
• Other Jurisdiction-Specific Privacy Rights
• Changes to this Privacy Policy
• Contact Information

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don't own or control or people we don't manage.

Categories of Personal Data We Collect

This list details the categories of Personal Data that we collect and have collected over the past 12 months:

• Profile or Contact Data
  • First and last name
  • Email
• Payment Data
  • Payment card type
  • Last 4 digits of payment card
  • Billing address, phone number, and email
• Device/IP Data
  • IP address
  • Device ID
  • Domain server
  • Type of device/operating system/browser used to access the Services
• Web Analytics
  • Web page interactions
  • Referring webpage/source through which you accessed the Services
  • Non-identifiable request IDs
  • Statistics associated with the interaction between device or browser and the Services
• Social Network Data
  • Email
  • Public profile name
  • IP address
  • Device ID
• AI Conversation and Interaction Data
  • Chat transcripts and user prompts
  • Documents and files uploaded for analysis
  • Voice data (temporarily processed for instant transcription)
  • Privacy Safeguards
  • Encryption in Transit: All conversation and interaction data is encrypted in transit.
  • Automatic PII Masking: Our systems automatically detect and mask common personal and sensitive identifiers (email addresses, payment card numbers, phone numbers, IBANs, national ID and passport numbers, IP addresses, and API keys and other credentials) before they are processed by AI models. Masking is on by default, and you can turn it off for an individual chat. Other content, such as names and free text, may be processed by the AI models to provide the Services, within our isolated Microsoft Azure environment.
  • No Training: We do not use your conversation data or documents to train our models or those of third-party providers. Our Services are powered by Microsoft Azure AI services (including Azure OpenAI and other foundational models), which provide enterprise-grade guarantees that customer data (prompts, completions, and training data) is not used to train or improve any base models. Your data remains isolated within our secure Microsoft Azure environment and is not shared with public AI services. For official verification, you may refer to:
    • Microsoft Azure AI Data Privacy and Security
    • Microsoft Trust Center
    • Microsoft Data Protection Addendum (DPA)
• Other Identifying Information that You Voluntarily Choose to Provide
  • Identifying information in emails or letters you send us

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You

• When you provide such information directly to us.
• When you create an account or use our interactive tools and Services.
• When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
• When you send us an email or otherwise contact us.
• When you use the Services and such information (like IP address) is collected automatically for security and session management.
• Through Cookies (as defined and described further below).
• If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

Third Parties

• Vendors: We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.

Our Commercial or Business Purposes for Collecting Personal Data

Providing, Customizing, and Improving the Services

• Creating and managing your account or other user profiles.
• Processing orders or other transactions; billing.
• Providing you with the products, services, or information you request.
• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Services.
• Improving the Services, including testing, research, internal analytics, and product development (Conversation data is only used for session-based reasoning and is not used for model training).
• Personalizing the Services, website content, and communications based on your preferences.
• Doing fraud protection, security, and debugging.
• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.

Service Updates

• Communicating product updates, new features, and relevant information about your use of the Services.

Corresponding with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Dvina or the Services.
• Sending emails and other communications according to your preferences or that display content that we think will interest you.

Meeting Legal Requirements and Enforcing Legal Terms

• Fulfilling our legal obligations under applicable law, regulation, court order, or other legal process, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property, or safety of you, Dvina, or another party.
• Enforcing any agreements with you.
• Responding to claims that any posting or other content violates third-party rights.
• Resolving disputes.

How We Share Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section.

Service Providers

These parties help us provide the Services or perform business functions on our behalf. They include:

• Hosting, technology, and communication providers (primarily Microsoft Azure).
• AI Model and Speech Processing providers (Microsoft Azure AI services) who receive interaction data, with common personal and sensitive identifiers masked unless you turn masking off for a chat.
• Network security, DDoS protection, and traffic routing providers (Cloudflare), who process IP addresses and request metadata. Cloudflare also stores uploaded files and encrypted backups in its EU jurisdiction and runs the isolated environments in which the assistant executes code on your behalf.
• Push notification delivery providers (Firebase Cloud Messaging by Google), who receive only a device token and the notification content.
• Our email delivery provider (Amazon Simple Email Service, in the United States), which receives your email address and the content of account and service emails such as sign-in codes.
• Security and fraud prevention consultants.
• Analytics providers (Amplitude, in its EU data center).
• Support and customer service vendors.
• Product fulfillment and delivery providers.
• Payment processors (Stripe, RevenueCat).

Integration Partners

These parties provide the tools you choose to connect to your workspace. They include:

• Third-party applications or services you authorize.
• Integration platforms that facilitate your data workflows within Dvina (Composio), including web search and connected-app integrations, acting on your instructions.

Parties You Authorize, Access, or Authenticate

• Third parties you access through the services.
• Social media services.
• Other users.

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under "Meeting Legal Requirements and Enforcing Legal Terms" in the "Our Commercial or Business Purposes for Collecting Personal Data" section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified, or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified, or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Tracking Tools and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, "Cookies") to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base, and operate and improve our Services. Cookies are small pieces of data—usually text files—placed on your computer, tablet, phone, or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support "Do Not Track" requests sent from a browser at this time.

We use the following types of Cookies:

Essential Cookies

Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.

Functional Cookies

Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time, and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).

Performance/Analytical Cookies

Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services, and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services' content for those who engage with our advertising.

Usage Analytics in the Dvina Apps

The Dvina apps (the web app and the desktop and mobile apps) count how they are used with Amplitude, in its EU data center. They use a pseudonymous identifier, never your name, email or message content, and nothing is used for advertising. Amplitude derives an approximate location (such as country and city) from the IP address of each request. Purchases made through the App Store or Google Play are also counted in Amplitude under the same pseudonymous identifier, sent by our payment processor RevenueCat. Analytics is on in the apps unless you switch it off, which you can do at any time in Settings › Privacy. Our website counts nothing until you accept its cookie notice.

Error and Performance Monitoring

The Dvina apps report errors and performance measurements, such as load times and failed requests, so that we can keep the Services reliable. These reports are linked only to your account and workspace identifiers: email addresses are masked, page addresses are recorded without their query parameters or fragments, your IP address is not stored, and there is no session recording or click tracking. This data stays in our own infrastructure and is kept for 30 days.

You can decide whether or not to accept Cookies through your internet browser's settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website, and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the "preferences" or "options" section of your browser's menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit allaboutcookies.org.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use, and disclosure using appropriate physical, technical, organizational, and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. When you delete a chat or a document within the Services, it is removed from our production systems according to your workspace's trash and retention settings. When you delete your account or workspace, it is permanently purged 30 days after your request. Deleted data leaves our encrypted backups within a further 35 days.

In some cases, we retain Personal Data for longer if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us with Personal Information, please contact us at hi@dvina.ai.

Jurisdiction-Specific Privacy Rights

California Resident Rights

If you are a California resident, you have the rights outlined in this section. Please see the "Exercising Your Rights" section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers' end users or employees in connection with our provision of services to customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at hi@dvina.ai.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. We will provide you with the following information:

• The categories of Personal Data that we have collected about you.
• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting or selling your Personal Data.
• The categories of third parties with whom we have shared your Personal Data.
• The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected from you. Under the California Consumer Privacy Act (CCPA), this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your Rights

To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a "Valid Request." We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

• Email us at: hi@dvina.ai

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties' direct marketing purposes; in order to submit such a request, please contact us at hi@dvina.ai.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at hi@dvina.ai with the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

European Union Data Subject Rights

EU Residents

If you are a resident of the European Union ("EU"), United Kingdom, Liechtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the "GDPR") with respect to your Personal Data, as outlined below.

For this section, we use the terms "Personal Data" and "processing" as they are defined in the GDPR, but "Personal Data" generally means information that can be used to individually identify a person, and "processing" generally covers actions that can be performed in connection with data such as collection, use, storage, and disclosure. Dvina will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at hi@dvina.ai. Note that we may also process Personal Data of our customers' end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

Personal Data We Collect

The "Categories of Personal Data We Collect" section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The "Our Commercial or Business Purposes for Collecting Personal Data" section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity, and our "legitimate interests" or the legitimate interest of others, as further described below.

Contractual Necessity

We process the following categories of Personal Data as a matter of "contractual necessity," meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data. Examples include:

• Profile or Contact Data
• Web Analytics or other similar network activity information
• Payment Data
• Social Network Data
• Device Data
• Other Identifying Information that You Voluntarily Choose to Provide

Legitimate Interest

We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties. We may also de-identify or anonymize Personal Data to further our legitimate interests. Examples of these legitimate interests include:

• Providing, customizing, and improving the Services.
• Marketing the Services.
• Corresponding with you.
• Meeting legal requirements and enforcing legal terms.
• Completing corporate transactions.

Consent

In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Other Processing Grounds

From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Sharing Personal Data

The "How We Share Your Personal Data" section above details how we share your Personal Data with third parties.

EU Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at hi@dvina.ai.

Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

Access

You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.

Rectification

If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account.

Erasure

You can request that we erase some or all of your Personal Data from our systems.

Withdrawal of Consent

If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

Portability

You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

Objection

You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.

Restriction of Processing

You can ask us to restrict further processing of your Personal Data.

Right to File Complaint

You have the right to lodge a complaint about Dvina's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data

The Services are hosted on Microsoft Azure infrastructure in GDPR-compliant regions of the European Union. While Dvina Inc. is headquartered in the United States, your conversations, files and workspace data are stored and processed in the European Union.

Some Personal Data is transferred outside the European Union where a service provider listed in "How We Share Your Personal Data" operates there, for example for account emails and payments. These transfers are protected by:

• the standard contractual clauses adopted by the European Commission (Implementing Decision (EU) 2021/914), available at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj, and
• where the recipient is certified, the EU-U.S. Data Privacy Framework.

We ensure that all data transfers comply with applicable data protection laws and that appropriate safeguards are in place to protect your Personal Data.

Changes to this Privacy Policy

We're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Dvina website, by sending you an email, and/or by some other means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

Email: hi@dvina.ai

Address: Dvina Inc., 2261 Market Street, San Francisco, CA 94114, United States