Privacy Policy
Introduction
This Privacy Policy explains how Dialog Intelligens ApS (“Diverge”, “we”, “us”, “our”, “the Company”) collects, uses, and shares information when you access or use our services, including our platform, APIs, AI development tools, and other services we provide (collectively, the “Services”).
We are committed to protecting your personal data and to processing it in a lawful, fair, and transparent manner. This policy applies to personal data collected through the chatbot interface on this website. Please read it carefully before using the chatbot.
Roles and Responsibilities
Data Controller and Data Processor: The legal entity that owns and operates this website (“the Company”). The Company is responsible for determining how and why your personal data is processed, in accordance with a written data processing agreement. Contact details for the Company are available at the bottom of the page.
Personal Data We Process
We process the information you choose to share in the chatbot, which may include:
Text messages that you enter in the chat.
Optional contact details that you provide, such as name, email address, phone number, or account information.
Order numbers or similar identifiers if you ask about order status or delivery.
We also automatically collect certain technical data when you use the chatbot:
IP address and approximate geographic location (country/region level).
Session identifiers and timestamps of interactions.
Browser type, operating system, and device type.
Referring URL and pages visited on this website.
The chatbot is not intended to be used for sharing special categories of personal data (for example information about health, religion or trade union membership). If you nevertheless choose to provide such information, it will be handled with the same level of protection and only in accordance with this privacy policy.
Purpose and Legal Basis
We process your personal data for the following purposes, each with its corresponding legal basis under GDPR Article 6:
Responding to your questions and requests in the chatbot.
Legal basis: Legitimate interests (Article 6(1)(f)) — the Company’s interest in providing effective customer service. Where you have provided contact details in order to receive a specific response, processing may additionally be based on steps taken at your request prior to entering a contract (Article 6(1)(b)).
Providing and improving customer service and chatbot quality.
Legal basis: Legitimate interests (Article 6(1)(f)) — the Company’s interest in maintaining and improving its digital services.
Monitoring the stability, performance and security of the chatbot service.
Legal basis: Legitimate interests (Article 6(1)(f)) — the Company’s interest in operating a secure and reliable service.
Security, fraud prevention, and compliance with internal policies.
We process technical data (such as IP addresses and session logs) to detect and prevent abuse, unauthorised access, and fraudulent activity, and to maintain audit trails in line with our internal security policies. Legal basis: Legitimate interests (Article 6(1)(f)) — the Company’s interest in protecting the security and integrity of its systems and users.
Compliance with legal obligations.
We may process and retain personal data to the extent required to comply with applicable laws and regulations, including data protection law, tax and financial record-keeping obligations, and responses to lawful requests from competent authorities (such as courts or regulators). Legal basis: Compliance with a legal obligation (Article 6(1)(c) GDPR).
Providing the chatbot service to end users on behalf of the Company.
The Company processes personal data as a data processor acting on the instructions of the Company. The underlying purpose is to deliver a functioning, reliable, and personalised chatbot experience to users of this website — including routing messages, generating responses, and maintaining session continuity during a conversation. Legal basis: Legitimate interests (Article 6(1)(f)) — the Company’s interest in delivering a digital service to its customers. Where the chatbot interaction is directly connected to a contractual relationship between the user and the Company (for example, handling an order query), processing may also be based on Article 6(1)(b).
Use of AI and Infrastructure
Chat messages are processed on Dialog Intelligens systems hosted within the European Union. To generate chatbot replies, Dialog Intelligens may use carefully selected AI service providers acting as sub-processors under written data processing agreements and strict technical safeguards.
Your data is processed solely for the purpose of generating and improving chatbot replies, and only the information necessary to fulfil your request is used.
A current list of sub-processors used by Dialog Intelligens is available upon request by contacting team@dialogintelligens.dk. We will notify you of any material changes to our sub-processor arrangements in advance where required by law.
International Data Transfers
Dialog Intelligens’ infrastructure is hosted within the European Economic Area (EEA). However, some of the AI sub-processors used to generate chatbot responses may be based outside the EEA, including in the United States.
Where personal data is transferred to a country not covered by an EU adequacy decision, we ensure appropriate safeguards are in place, including:
Standard Contractual Clauses (SCCs) approved by the European Commission.
Supplementary technical measures where required, such as encryption and data minimisation.
You may request further information about the specific transfer mechanisms in place by contacting us at the details in Section 13 below.
Automated Decision-Making and Profiling
The chatbot uses AI to generate responses to your messages. This processing is automated in nature; however, it does not produce legal effects concerning you or similarly significantly affect you.
We do not use chatbot interactions to make automated decisions about you that have legal or similarly significant consequences, such as decisions about credit, employment, or access to services.
Cookies and Tracking
The chatbot may use cookies or similar technologies, such as session tokens and local storage, to maintain your session and ensure the service functions correctly. Cookies that are strictly necessary for the operation of the service are used regardless of your cookie preferences, as the chatbot cannot function without them.
Where you decline non-essential cookies, the chatbot will remain accessible, but certain non-essential features may be unavailable. In some configurations, the chatbot may also use non-essential third-party cookies; these will only be placed if you have provided your explicit consent.
Children's Privacy
This chatbot service is not directed at children under the age of 16. We do not knowingly collect personal data from children under 16 without verifiable parental consent.
If you are a parent or guardian and believe that a child under 16 has provided personal data through the chatbot without your consent, please contact us using the details in Section 13. We will take steps to delete the data as soon as reasonably practicable.
Security
We apply appropriate technical and organisational measures to protect your personal data, including:
Encryption of data in transit (TLS) and at rest where relevant.
Access controls limiting data access to authorised personnel only.
Audit logging of access to chatbot data.
Secure hosting in professionally managed data centres within the EU.
Regular review of security measures and data processing arrangements.
Access to chatbot data is restricted to authorised personnel who need it to operate, support or improve the service. Dialog Intelligens is subject to binding confidentiality obligations in relation to your data.
Data Retention
We retain personal data only for as long as necessary for the purposes for which it was collected:
Chat conversation data (messages and metadata): up to 12 months from the date of the conversation, unless the Company instructs a shorter retention period.
Contact details provided in chat (name, email, phone): retained for the same period as the related conversation, or as required to respond to your enquiry.
Technical data (IP address, session identifiers): up to 12 months, or as required for security and fraud prevention purposes.
After the applicable retention period, data is deleted or irreversibly anonymised. Aggregated statistics that contain no personal data may be retained indefinitely for analytical purposes.
In some cases we may be required to retain data for longer periods to comply with legal obligations (for example, if data forms part of a legal claim or regulatory investigation).
Your Rights
Subject to applicable law, you have the following rights in relation to your personal data:
Right of access — to obtain confirmation and a copy of the personal data we process about you (Article 15 GDPR).
Right to rectification — to have inaccurate or incomplete personal data corrected (Article 16 GDPR).
Right to erasure — to request deletion of your personal data in certain circumstances, for example where it is no longer necessary for the purpose for which it was collected (Article 17 GDPR).
Right to restriction — to request that processing of your personal data is restricted in certain circumstances, for example while the accuracy of data is contested (Article 18 GDPR).
Right to data portability — to receive your personal data in a structured, commonly used and machine-readable format where processing is based on consent or contract and carried out by automated means (Article 20 GDPR).
Right to object — to object to processing based on legitimate interests, on grounds relating to your particular situation. We must stop processing unless we can demonstrate compelling legitimate grounds that override your interests (Article 21 GDPR).
Right to withdraw consent — where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
Right to lodge a complaint — you have the right to lodge a complaint with a supervisory authority if you believe your data has been processed unlawfully. In Denmark, the supervisory authority is Datatilsynet (www.datatilsynet.dk). If the Company is based in another EU/EEA member state, you may also contact that country’s national data protection authority.
We will respond to requests to exercise your rights within 30 days of receipt. This period may be extended by a further 60 days where requests are complex or numerous, in which case we will inform you within the first 30 days.
13. Contact and Exercising Your Rights
If you have questions about this privacy policy or wish to exercise any of your rights, you can contact:
Dialog Intelligens ApS (“Diverge”)
Vestergade 12, 3. sal, 1456 København K
Email: team@dialogintelligens.dk
When contacting us to exercise a right, please include enough information to identify your request (for example, the approximate date and time of your chatbot conversation). We may need to verify your identity before processing your request.
14. Changes to this Policy
We may update this privacy policy from time to time, including changes to how the chatbot works or to comply with new legal requirements. The current version, together with its effective date, will always be available on this website.
Where changes are material, we will take reasonable steps to bring them to your attention, for example by displaying a notice in the chatbot or on the website.
