Privacy Policy | Divanas App

Effective date: 20 May 2025

This Privacy Policy describes how ReBoss Ventures LLC (“we”, “us”, “our”) collects, uses, and protects the personal information you provide when using the website www.divanas.app, including when joining our beta waiting list.

ReBoss Ventures LLC (“ReBoss”, “we”, “us”, “ours”) values your privacy. ReBoss provides users with website(s), mobile application(s), Content, Social media posts, courses, presentations, products and services (“ReBoss Services”) in the wellness, personal development and biohacking space. This Privacy Policy ("Policy") will help you understand how we collect and use personal information from those who use ReBoss Services, and what we will and will not do with the information we collect. Our Policy has been designed and created to ensure those affiliated with ReBoss Ventures LLC of our commitment and realization of our obligation not only to meet, but to exceed, most existing privacy standards.

We reserve the right to make changes to this Policy at any given time. If you want to make sure that you are up to date with the latest changes, we advise you to frequently visit this page. If at any point in time ReBoss Ventures LLC decides to make use of any personally identifiable information on file, in a manner vastly different from that which was stated when this information was initially collected, the user or users shall be notified by email. Users at that time shall have the option as to whether to permit the use of their information in this separate manner.

This Policy applies to ReBoss Ventures LLC and any subsidiary company listed below, and it governs any and all data collection and usage by us. By using ReBoss Services or services of any affiliated website(s) or companies, you are therefore consenting to the data collection procedures expressed in this Policy.

Please note that this Policy does not govern the collection and use of information by companies that ReBoss Ventures LLC does not control, nor by individuals not employed or managed by us. If you visit a website, download a mobile application and/or purchase a product or service that we mention or link to, be sure to review its privacy policy before providing the site with information. It is highly recommended and suggested that you review the privacy policies and statements of any website, mobile application, product and/or service you choose to use or frequent to better understand the way in which they garner, make use of and share the information collected.

Specifically, this Policy will inform you of the following:

1. what personally identifiable information is collected from you through ReBoss Services;

2. why we collect personally identifiable information and the legal basis for such collection;

3. how we use the collected information and with whom it may be shared;

4. what choices are available to you regarding the use of your personal information; and

5. the security procedures in place to protect the misuse of your information.

Information We Collect

It is always up to you whether to disclose personally identifiable information to us, although if you elect not to do so, we reserve the right not to register you as a user or provide you with any products or services. We may collect various types of information, such as:

Personal information

This is personal data about you that we may collect when you sign up for our services, fill in forms on the site, or by corresponding with us by phone, e-mail or otherwise:

your name;
shipping, billing, and/or business addresses;
location information;
phone number;
e-mail address;
gender;
date of birth; and
survey response data;
profile photo.

Technical information

This is the technical data you are using to access our website and app such as:

IP address;
device identification;
username and password information;
browser type and version;
time zone;
browser plug-in types and versions;
data about your activities on our websites, including the Uniform Resource Locator (URL) from which you came to our websites and the URLs that you visited on our websites;
cookie number;
habits & Routines you viewed or searched for;
download errors;
length of visits to certain pages;
page interaction information;
methods used to browse away from the page;
operating system and platform;
the devices and/or computers that you used to access ReBoss Services.

Fitness information

We may collect this data to help you improve your routines, habits and achieve your health and wellness goals:

physical information (e.g., weight,height metrics);
behavioural specifications (habits, daily routines);
food and nutritional information;
fitness and activity information;
mental state (mood, mental condition);
supplements information.

In addition, ReBoss Ventures LLC may have the occasion to collect demographic information, such as age, gender, household income, political affiliation, race and religion, as well as the type of browser you are using, IP address, or type of operating system, which will assist us in providing and maintaining superior quality service.

ReBoss Ventures LLC may also deem it necessary, from time to time, to follow websites that our users may frequent to visit what types of services and products may be the most popular to customers or the general public.

Please rest assured that ReBoss Ventures LLC will only collect personal information that you knowingly and willingly provide to us by way of surveys, completed membership forms, emails and any information collected by any of our mobile applications.

We may use your information for Marketing/Advertising, for example to send you offers for our or third party products that you may like. To inform you of any ReBoss news and newsletters, special offers, and promotions, including email, social media and text messages; to contact you about products or information we think may interest you. Also, for other marketing, advertising, and promotional purposes.

If you purchase certain ReBoss Services, such as our courses, you provide your payment information, including your name, credit or debit card number, card expiration date, CVV code, and billing address. We do not store this payment information. Note that third-party payment processors may retain this information in accordance with their own privacy policies and terms.

If you choose to connect or integrate certain ReBoss Services, such as our mobile application, to another service, we may receive and/or provide certain information to/from the other service. For example, if you connect to Facebook, we may receive information like your user name, age range, language, email address, and contacts. You may also choose to integrate ReBoss Services with wearable devices and/or other apps. If you do so certain data will be sent to us in order to enhance your usage experience of ReBoss Services. You can stop sharing the information from the other service with us by removing our access to that other service.

We may partner with third parties, such as businesses that offer ReBoss Services to their employees and customers. In such cases, those companies may provide us with your name, email address, or similar information so that we can invite you to participate or determine your eligibility for particular benefits, such as discounts or free services.

Why We Collect Information and For How Long

We only ask for personal information when we truly need it to provide a service to you. We collect it by fair and lawful means, with your knowledge and consent. We also let you know why we’re collecting it and how it will be used.

We are collecting your data for following reasons:

To better understand your needs and provide you with the services you have requested.
To fulfill our legitimate interest in improving our services and products.
To send you promotional emails containing information we think you may like when we have your consent to do so.
To contact you to fill out surveys or participate in other types of market research, when we have your consent to do so.
To recommend products/services that could be of benefit to you through our affiliates, unaffiliated third parties and partners.
To customize our website according to your online behavior and personal preferences.
To provide personalized habit routines and lifestyle suggestions.

The length of time we retain said information will be determined based upon the following criteria: the length of time your personal remains relevant; the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations; any limitation periods within which claims might be made; any retention periods prescribed by law or recommended by regulators, professional bodies or associations; the type of contract we have with you, the existence of your consent, and our legitimate interest in keeping such information as stated in this Policy.

Whatever data we store, we’ll protect within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification.

We don’t share any personally identifying information publicly, except when required to by law.

How we store data

Personal data controller - ReBoss Ventures LLC will be the controller of your personal data.

ReBoss Ventures LLC takes precautions to protect your information. When you submit sensitive information via ReBoss Services, your information is protected both online and offline. Wherever we collect sensitive information , that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for "https" at the beginning of the address of the webpage.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers and servers in which we store personally identifiable information are kept in a secure environment. This is all done to prevent any loss, misuse, unauthorized access, disclosure or modification of the user's personal information under our control.

The company also uses Secure Socket Layer (SSL) for authentication and private communications to build users' trust and confidence in the internet and website use by providing simple and secure access and communication of credit card and personal information.

Use of Information Collected

We may share your information, including your personal information, with the following entities and in the following situations:

Affiliates - Information may be provided to our affiliates for research and marketing purposes, including marketing ReBoss Services as well as their own products and services, and other purposes that align within this Policy.

Partners - We may offer promotions with other entities, and we may share your information with the other entity for the purpose of the joint promotion at the benefit of you.

ReBoss Ventures LLC may collect and may make use of personal information to assist in the operation of ReBoss Services and to ensure the delivery of the services you need and request. At times, we may find it necessary to use personally identifiable information as a means to keep you informed of other possible products and/or services that may be available to you from www.divanas.app and its subsidiaries.

ReBoss Ventures LLC and its subsidiaries may also be in contact with you with regards to completing surveys and/or research questionnaires related to your opinion of current or potential future services that may be offered.

ReBoss Ventures LLC may feel it necessary, from time to time, to contact you on behalf of our other external business partners with regards to a potential new offer which may be of interest to you. If you consent or show interest in presented offers, then, at that time, specific identifiable information, such as name, email address and/or telephone number, may be shared with the third party.

ReBoss Ventures LLC uses various third-party social media features including but not limited to Instagram, Facebook, Pinterest, Twitter, LinkedIn and other interactive programs. These may collect your IP address and require cookies to work properly. These services are governed by the privacy policies of the providers and are not within ReBoss' control.

Disclosure of Information

ReBoss Ventures LLC may not disclose the information provided by you except under the following circumstances:

As necessary to provide services or products you have ordered.
In other ways described in this Policy or to which you have otherwise consented.
In the aggregate with other information in such a way so that your identity cannot reasonably be determined.
As required by law, or in response to a subpoena or search warrant.
To outside auditors who have agreed to keep the information confidential.
As necessary to enforce our Terms and Conditions of Use.
As necessary to maintain, safeguard and preserve all the rights and property of ReBoss Ventures LLC.
As a sale of aggregated user data to companies that we do business with.

Marketing

We might use the data you gave to us to send you promotional emails containing information of our services we think you may like, as well as those of our partners.

You have the right to stop ReBoss from contacting you for marketing purposes or giving your data to the other members of ReBoss Ventures LLC.

Contests & Promotions

We may offer contests and promotions for our users. With these contests and promotions your name may appear on parts of our website where we display winners or top performers.

Sometimes we may not have your name and may need to rank you based on your email. We will never display your complete email address anywhere but may display the first few letters so that you can identify yourself.

By signing up to Divana or Purchasing Divana you agree that the name you provide us may appear in such places on our site and our app. If you don’t want to participate in our contests and promotions and have your name not appear just email support@divanas.app and request that and we will remove you.

Non-Marketing Purposes

ReBoss Ventures LLC greatly respects your privacy. We do maintain and reserve the right to contact you if needed for non-marketing purposes (such as bug alerts, security breaches, account issues, and/or changes in ReBoss Ventures LLC products and services). In certain circumstances, we may use ReBoss Services, newspapers, social media or other public means to post a notice.

Types of Cookies We Use

In compliance with the General Data Protection Regulation (GDPR) and the ePrivacy Directive (Cookie Law), we request your explicit consent before placing any cookies on your device that are not strictly necessary.

You can manage your cookie preferences at any time by accessing our cookie settings interface.

You may accept all cookies, reject non-essential ones, or select specific types of cookies to allow.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Below we explain the cookies we use and why.

We use cookies to distinguish you from other users of the services.

1. Essential Cookies

These cookies are necessary for the core functionality of the website and do not require user consent. They ensure basic security and proper website performance.

2. Functional Cookies

These cookies allow the website to remember user preferences, such as language or region, and enable enhanced, personalized features.

3. Analytics Cookies

These cookies collect information about how visitors use the site, such as which pages are most frequently visited. They help us improve the performance and usability of the website.

4. Advertising Cookies

These cookies are used to deliver relevant ads to visitors based on their interests and to measure the effectiveness of advertising campaigns.

5. Third-Party Cookies

If third-party apps or integrations (e.g., Google Analytics, Facebook Pixel) are added to the site, these services may set their own cookies. It is important to identify these cookies and obtain user consent where required.

You can set your browser not to accept cookies. However, in some cases our website features may not function as a result.

Children Under the Age of 13

ReBoss Services are not intended for individuals under the age of 13. We do not knowingly collect personal data from children under this age. If we become aware that such information has been inadvertently collected, we will take immediate steps to delete it or obtain verifiable parental consent for its use. Children under 13 must have parent or guardian permission to use our services.

Unsubscribe or Opt-Out

All users of ReBoss Services have the option to discontinue receiving communications from us by way of email or newsletters. To discontinue or unsubscribe from ReBoss Services please send an email that you wish to unsubscribe to support@divanas.app and click the unsubscribe link at the bottom of one of the emails that you receive from us. If you wish to unsubscribe or opt-out from any third-party websites, you must go to that specific website to unsubscribe or opt-out. ReBoss Ventures LLC will continue to adhere to this Policy with respect to any personal information previously collected.

Links to Other Websites and Services

ReBoss Ventures LLC contain links to other websites. ReBoss Ventures LLC does not claim nor accept responsibility for any privacy policies, practices and/or procedures of other such websites. Therefore, we encourage all users and visitors to be aware when they leave ReBoss Services and to read the privacy statements of every website that collects personally identifiable information. This Privacy Policy Agreement applies only and solely to the information collected by ReBoss Services.

Certain ReBoss Services including but not limited to our mobile application(s) allow you to link to or integrate with third party services that are not under ReBoss' control. We provide these links only as a convenience and are not responsible for the privacy policies of those services. We encourage you to review the privacy policies of any service that we integrate with and/or that you can link to from ReBoss Services and make sure that you agree to it prior to integrating and/or linking any third party service to any ReBoss Services.

In some instances ReBoss Services may mention third party products or services “Third Party Products”. This is done for your convenience. Typically there will be a link to those products or services on ReBoss Services such as our website(s), mobile application(s) and social media accounts. In some cases we may use a vendor's affiliate link and receive affiliate compensation from the vendor when you purchase their product or service by using our affiliate links. Please note that we have no control nor do we stand behind any Third Party Products. We simply mention them for your convenience. Please note that these Third Party Products have their own privacy policies. ReBoss has no control over their privacy policies. We strongly encourage you to review the privacy policy of any Third Party Product of service that we may link to from ReBoss Services before purchasing it and/or providing your personal information to the vendor of such third party products or services.

To be clear, when you leave ReBoss Services and visit other websites, integrate with other tools and products or purchase any third party products please be aware that ReBoss Terms of Use, Privacy Policy no longer apply. We strongly suggest that you read the Terms of Use and Privacy Policy and all other appropriate disclaimers of all third party products you purchase, third party websites you visit and/or any tools and services that you may link to from ReBoss Services.

Notice to European Union Users

ReBoss – back to basis, s.r.o. is registered in the Czech Republic and processes personal data in accordance with applicable EU laws, including the General Data Protection Regulation (GDPR). Some of the services we use (such as cloud or analytics providers) may result in the transfer of your data outside the European Economic Area (e.g., to the United States).

In all such cases, we ensure appropriate safeguards are in place, such as the Standard Contractual Clauses (SCCs) approved by the European Commission, or we work with providers that participate in the EU-U.S. Data Privacy Framework.

Security

ReBoss Ventures LLC takes precautions to protect your information. When you submit sensitive information via ReBoss Services, your information is protected both online and offline. Wherever we collect sensitive information (e.g. credit card information), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for "https" at the beginning of the address of the webpage.

Legal Basis of Personal Data Processing

For personal data subject to the GDPR, we rely on several legal bases to process the data.

The performance of the contract (the ReBoss Terms of Use) between you and ReBoss for the data processing relating to your use of ReBoss services.

ReBoss’ legitimate interest, more specifically:

Our business interest in providing you with emails and push notifications for timely introductory materials and information about your ReBoss account, our Product or services features and updates, and offers to upgrade your free account to a subscription account.
Our financial interest in providing you with promotional offers and/or discounts with respect to paid subscriptions and special offerings.
Our business interest in offering you particularized or adapted content based on your usage of the ReBoss services and products.
Our business interest in collecting data regarding your general usage activities for the purpose of improving our ReBoss user experience.
Our business interest is requesting that you partake in company’s surveys in order to better understand your needs and expectations.
Our financial interest in providing you the opportunity to purchase ReBoss subscriptions for the benefit of a third party.
Our business interest in providing you with customer service communications regarding your account, questions about our content offerings or any other matters directed to customer service staff, in order to have clear and easy communication with you and to respond to all your requests.
Our business interest in collecting data related to unplanned downtime or errors in the website or app.

California Residents

This Section of our privacy policy is for all visitors, users, and others who are California Residents only. We adopt this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

If you are a resident of California, you may request that we provide you with the information listed below (“Access Request”) and information that we have shared with third parties for electronic/online direct marketing purposes, if such sharing has occurred; such information can be provided to you once a year free of charge, and will cover information shared during the past twelve (12) months. Information will be provided within Forty Five (45) days of your request, or we will inform you that we need additional time to fulfill your request.

If you are a California resident and wish to make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request in writing to us at support@divanas.app. Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this address.

Information shared for purposes other than direct marketing will not necessarily be included in our response to such request. We reserve the right to request and confirm proof of identity as we determine necessary in our sole discretion, and retain your request for at least two years for auditing and user management purposes.

Data Access

You may contact us at support@divanas.app if you wish to obtain a copy of personal data that we have collected about you; if the CCPA applies to you, You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email us at support@divanas.app. We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.

Data Access for California Residents

If you are a California resident, the information below also applies to you. Certain terms used in this section have the meanings given to them in the California Consumer Privacy Act of 2018 (“CCPA”).

Categories of Personal Information ReBoss has collected from or about its Users in the preceding 12 months:

Identifiers (e.g. name, mailing address, email address, phone number, credit/debit card number).
Commercial information (e.g. products or services purchased, purchase history).
Internet or other electronic network activity (e.g. browse or search history).
Audio, electronic, visual, or similar information (e.g. recording of member service calls).
Payment Information (collected by a third-party vendor; ReBoss does not store payment information itself).
Biometric information (physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Professional or employment-related information. (Current or past job history or performance evaluations).
Inferences drawn from other personal information. (Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes).
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). (A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Geolocation data (Physical location or movements).

Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- - Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
  - Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Non-Discrimination

ReBoss will not discriminate against you because you exercise your rights. For example, ReBoss will not deny you Services or charge you a different price or rate for Services if you make an access, deletion, or do not sell request.

Financial Incentive Program

ReBoss does not offer a financial incentive program.

Rights for California Consumers

You have the following rights under the CCPA –

The right to make requests (no more than twice in a 12-month period) as follows:

1. Access Request

- - Categories of personal information (“PI”) we collected about you during the preceding 12 months.
  - Categories of sources from which PI is collected.
  - Business or commercial purpose for collecting or selling PI.
  - Specific pieces of PI we collected about you.
  - Categories of PI ReBoss has sold about you.
  - Categories of third parties to whom the PI was sold.
  - Categories of PI disclosed about you for a business purpose.
  - Categories of third parties to whom PI was disclosed for a business purpose.

2. Deletion Request

- - Request ReBoss delete your PI. Please note that, if you are a member, certain account information is necessary to maintain your membership and so a request to delete personal information will delete your account. If you would like to continue your membership after deletion, you will need to set up a new membership account, which will be devoid of all prior order history or other information. Please contact ReBoss at support@divanas.app about such request. Please be aware that if you do not contact ReBoss within seven (7) days of your deletion request, we will not be able to continue your membership through a secondary account.

3. Do Not Sell My Info

- - Request ReBoss opt you out of the sale of your PI. Send us an email to opt-out to support@divanas.app Attn: California Opt Out.

Submit Requests

1. Access Requests

- - If you are a User, you may contact ReBoss for privacy-related requests via email to support@divanas.app. Please put Privacy-Related Requests into the subject line of your email.
  - If you are not a User, and you believe ReBoss has collected information about you, and would like to exercise your right to obtain a disclosure of that personal information, contact ReBoss via email to support@divanas.app

2. Deletion Requests

- - If you are a User, you may contact ReBoss for privacy-related requests via email to support@divanas.app.
  - If you are not a User, and you believe ReBoss has collected information about you, and would like to exercise your right to obtain a disclosure of that personal information, contact ReBoss via email to support@divanas.app.

Selling Personal Information

ReBoss shares some data concerning User transactions that may qualify as “data sales” under CCPA including User interaction with third-party vendors and affiliates. This information may include personal information such as member email and address. To opt out of your participation in transactional data sharing, please email support@divanas.app Attn: California Opt Out.

Shine the Light Law

If you are a resident of California, pursuant to California Civil Code Section 1798.83, you may request information regarding our disclosure of your personal information to a third party for that party's direct marketing purposes. Any such disclosure made to a third party by us would be otherwise in accordance with the terms of this Privacy Policy. To make such a request please email us at support@divanas.app Attn: Shine the Light.

Acceptance of this Privacy Policy

By using the ReBoss Services including our Website and Mobile App(s), you are hereby accepting the terms and conditions stipulated within the Privacy Policy Agreement. If you are not in agreement with our terms and conditions, then you should refrain from further use of ReBoss Services. In addition, your continued use of ReBoss Services following the posting of any updates or changes to our Privacy Policy and/or Terms and Conditions of Use shall mean that you agree and accept our Privacy Policy, Terms and Conditions of use and all term changes.

European Union (EU) users – GDPR compliance

If you are located in the European Union (EU) or European Economic Area (EEA), you are entitled to specific rights under the General Data Protection Regulation (GDPR).

Your Rights Under the GDPR

Right to access your personal data.
Right to rectify incorrect or incomplete data.
Right to erasure (‘right to be forgotten’).
Right to restrict the processing of your data.
Right to data portability.
Right to object to processing.
Right to withdraw your consent at any time.
Right to lodge a complaint with a supervisory authority.

Legal Bases for Processing
We process your personal data under the following legal bases:

Your explicit consent.
Performance of a contract (e.g., our Terms of Use).
Compliance with legal obligations.
Protection of vital interests.
Our legitimate business interests.

International Data Transfer

ReBoss Ventures LLC is based in Delaware, USA. When we transfer your data outside the EU/EEA, we use safeguards such as Standard Contractual Clauses approved by the European Commission.

Data Controller - how to contact us

If you have any questions or concerns regarding our Privacy Policy Agreement related to our website, please feel free to contact us at the following:

ReBoss Ventures LLC

2604 Whittier Place, Wilmington

DE 19808

Email: support@divanas.app

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