Terms of Service

1. Purpose

Your privacy is important to us. We believe you should always know what data we collect from you and how we use it, and that you should have meaningful control over both. This Privacy Policy explains how information about you is collected, used and disclosed by Diwala AS. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your Personal Information, as defined below.

Diwala AS ("us", "we", or "our") operates the https://diwala.io/ website, the Diwala mobile application and the Diwala web app, https://cert.diwala.io/, all under (“the Service”). All applicable to all clients as stated in this section.

Diwala is the data controller, as defined by article 4, nr. 7 of the General Data Protection Regulation ("GDPR"). The GDPR has been implemented into Norwegian law through the Personal Data Act (LOV-2018-06-15-38).

2. Data Protection Officer

Diwala AS is headquartered in Norway. Diwala AS have not appointed an internal data protection officer as our processing is not of a type or scale that requires one. However, should you have any questions or concerns about Diwala AS' personal data policies or practices; you can reach out to us at the following address:

Diwala AS

Herslebs Gate 23

Oslo, 0561

Norway

Email: privacy@diwala.io

Company Number: 920 180 485

We always respond to data enquiries and will investigate or clarify any requests. If there are any questions we encourage you to get in touch with us, so we can respond accordingly.

3. How we collect and use your personal information

Personal information you give to us

Registered Users – Users

As a registered user we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to: 

Email address 

First name and last name 

Address, State, Province, ZIP/Postal code, City 

Cookies and Usage Data

We process your Personal Data under the General Data Protection Regulations Article (6)(b) to provide you with administration and identity management that you have requested. We will also process this information to undertake standard business functions such to inform you of relevant events, content, and other benefits or related opportunities. Diwala AS may also process this information under the General Data Protection Regulations Article (6)(f) to help us understand our customers’ needs and interests, to better tailor our products and services to meet those needs.


All users - analytics

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device or a browser ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. 

When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data

We process your Usage Date under the General Data Protection Regulations Article (6)(b) to provide you with administration and identity management that you have requested. We will also process this information to undertake standard business functions such to inform you of relevant events, content, and other benefits or related opportunities. Diwala AS may also process this information under the General Data Protection Regulations Article (6)(f) to help us understand our customers’ needs and interests, to better tailor our products and services to meet those needs

All users - Tracking & Cookies Data 

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. 

Examples of Cookies we use:

Session Cookies. We use Session Cookies to operate our Service. 

Security Cookies. We use Security Cookies for security purposes.

4. Personal information from third parties

Diwala AS does not receive Personal Data about individuals from third parties. Diwala receive contact information from tutoring entities, as they try to onboard students to their courses.

Diwala AS can receive or request Personal Data with your consent through the decentralised identity wallet you use to access our service.

5. Sharing information with others

Registered Users

When you register with Diwala we create an account for you and store your data in one of our European based servers. When you are signed up for a course, this too is processed and maintained in association with your account in one of our European based servers. When you receive a certificate, this is NOT stored in our European based servers, because that data belong to you. But it is processed and sent through our European based servers. We will process information about what courses you attend, what skills you acquire and statistics about your usage to provide a better service to you.

We do not share any information outside of the Diwala ecosystem, being the Diwala app, the Diwala certification administration page, unless you decide to share yourself using your decentralised identity or provided links that makes your information available.

All users

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside Norway and choose to provide information to us, please note that we transfer the data, including Personal Data, to Norway and process it there. 

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. 

Diwala AS will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

6. Security of your information

To help protect the privacy of data and personally identifiable information you transmit through use of this Site, we maintain a range of physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees and clients who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

7. Data storage and retention

The Personal Data we collect is stored by Diwala AS on its servers located in Europe, and Usage Data is stored on the analytics servers (Intercom, Google Analytics) that we engage, located in the United States. They have the right privacy shield policies in place for us to be allowed to use. Diwala AS retains data for the duration of the users or business relationship with us. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact our privacy officer at privacy@diwala.io.

Rights of Access, Amendment, Deletion, and Restriction

You may inquire as to whether Diwala are processing your personal Information, request access to your personal information, and ask that Diwala correct, amend, or delete your personal information where it is inaccurate.

Requests can be sent via an e-mail to privacy@diwala.io or use any of the methods set out in this policy to request access to information held about you by Diwala, restrict the processing of your information, seek amendment of your information, or request the deletion of personal information held about you by Diwala.

All efforts to provide individuals with access to their personal information are made in good faith, however, there may be circumstances in which Diwala is unable to provide access, these circumstances include, but not limited to, where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If Diwala determines that access should be restricted in any instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Diwala will take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information.

8. Children and minors

Diwala AS is not at all directed towards individuals under the age of eighteen (18), however we are aware due to the nature of some of courses arranged around the world, those between 16 and 18 may use the Services. Individuals under the age of thirteen (13) are expressly prohibited from using Diwala, unless parental consent is provided, and we are notified.

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

9. Changes and updates to the Privacy Notice

By using this Site, you agree to the terms and conditions contained in this Privacy Notice and Conditions of Use and/or any other agreement that we might have with you. If you do not agree to any of these terms and conditions, you should not use this Site or any Diwala AS services. You agree that any dispute over privacy or the terms contained in this Privacy Notice and Conditions of Use, or any other agreement we have with you, will be governed by the laws of Norway.

As our business changes from time to time, this Privacy Notice and Conditions of Use are expected to change as well. We reserve the right to amend the Privacy Notice and Conditions of Use at any time, for any reason, without notice to you, other than the posting of the amended Privacy Notice and Conditions of Use at this Site. Unless the change demands a request to accept. 

We may email periodic reminders of our notices and terms and conditions and will email customers of material changes thereto, but you should check our Site frequently to see the current Privacy Notice and Conditions of Use that is in effect and any changes that may have been made to it. The provisions contained herein supersede all previous notices or statements regarding our privacy practices and the terms and conditions that govern the use of this Site.

10. Desktop, Mobile and Application

Note that this privacy policy is applicable to Diwala AS across all devices including Desktop, the mobile site and the Diwala Mobile App.

11. Questions, concerns or complaints

Please contact us at the address below:

Diwala AS

Herslebs Gate 23

Oslo, 0561

Norway

Email: privacy@diwala.io

Norwegian Company Number: 920 180 485