PRIVACY POLICY

Version Release Date: January 01, 2025 Notice Version: 2.0

Data Controller Contact Information

DEMAVIAS, LLC
1007 N Orange street
4th floor, #91
DE-10981-Wilmington
Delaware, USA

Privacy Policy for DEMAVIAS, LLC d/b/a Di-Atomic.com Version: 2.0 Effective Date: January 1, 2025
DEMAVIAS, LLC, a Delaware limited liability company doing business as Di-Atomic.com (the "Company," "we," "us," or "our"), respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you access or use our B2B Lead Generation and Campaign Automation Platform (the "Services"), as described in our Terms of Service (Version 2.0). By using the Services, you consent to the practices described herein. This Policy incorporates by reference the Terms of Service and applies to all users ("you" or "your").
If you do not agree with this Privacy Policy, do not access or use the Services. Capitalized terms not defined here have the meanings given in the Terms of Service.

1. Information We Collect
We collect information in the following categories:

• User-Provided Information: When you create an account, subscribe, or use the Services, you may provide us with:
• Contact details (e.g., name, email, company name, billing address).
• User Content, such as product descriptions, target languages, or other inputs for processing (e.g., for AI enrichment or ICP generation).
• Payment information (processed via third-party providers; we do not store full card details).
• Automatically Collected Information: As you interact with the Services, we may collect:
• Usage data (e.g., IP address, browser type, device identifiers, pages viewed, time spent).
• Log data (e.g., access times, errors).
• Cookies and similar technologies for analytics and functionality (you can manage preferences via browser settings).
• Processed Data from Services: Through automated workflows (e.g., n8n-based), we may generate or process:
• Enriched marketing content (e.g., product descriptions, key benefits).
• ICP data (e.g., industry segments, job titles, SIC codes).
• Prospect and contact data (e.g., company names, emails, phone numbers from third-party sources like Apollo.io or Google Maps API). This may include Personal Data of third parties (e.g., business contacts) that you instruct us to process.

We do not intentionally collect sensitive Personal Data (e.g., health, racial, or biometric data) unless provided by you, and we advise against submitting such data.

2. How We Use Your Information
We use information to provide and improve the Services, including:

• Processing User Content through AI models (e.g., OpenAI GPT-4 for content enrichment, Claude for ICP analysis) to generate Outputs like marketing collateral, email sequences, and contact lists.
• Orchestrating workflows (e.g., via Airtable) for prospect discovery, email validation (EmailListVerify), and campaign exports (e.g., to SmartLead).
• Billing, account management, and customer support.
• Analytics to monitor usage and enhance performance.
• Compliance with legal obligations (e.g., responding to subpoenas).

For Personal Data in prospect databases, we act as a data processor under your instructions (e.g., for GDPR purposes). You are responsible for establishing a legal basis (e.g., legitimate interest) for such processing.

3. Sharing and Disclosure of Information
We may share information as follows:

• Service Providers: With third-party vendors for operations (e.g., OpenAI/Anthropic for AI, Apollo.io for enrichment, Firecrawl for scraping, SmartLead for campaigns). These providers are bound by data processing agreements (DPAs) and process data only as instructed.
• Business Transfers: In connection with mergers, acquisitions, or asset sales (subject to confidentiality).
• Legal Requirements: To comply with laws, respond to authorities, or protect rights (e.g., fraud prevention).
• Aggregated Data: Non-personal, anonymized data for analytics or marketing.

We do not sell Personal Data. For GDPR/CCPA purposes, sharing with processors is not a "sale."

4. Data Retention
We retain information as needed for the Services and legal compliance:

• Account and User Content: While your account is active, plus 2 years post-termination.
• Generated Outputs (e.g., ICPs, campaigns): Indefinite for business records, unless you request deletion.
• Prospect/Contact Data: 2 years for inactive records; up to 5 years for engaged ones.
• Logs/Usage Data: Up to 90 days for tasks; longer for analytics.

Data is deleted securely upon expiration or your valid request, subject to backups (retained up to 30 days).

5. Data Security
We implement reasonable administrative, technical, and physical safeguards (e.g., encryption, access controls) to protect information. However, no system is impenetrable, and we cannot guarantee absolute security. You are responsible for securing your account and verifying Outputs before use. Report suspected breaches to [insert contact email] immediately.

6. Your Rights and Choices
Depending on your location (e.g., GDPR for EU residents, CCPA for California):

• Access, correct, or delete your Personal Data.
• Object to processing or request restriction.
• Portability of data.
• Opt-out of automated decision-making (note: Services use AI but require your verification).
• Withdraw consent (where applicable).

Submit requests to [insert contact email]. We respond within applicable timelines (e.g., 1 month for GDPR). For cookies, use browser settings; for marketing emails, unsubscribe via links.
We do not collect data from children under 13 (or 16 in some jurisdictions) and will delete such data if identified.

7. International Transfers
Data may be processed in the U.S. or other countries. For EU/UK data, we use Standard Contractual Clauses or equivalent safeguards. By using the Services, you consent to such transfers.

8. Third-Party Links and Services
The Services integrate third-party tools (e.g., OpenAI, Apollo.io). Their privacy practices apply to data shared with them; review their policies. We are not responsible for third-party actions.

9. Changes to This Policy
We may update this Policy with notice (e.g., email or in-app). Continued use constitutes acceptance. Check periodically for changes.

10. Contact Us
For questions or requests: DEMAVIAS, LLC 1007 N Orange Street, DE-10981 Wilmington, USA
Email: compliance@di-atomic.com

This Policy protects DEMAVIAS, LLC's interests by limiting our role to processor where possible and disclaiming warranties. Consult your own counsel for your compliance obligations.
DEMAVIAS, LLC By: Martin Shein Its: Sole Member