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Privacy Policy

Effective Date: September 7, 2026

This Privacy Policy explains how Otto Web Solutions, LLC, doing business as DivvyDen ("DivvyDen," "we," "us," or "our") collects, uses, discloses, stores, and protects personal information when you access or use https://divvyden.com and any related websites, applications, software, features, tools, and services we provide (collectively, the "Platform").

By accessing or using the Platform, you acknowledge that you have read this Privacy Policy. If you do not agree with our practices, please do not use the Platform.

1. What DivvyDen Does

DivvyDen is a software-as-a-service platform for creators and businesses. The Platform offers a broad set of tools that may include: customizable link-in-bio profile pages; an AI Book Studio for generating ebooks, picture books, puzzle books, coloring books, journals, recipe books, and courses; AI-generated Landing Pages — custom marketing pages built for a specific product; digital storefronts for selling ebooks, courses, audio products, and other digital goods; social media automation (AutoDM) for Instagram and Facebook; a Social Promoter for AI-assisted organic post creation and publishing to connected Facebook Pages, Instagram accounts, and Pinterest boards (including DivvyDen's own official accounts, which may promote published creator content); automated email marketing and sales funnels; lead magnet opt-in campaigns; appointment bookings; event ticketing; membership management; a Store Hub for physical businesses (including loyalty stamp cards, QR check-ins, giveaways, and surveys); profile analytics; and a creator directory.

DivvyDen may offer free and paid subscription plans. Availability of specific features depends on your subscription plan and account type (Creator or Business).

2. Scope of This Privacy Policy

This Privacy Policy applies to personal information we collect when you:

  • Visit or browse the Platform;
  • Create or use a DivvyDen account;
  • Create or manage a public profile;
  • Subscribe to a paid plan;
  • Generate, upload, publish, or sell ebooks, courses, puzzles, picture books, landing pages, audio products, or other digital products;
  • Purchase ebooks, courses, puzzles, picture books, or other digital products through the Platform;
  • Offer or book appointments, events, or memberships;
  • Use social media automation (AutoDM) features or Social Promoter (organic post creation and publishing);
  • Use email marketing or sales funnel tools;
  • Opt in to a lead magnet offered by a creator on the Platform;
  • Participate in giveaways, surveys, or loyalty programs offered through the Platform;
  • Scan a QR code linked to a DivvyDen business profile;
  • Apply for or receive seller payouts;
  • Contact us for support; or
  • Otherwise engage with us through the Platform.

This Privacy Policy applies to information we control. It does not govern how third parties handle your information after you leave DivvyDen or interact with third-party websites, social platforms, payment processors, affiliate programs, or other external services.

3. Public Profiles, Public Content, and Creator Stores

DivvyDen profiles, creator stores, public links, product listings, event pages, booking pages, membership pages, and published content are generally intended to be public by default unless we expressly provide privacy or access controls for a specific feature.

Information you choose to publish may be visible to visitors, customers, search engines, payment processors, analytics tools, and other third parties. This may include your username, display name, biography, profile image, banner image, background image, links, social handles, product titles, ebook and course descriptions, pricing, previews, cover images, AI-generated landing pages, event details, booking availability, membership tiers, seller information, and other public content.

You should not publish sensitive personal information on your public profile or anywhere else on the Platform unless you are comfortable making that information available publicly.

4. Information We Collect

We may collect the following categories of personal information.

4.1 Information You Provide Directly

Account Information: name, email address, username, password, profile details, business name, display name, account type (Creator or Business), account preferences, and login information.

Profile and Store Content: biography, profile photo, banner image, background image, links, affiliate links, social handles, product listings, ebook titles, ebook descriptions, ebook files, course titles, course descriptions, course outlines, lesson content, puzzle and picture book files, landing page copy and generated hero images, audio files, cover images, pricing, booking service descriptions, event details, membership tier information, branding, and other content you upload or publish.

AI Generation Inputs and Outputs: prompts, instructions, draft text, generated ebook and course content, lessons, quiz questions, revisions, titles, outlines, summaries, product descriptions, cover art generation requests, and other materials created, submitted, edited, or generated using DivvyDen's AI tools.

Social Account Access (AutoDM and Social Promoter): when you connect a social media account (such as Instagram, Facebook, or Pinterest) to use AutoDM or Social Promoter features, we receive OAuth access tokens and limited account information necessary to operate the features you configure. We do not store your social platform login credentials. When you use Social Promoter, the post caption and image URL you select are transmitted to Meta's API (for Facebook and Instagram) or Pinterest's API (for Pinterest, including the board you select) on your behalf to publish your organic post or Pin. This access is used solely to deliver the social media functionality you set up and is not used for any other purpose.

DivvyDen's Official Social Accounts: separately from the social accounts you connect yourself, DivvyDen operates its own official social media accounts (Instagram, Facebook, and Pinterest) that it may use to promote published creator content — such as ebook, course, puzzle, and picture book titles, cover images, and landing page links — as part of marketing the Platform. This does not involve your personal social account credentials or access tokens; it uses only the public product information you have already chosen to publish.

Email Marketing and Funnel Configuration: email sequence content, step delays, trigger settings, subject lines, and email body content that you create and configure for your sales funnels and email campaigns.

Seller Information: information needed to enable seller accounts, payouts, tax reporting, fraud prevention, compliance checks, and marketplace operations, including payout status, connected payment account identifiers, business details, and seller verification status.

Buyer and Customer Information: information submitted when purchasing digital products, booking appointments, registering for events, or joining memberships — such as name, email address, billing details, order history, booking details, event registration information, download access records, customer support messages, and transaction-related information.

Billing and Subscription Information: billing name, billing email, billing address, subscription plan, payment status, invoice information, renewal dates, cancellation status, failed payment details, and related account billing records.

Business Feature Data: if you use Store Hub or business-tier features, information submitted through loyalty stamp card programs, QR check-in campaigns, giveaway entries, or surveys — which may include names, email addresses, phone numbers, participation records, and survey responses provided by your customers or visitors.

Communications: messages you send to us through support forms, email, chat, contact pages, dispute processes, copyright complaints, policy reports, or other communication channels.

Verification, Compliance, and Dispute Information: information related to identity checks, fraud reviews, chargebacks, refunds, copyright complaints, policy violations, account investigations, and legal requests.

Promotional Information: information you provide when participating in surveys, giveaways, waitlists, beta programs, promotions, referral programs, or similar activities.

4.2 Information We Collect Automatically

Device and Browser Information: IP address, browser type, operating system, device identifiers, device type, language settings, and approximate location derived from IP address.

Usage Information: pages viewed, profiles visited, products viewed, links clicked, ebooks and courses purchased, downloads initiated, lessons completed, events registered, bookings made, referral source, timestamps, session duration, navigation paths, and interactions with Platform features.

Analytics and Performance Data: profile views, link clicks, product views, conversion activity, download counts, sales analytics, referral tracking, error logs, crash reports, performance data, and diagnostic information.

Email Engagement Data: when you use Email Marketing Features, we may collect data about email delivery, open events, click events, unsubscribe events, bounce rates, and complaint rates in connection with automated email sequences sent through the Platform.

Security and Fraud Data: login activity, failed login attempts, suspicious activity indicators, abuse reports, payment risk indicators, device fingerprints where permitted, and other security-related data.

Cookie and Tracking Information: information collected through cookies, local storage, session storage, pixels, tags, and similar technologies, as described below.

4.3 Information from Third Parties

Payment Processors: we may receive information from Stripe, PayPal, or other payment providers, including customer IDs, subscription status, payment status, invoice records, payout status, connected account IDs, chargeback or dispute data, fraud signals, and limited billing details.

Social Platforms (AutoDM and Social Promoter): when you connect a social account for AutoDM or Social Promoter, we may receive account identifiers, page or board identifiers, publishing tokens, comment and message data necessary to identify keyword triggers and deliver automated responses (AutoDM), and publishing confirmations or error responses returned by Meta's API or Pinterest's API when posting on your behalf (Social Promoter). This data is used only to operate the applicable feature.

Authentication and Infrastructure Providers: we use trusted third-party authentication and cloud infrastructure providers and may receive authentication tokens, user identifiers, session data, logging records, email verification status, and security-related information from them.

Connected or Linked Services: if you connect third-party tools, social accounts, affiliate networks, or integrations, we may receive information made available through those services.

Marketing and Analytics Providers: we may receive information from advertising, analytics, referral, or marketing partners consistent with their terms and your privacy settings.

Customers, Visitors, or Other Users: we may receive reports, complaints, reviews, support requests, copyright claims, abuse reports, or dispute information from buyers, visitors, creators, or third parties.

5. How We Use Personal Information

We may use personal information to:

  • Provide, operate, maintain, and improve the Platform;
  • Create, authenticate, and manage user accounts;
  • Host and display public profiles, creator stores, and product listings;
  • Enable AI-assisted ebook and course drafting, content generation, editing, and publishing tools;
  • Operate social media automation (AutoDM) features on your behalf;
  • Operate Social Promoter features — generating AI-assisted post captions and publishing organic posts to connected Facebook Pages, Instagram accounts, and Pinterest boards on your behalf;
  • Send automated marketing emails and sales funnel sequences you configure;
  • Operate lead magnet delivery and subscriber opt-in functionality;
  • Facilitate appointment bookings, event registrations, and membership enrollments;
  • Operate business-tier features including loyalty programs, giveaways, QR check-ins, and surveys;
  • Process subscriptions, renewals, upgrades, downgrades, cancellations, and failed payments;
  • Process digital product purchases and provide download access;
  • Support seller onboarding, payment processing, payouts, fraud screening, and compliance checks;
  • Calculate platform fees, seller earnings, refunds, chargebacks, taxes, and transaction history;
  • Provide analytics to creators, including views, clicks, product performance, and sales metrics;
  • Communicate with you about your account, purchases, billing, payouts, product updates, support requests, and security matters;
  • Detect, prevent, investigate, and address fraud, spam, abuse, policy violations, intellectual property violations, security incidents, and unlawful activity;
  • Review, moderate, disable, remove, or restrict content, products, profiles, stores, automated messages, email campaigns, or accounts;
  • Enforce our Terms of Service and other agreements;
  • Comply with tax, accounting, legal, regulatory, card network, payment processor, and law enforcement obligations;
  • Respond to disputes, chargebacks, refund requests, copyright complaints, and legal claims;
  • Send marketing or promotional communications where permitted by law or with your consent;
  • Personalize and improve the user experience; and
  • Protect the rights, safety, property, and integrity of DivvyDen, our users, buyers, creators, partners, and the public.

6. AI-Generated Content and Prompts

When you use DivvyDen's AI Book Studio or other content creation tools, we may process the prompts, instructions, source materials, generated outputs, edits, drafts, titles, outlines, cover art requests, and related content you submit or create.

We use this information to provide the requested generation features, improve Platform functionality, maintain account history, support publishing and sales workflows, detect abuse, enforce policies, investigate prohibited content, and comply with legal obligations.

You should not submit confidential, sensitive, regulated, proprietary, or third-party information into the AI generation tools unless you have the necessary rights and permissions to do so.

7. Social Media Features — AutoDM and Social Promoter

7.1 AutoDM (Automated Messaging and Comment Replies)

When you use AutoDM features and connect a social media account (such as Instagram or Facebook), DivvyDen receives and uses limited data from that account solely to operate the automation rules you configure. This may include OAuth access tokens, account identifiers, incoming comment text, and incoming message content necessary to identify keyword triggers and deliver your configured automated responses.

We use this data only to:

  • Authenticate and maintain your connection to the social platform;
  • Identify qualifying comments or messages based on the keywords you set;
  • Send the automated replies you configured; and
  • Monitor feature health and detect policy violations.

7.2 Social Promoter (Organic Post Publishing)

When you use the Social Promoter feature, DivvyDen processes the following information:

  • AI caption generation: the product type, product title, and product description you select are transmitted to OpenAI's API to generate suggested post captions. We do not retain your prompts or OpenAI's responses beyond the current session.
  • Post publishing: the caption text you approve and the image URL you select are transmitted to Meta's Graph API (Facebook and/or Instagram) or Pinterest's API on your behalf to publish the organic post or Pin to the connected account(s) and, for Pinterest, the board you choose.
  • Post history and logging: every publish attempt — whether successful or failed — is logged in our database. This log includes the platform, account username, product type, product title, caption text, post status (published or failed), any error message, and timestamp. This log is maintained for platform integrity, abuse detection, and compliance purposes.
  • Soft deletion: if you remove a post from your visible history, the record is hidden from your dashboard but is not permanently deleted from our database. The underlying log is retained internally for platform safety, dispute resolution, and legal compliance purposes.

We do not store your social platform login credentials. We do not use social account data for advertising, profiling, or any purpose beyond operating the AutoDM and Social Promoter features. We do not share social account data with third parties except as strictly necessary to deliver these features (for example, transmitting a post caption through the social platform's API).

You can revoke DivvyDen's access to your social account at any time through your social platform's connected apps or permissions settings, which will disable AutoDM and Social Promoter functionality for that account.

Social platforms may independently collect, retain, and process data in connection with your account, your posts, and your use of their APIs. Their data practices are governed by their own privacy policies.

8. Email Marketing, Sales Funnels, and Subscriber Data

When you use Email Marketing Features — including sales funnels and lead magnet delivery — DivvyDen processes the email addresses, names, and other contact information of your subscribers and leads ("Subscriber Data") on your behalf.

You are the data controller. As the creator who collects subscriber opt-ins, you are responsible for your data collection practices, opt-in consent, privacy disclosures to subscribers, and full compliance with applicable email marketing and data protection laws (including CAN-SPAM, CASL, and GDPR). DivvyDen acts as a data processor for Subscriber Data, processing it only as directed by you and as necessary to deliver the Email Marketing Features.

We use Subscriber Data only to:

  • Send the email sequences you configure to the recipients you specify;
  • Track delivery status, open events, click events, and unsubscribe requests;
  • Honor unsubscribe and opt-out requests on your behalf;
  • Provide you with engagement analytics for your campaigns; and
  • Detect abuse, enforce policies, and comply with applicable law.

We do not use Subscriber Data for our own marketing purposes, sell Subscriber Data, or share it with third parties except as strictly necessary to deliver the email (for example, routing through an email delivery provider).

Subscribers may opt out of your email sequences at any time using the unsubscribe link included in each email sent through the Platform. We honor all unsubscribe requests processed through the Platform on behalf of creators.

9. Business Features and Visitor Data

If you use DivvyDen's business-tier features — including loyalty stamp cards, QR check-in campaigns, giveaways, surveys, and similar tools — you may collect personal information from the people who interact with those features ("Visitor Data"). Visitor Data may include names, email addresses, phone numbers, QR scan records, loyalty card status, survey responses, giveaway entries, and participation history.

You are the data controller for Visitor Data. DivvyDen processes Visitor Data on your behalf to operate the features you enable. You are solely responsible for:

  • Providing appropriate privacy notices to visitors and customers who interact with your business features;
  • Obtaining any consents required by applicable privacy law before collecting personal information;
  • Complying with applicable data protection, consumer protection, and promotional contest laws; and
  • Ensuring any giveaways, contests, or promotions you run comply with applicable legal requirements.

DivvyDen does not use Visitor Data for our own marketing purposes, and does not share it with third parties except as necessary to operate the Platform or as required by law.

10. Payment Processing, Stripe, PayPal, and Seller Payouts

DivvyDen uses third-party payment processors, including Stripe and PayPal, to process subscriptions, digital product purchases, booking and event payments, membership payments, seller payouts, refunds, chargebacks, and related payment activity.

We do not store full payment card numbers on our own servers. Payment information may be collected and processed directly by Stripe, PayPal, or another payment provider according to that provider's terms, privacy policy, and security practices.

For subscriptions, we may receive and retain limited payment-related information, including customer identifiers, subscription status, payment status, invoice records, billing period information, plan details, and basic billing information.

For digital product sales and seller payouts, we may receive and retain transaction-related and payout-related information, including connected account IDs, seller verification status, payout eligibility, payout history, order records, refund records, dispute records, chargeback data, tax-related records, fraud indicators, and compliance information.

Payment processors may require sellers to provide additional information directly to them for identity verification, tax reporting, fraud prevention, risk review, and payout eligibility. DivvyDen does not control how payment processors collect, process, or store information submitted directly to them.

11. Digital Product Purchases and Buyer Data

When a buyer purchases an ebook, course, audio product, or other approved digital product through the Platform, we may collect and process information necessary to complete the transaction, provide access to the digital product, deliver receipts, prevent fraud, process refunds or chargebacks, and provide customer support.

Creators may receive limited buyer information needed to fulfill the transaction, provide support, comply with legal obligations, or manage their sales activity. Creators may not misuse buyer information, spam buyers, sell buyer data, or use buyer information outside the scope permitted by DivvyDen's policies and applicable law.

12. Affiliate Links and Third-Party Destinations

DivvyDen allows users to publish affiliate links, referral links, product links, and links to third-party websites, merchants, services, social platforms, and affiliate programs.

If you click a third-party link or leave DivvyDen, your information may be collected and used by that third party under its own privacy policy. DivvyDen does not control and is not responsible for the privacy, security, or data practices of third-party sites, merchants, affiliate networks, advertisers, or social platforms.

13. Cookies and Similar Technologies

13.1 What Are Cookies

Cookies are small text files placed on your device by a website you visit. We also use similar technologies such as local storage, session storage, pixels, tags, and scripts. In this section, we refer to these collectively as "cookies."

13.2 Categories of Cookies We Use

Strictly Necessary Cookies: required for authentication, account security, checkout, session management, fraud prevention, CSRF protection, and core Platform functionality.

Functional Cookies: used to remember preferences such as UI settings, profile editing state, dashboard behavior, and account management preferences.

Analytics and Performance Cookies: used to understand how visitors and users interact with the Platform, including profile views, product views, link clicks, referral activity, email engagement metrics, and performance metrics.

Marketing and Referral Cookies: used to measure referrals, affiliate activity, promotional campaigns, and advertising effectiveness where permitted by law.

Payment and Fraud Prevention Cookies: used by payment processors and fraud prevention tools to support checkout, subscription billing, seller payouts, risk analysis, and payment security.

13.3 Third-Party Cookies

Third-party services we use may set their own cookies or similar technologies, including payment processors, authentication providers, hosting providers, analytics services, fraud prevention providers, email delivery providers, and marketing tools. We do not control third-party cookies.

13.4 Managing Cookies

When you first visit the Platform, our cookie banner lets you accept all cookies or reject non-essential (analytics) cookies — either choice gives you full access to the Platform. You can change your choice at any time by clearing your browser's local storage for this site, which will show the banner again. You may also control cookies through your browser settings. Blocking strictly necessary cookies may prevent the Platform from functioning correctly, including login, checkout, seller dashboard access, ebook downloads, course access, or account management.

14. How We Share Personal Information

We may share personal information in the following circumstances:

Service Providers: with vendors, contractors, and service providers that help us operate the Platform, including hosting, cloud storage, authentication, email delivery, analytics, fraud prevention, payment processing, customer support, content moderation, social platform API integrations, and infrastructure providers.

Payment Processors and Financial Partners: with Stripe, PayPal, or other payment providers to process payments, subscriptions, refunds, chargebacks, seller onboarding, KYC, payouts, tax reporting, fraud reviews, and compliance obligations.

Social Platforms (AutoDM and Social Promoter): when operating AutoDM features, we transmit automated message and comment reply content to the applicable social platform's API on your behalf. When operating Social Promoter, we transmit post captions and image URLs to Meta's API or Pinterest's API on your behalf to publish organic posts or Pins to the Facebook Pages, Instagram accounts, and Pinterest boards you select.

Email Delivery Providers: when sending emails through Email Marketing Features, we share recipient email addresses and email content with our email delivery infrastructure providers solely to deliver your configured messages.

Creators and Sellers: with sellers when necessary to complete digital product sales, provide access to orders, manage customer support, process refunds, respond to disputes, and operate seller dashboards.

Buyers: with buyers when necessary to identify the creator or seller of a product, provide receipts, deliver digital products, process support requests, or satisfy legal obligations.

Public Content: information you choose to make public through your profile, store, links, product listings, event pages, or other public features may be visible to visitors and may be indexed, copied, saved, or shared by third parties.

Legal Compliance: where required by law, subpoena, court order, regulation, legal process, tax authority, card network rule, payment processor requirement, or government request.

Protection and Enforcement: where we believe disclosure is necessary to protect rights, safety, property, security, prevent fraud, enforce our agreements, investigate abuse, respond to disputes, or protect the Platform.

Business Transfers: in connection with a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar business transaction.

With Your Direction or Consent: where you direct us to share information or use an integration that requires such sharing.

We do not sell your personal information for money. However, depending on applicable privacy law, certain analytics, advertising, referral, or tracking activities may be considered a "sale," "sharing," or "targeted advertising." Where legally required, we will provide applicable opt-out rights.

15. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Platform, maintain your account, process transactions, support seller payouts, comply with legal obligations, resolve disputes, enforce agreements, prevent fraud, maintain tax and accounting records, and protect the Platform.

Retention periods may vary depending on the type of information, the nature of our relationship with you, legal requirements, payment processor requirements, tax obligations, security needs, dispute history, and operational needs.

Public content may remain visible until removed by you or by DivvyDen. Copies of removed content may remain in backups, logs, archives, transaction records, dispute records, or legal compliance records for a limited period.

Social account access tokens are retained only as long as your AutoDM or Social Promoter integration is active. Subscriber Data and Visitor Data are retained as long as your account is active and for a reasonable period thereafter to comply with legal obligations. Social Promoter post logs (including captions, platform, status, and timestamps) are retained even after you hide a post, for platform safety, abuse detection, and legal compliance purposes.

IP addresses: IP addresses collected through link clicks, profile visits, and product views are kept in identifiable form for up to 90 days for security, fraud prevention, and abuse investigation, and are then automatically removed from these analytics records. Aggregate, non-identifying metrics derived from this activity (such as total click or view counts) are retained for longer as part of your dashboard analytics.

16. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, misuse, or destruction.

However, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security.

You are responsible for maintaining the confidentiality of your login credentials and for using strong passwords and secure devices.

17. Children's Privacy

DivvyDen is not directed to children under 13, and we do not knowingly collect personal information from children under 13.

To create an account, subscribe to paid services, sell digital products, offer Creator Services, use automation features, or receive payouts, you must be at least 18 years old or the age of legal majority in your jurisdiction.

If we learn that we have collected personal information from a child under 13 without appropriate authorization, we will take reasonable steps to delete it.

18. Your Privacy Choices and Rights

Depending on where you live, you may have rights regarding your personal information, including the right to:

  • Access personal information we hold about you;
  • Request correction of inaccurate information;
  • Request deletion of certain personal information;
  • Object to or limit certain processing;
  • Opt out of certain marketing communications;
  • Opt out of certain sales, sharing, or targeted advertising where applicable;
  • Request a copy of certain personal information in a portable format; and
  • Appeal certain privacy request decisions where required by law.

To exercise available rights, contact us using the information below. We may need to verify your identity before fulfilling your request.

Email unsubscribes: if you are a subscriber on a creator's email list and wish to unsubscribe, use the opt-out link in any email you receive, or contact us and we will process your request on the creator's behalf.

19. U.S. State Privacy Rights

If you reside in a U.S. state that grants specific privacy rights (including California, Virginia, Colorado, Connecticut, Texas, and others), you may have additional rights under applicable law, subject to verification and legal exceptions.

These rights may include the right to know, access, correct, delete, obtain a copy of your personal information, opt out of targeted advertising or certain data sharing, and not be discriminated against for exercising privacy rights.

To submit a privacy request, use the contact information provided below.

20. International Data Transfers

If you access the Platform from outside the United States, your information may be transferred to, stored in, or processed in the United States or other countries where we or our service providers operate.

By using the Platform, you understand that your information may be transferred to countries that may not provide the same level of data protection as your home jurisdiction.

21. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make changes, we will post the updated version on this page and update the Effective Date.

Your continued use of the Platform after any changes become effective means you acknowledge the updated Privacy Policy.

22. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact:

Otto Web Solutions, LLC d/b/a DivvyDen
Website: https://divvyden.com
Email: support@divvyden.com

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