Privacy Policy

Last modified November 25, 2024
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Welcome to That’s Me: an identity recognition system created and owned by the Digital Verification Research Group, Inc. (DIVERG). We will not sell, rent, or trade your personal information. We will only transfer your personal information with your consent, to third parties to assist in verifying your identity or as required for the prevention of fraud or otherwise permitted by law.

DIVERG Privacy Policy

Digital Verification Research Group, Inc. (“DIVERG,” “Company,” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy (“Privacy Policy”).

This Privacy Policy describes the types of information we may collect from you or that you may provide when you use our “That’s Me” service, visit our website, or contact our customer service (collectively, our "Service"), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy does not apply to information collected by any third party, including through any application or content that may link to or be accessible from or on our website or other features of the Service, or to information collected by us offline or through any other means, including on any other websites operated by the Company or any third party (including our affiliates or subsidiaries).

Please read this Privacy Policy carefully to understand our practices regarding your information and how we will treat it. There may be additional notices about our information practices including our BIOMETRIC INFORMATION PRIVACY POLICY. If you do not agree with our policies and practices, your choice is not to use our Service. By accessing or using our Service, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of this Service after we make changes is deemed to be acceptance of those changes, so please review this Privacy Policy periodically for updates.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
HOW WE USE YOUR INFORMATION
HOW WE SHARE YOUR INFORMATION
YOUR CHOICES, RIGHTS, AND CONTROLS
HOW WE PROTECT YOUR INFORMATION
HOW WE RETAIN YOUR INFORMATION
HOW WE TREAT INFORMATION FROM CHILDREN UNDER THE AGE OF THIRTEEN
CHANGES TO OUR PRIVACY POLICY
CONTACT INFORMATION

1. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect several types of information from and about users of our Service

‍Information You Provide to Us
‍We collect information you provide to us which includes:

Verification Information from End Users: To verify your identity, we may collect information such as your name, date of birth, scanned copies of your government issued identification card (e.g., license or passport), email address, phone number, mailing address, student ID number, and certain photographic images, and biometric data. You may also be asked to provide affiliations such as your school.
ID Card Information for End Users: To provide you with a digital ID card we may collect information such as your legal name, preferred name, student ID number, date of birth, certain photographic images, phone number, mailing address, and school affiliation.
Customer Information: Our customers are businesses and schools. We may collect information about our customers and the services they provide, including but not limited to student contact information, student ID numbers, and other information provided to us as part of our agreement and to fulfill our Service. We use this information to verify an End User’s identity and generate a digital ID card. When we do process student information on behalf of our customers, we comply with the Family Educational Rights and Privacy Act (“FERPA”).
Contact Information: Records and copies of your correspondence (including your name, contact information, email addresses, and any information you provide us), if you contact us directly or provide feedback on our Service directly to us.

Biometric data will only be collected and used to verify your identity. For more information, please see our BIOMETRIC INFORMATION PRIVACY POLICY.

‍Information We Collect Through Automatic Data Collection Technologies‍
As you navigate through and interact with our Service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns.

The information we collect automatically may not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. Automatic data collection helps us to improve our Service and to deliver better and more personalized services, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Service according to your individual interests.
Recognize you when you return to our Service.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Service. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Service.
Flash Cookies. Certain features of our Service may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons. Pages of our Service and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

‍2. HOW WE USE YOUR INFORMATION

DIVERG will not sell, rent, or trade your personal information. We will only transfer your personal information with your consent, to third parties to assist in verifying your identity or as required for the prevention of fraud or otherwise permitted by law.

We use information that we collect about you or that you provide to us, including any personal information:

To present our Service and its contents to you. This may include using the information collected about you to authenticate and manage your identity when you create an account, including to verify attributes of your identity such as school affiliation.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose for which you provide it.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Service or any products or services we offer or provide though it.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

3. HOW WE SHARE YOUR INFORMATION
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We do not share personal information with any third parties except in the limited circumstances described below:

We may share personal information to fulfill the purpose for which you provide it.
We may share personal information with your consent.
We may share your personal information with our subsidiaries and affiliates.
We may need to share or provide information including personal information to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
We may share your personal information with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Service is among the assets transferred.
We may share aggregated information about our users and information that does not identify any individual, without restriction.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our TERMS OF USE and any other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

4. YOUR CHOICES, RIGHTS, AND CONTROLS

You can exercise any of the rights described in this section consistent with applicable law by emailing privacy@diverg.com. The exact scope of these rights may vary by state.

In some states, applicable law may entitle you to:

Confirm whether we process your personal information.
Access and delete certain personal information.
Correct inaccuracies in your personal information, considering the information’s nature processing purpose.
Data portability.
Opt-out of personal data processing for: targeted advertising; sales; or profiling in furtherance of decisions that produce legal or similarly significant effects.
Either limit (opt-out of) or require consent to process sensitive personal data.

To appeal a decision regarding a consumer rights request, you may send an email to privacy@diverg.com.

‍Data Updating and Correcting Your Information
‍You may send us an email at privacy@diverg.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Residents of certain states may have additional personal information rights and choices.

5. HOW WE PROTECT YOUR INFORMATION

We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, destruction, use, modification, and disclosure.

To safeguard certain sensitive information (such as biometric information and government-issued identification information), we implement security measures such as encryption, firewalls, and intrusion detection and prevention systems.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Service. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in the Service.

6. HOW WE RETAIN YOUR INFORMATION

Personal information will be retained until we have fulfilled our legal, contractual, and policy obligations. We store your personal information for as long as needed or permitted, based on the reason why we obtained it. For more information on our retention policy for biometric information, please see our BIOMETRIC INFORMATION PRIVACY POLICY.

7. HOW WE TREAT INFORMATION FROM CHILDREN UNDER THE AGE OF THIRTEEN

Children’s Online Privacy Protection Act of 1998 (“COPPA”) requires us to inform parents and legal guardians (“parents”) about our practices for collecting, using, and disclosing personal information from children under the age of 13. Our Service is not directed to children under the age of 13. We do not knowingly collect personal or other information from anyone under the age of 13.

If we discover that we have collected information from a child in a manner inconsistent with COPPA, we will take appropriate steps to either delete the information, or immediately seek consent for that collection.

8. CHANGES TO OUR PRIVACY POLICY

We will post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat personal information, we will notify you through a notice on our home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting this Privacy Policy to check for any changes.

9. CONTACT INFORMATION

To ask questions or for more information about this Privacy Policy and our privacy practices, contact us at: privacy@diverg.com.

By mail:

Digital Verification Research Group, Inc.
399 Boylston St, FL 6
Boston, MA 02116