Privacy Policy

Last Updated: May 2026

1. Introduction

D2I0A2M5O Inc., doing business as DIAMO (“DIAMO,” “we,” “us,” or “our”), provides software and digital marketing services to independent hotels, including a pricing engine, search engine marketing (SEM), metasearch and online travel agency (OTA) advertising management, OTA distribution support, website creation, and booking engine services (collectively, the “Services”).

This Privacy Policy describes how DIAMO collects, uses, discloses, and otherwise processes personal information in connection with our website at diamo.ai (the “Site”) and our Services. It applies to personal information we process as a controller—meaning when we determine the purposes and means of processing—such as information about our website visitors, prospects, customers, and the personnel of our hotel customers.

Separately, DIAMO acts as a service provider or processor on behalf of our hotel customers when we operate their websites, booking engines, advertising campaigns, and distribution channels. When we process personal information in that capacity, our customers (the hotels) are the controllers of that information, their own privacy policies govern, and our processing is governed by our agreements with them. Section 11 explains this in more detail.

2. Information We Collect

We collect the following categories of personal information:

2.1. Information You Provide to Us

Contact and demo request information: When you submit a demo request, contact form, or otherwise reach out to us, we collect your name, business email address, phone number, company name, job title, and any information you choose to include in your message.
Account information: If you become a DIAMO customer, we collect information needed to set up and administer your account, including the names, business contact details, and login credentials of authorized users at your hotel.
Billing information: We collect billing contact details and information necessary to invoice and collect payment from customers. Payment card data is processed by our third-party payment processor; we do not store full card numbers on our systems.
Communications: When you communicate with us by email, phone, support ticket, or other means, we collect the content of those communications and related metadata.
Marketing preferences: Your subscription preferences for our newsletters, product updates, and marketing communications.

2.2. Information Collected Automatically

When you visit our Site, we and our service providers automatically collect certain information about your device and browsing activity, including:

IP address and approximate location derived from it
Device, browser, and operating system information
Pages visited, links clicked, referring URL, and time spent on the Site
Cookie identifiers and similar online identifiers

We use Google Analytics to understand how visitors use our Site. Google Analytics uses cookies and similar technologies to collect information about your use of the Site. You can learn more about Google Analytics at https://policies.google.com/privacy/partners and opt out using the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout.

Section 5 describes our use of cookies and your choices in more detail.

2.3. Information from Third Parties

We may receive information about you from third parties, including:

Business contact databases and lead enrichment services we use for sales and marketing
Publicly available sources such as company websites and professional networking sites
Referrals from our customers, partners, or other DIAMO contacts

3. How We Use Personal Information

We use personal information for the following purposes:

Providing the Services: To establish and administer customer accounts, deliver the Services, process transactions, and provide customer support.
Sales and marketing: To respond to demo requests and inquiries, send marketing communications about DIAMO and our Services, measure the effectiveness of our marketing, and develop new business opportunities. You can opt out of marketing communications at any time (see Section 7).
Site operation and improvement: To operate, maintain, secure, and improve our Site and Services, including through analytics.
Communications: To respond to your inquiries, send service-related notices, and communicate with you about your account or transactions.
Legal and compliance: To comply with applicable laws, respond to lawful requests from public authorities, enforce our agreements, protect our rights and the rights of others, prevent fraud, and ensure the security of our systems.
Business operations: For internal business purposes such as financial management, audits, corporate governance, and evaluating potential transactions (such as a merger, acquisition, financing, or asset sale).

Legal bases (EEA/UK): If you are located in the European Economic Area or the United Kingdom, our legal bases for processing your personal information are: (i) performance of a contract with you or your employer; (ii) our legitimate interests in operating and growing our business, marketing our Services, and ensuring the security of our systems; (iii) your consent, where required (for example, for certain cookies or marketing communications); and (iv) compliance with our legal obligations.

4. How We Share Personal Information

We share personal information in the following circumstances:

Service providers and sub-processors: We share personal information with third-party vendors who provide services on our behalf, including:
- Cloud hosting and infrastructure providers (including Google Cloud Platform and Amazon Web Services)
- Customer relationship management and marketing automation providers
- Payment processing providers
- Analytics providers
- Communications, email, and customer support providers
- Professional advisors (such as accountants, auditors, and lawyers)

These service providers are contractually required to use personal information only for the purposes we direct and to maintain appropriate safeguards.

Advertising platforms (when acting on behalf of customers): When we execute SEM, metasearch, and OTA advertising campaigns on behalf of our hotel customers, we share campaign data and parameters with advertising platforms such as Google, Bing, metasearch providers, and OTAs. Conversion tracking associated with these campaigns may involve the collection of online identifiers (such as cookie IDs, device identifiers, and IP addresses) from consumers who interact with the ads. This activity is conducted at the direction of our hotel customers; the relevant hotel is the controller of that information, and the consumer’s relationship with respect to that data is with the hotel and the advertising platform.
Business transfers: We may share personal information in connection with a merger, acquisition, financing, reorganization, bankruptcy, sale of all or part of our assets, or similar transaction. We will notify affected individuals as required by applicable law.
Legal compliance and protection: We may disclose personal information if we believe in good faith that disclosure is necessary to (i) comply with applicable law or legal process; (ii) respond to lawful requests from public authorities; (iii) enforce our agreements; (iv) protect the rights, property, or safety of DIAMO, our customers, or others; or (v) detect, prevent, or address fraud, security, or technical issues.
With your consent: We may share personal information for other purposes with your consent or at your direction.

Sale of personal information: DIAMO does not sell personal information for monetary consideration. Certain disclosures we make to advertising platforms in the course of executing ad campaigns may be considered “sales” or “sharing” under some U.S. state privacy laws (for example, the CCPA as amended by the CPRA). See Section 9 for U.S. state rights, including how to opt out.

5. Cookies and Similar Technologies

We and our service providers use cookies and similar technologies (such as pixels, web beacons, and local storage) on our Site to operate the Site, remember your preferences, analyze usage, and measure marketing effectiveness.

Most browsers allow you to refuse or delete cookies through your browser settings. If you disable cookies, some features of the Site may not function properly. You can also opt out of Google Analytics using the link in Section 2.2.

6. International Data Transfers

DIAMO is headquartered in the United States, and our service providers are located in various countries. When we transfer personal information from the European Economic Area, the United Kingdom,Switzerland, or other jurisdictions to a country that has not been deemed toprovide an adequate level of protection, we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum, where required by law.

7. Your Choices

Marketing communications: You can opt out of marketing emails by clicking the “unsubscribe” link in any marketing email we send or by contacting us at the address in Section 16. Even if you opt out of marketing emails, we may still send you transactional or service-related communications.
Cookies: You can manage cookies through your browser settings and through any cookie preferences tool we make available on the Site.
Do Not Track: Our Site does not respond to “Do Not Track” signals. We do, however, treat Global Privacy Control (GPC) signals as a valid request to opt out of “sale” or “sharing” for visitors in U.S. states where the GPC is recognized.

8. Rights of Individuals in the EEA, UK, and Switzerland

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the following rights with respect to your personal information, subject to applicable law:

Access to your personal information
Correction of inaccurate or incomplete personal information
Erasure of your personal information in certain circumstances
Restriction of processing in certain circumstances
Objection to processing based on our legitimate interests
Data portability, where applicable
Withdrawal of consent where processing is based on consent (without affecting prior processing)
Lodging a complaint with your local supervisory authority

To exercise any of these rights, contact us using the information in Section 16. We may need to verify your identity before responding.

9. U.S. State Privacy Rights

If you are a resident of California, Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, or another U.S. state with a comprehensive privacy law, you may have the following rights, subject to certain exceptions:

Right to know or access the personal information we have collected about you
Right to delete personal information we have collected about you
Right to correct inaccurate personal information
Right to data portability
Right to opt out of the “sale” or “sharing” of personal information and of targeted advertising
Right to limit the use and disclosure of sensitive personal information (we do not currently use or disclose sensitive personal information for purposes that would trigger this right)
Right to non-discrimination for exercising these rights

To exercise these rights, contact us at the email address in Section 16. We will verify your request before responding. You may also designate an authorized agent to make a request on your behalf.

Appeals: If we deny your request, you may appeal our decision by replying to our response or contacting us at the email address in Section 16.

California “Shine the Light”: California residents may request information about the categories of personal information we disclosed to third parties for their direct marketing purposes during the prior calendar year. DIAMO does not disclose personal information to third parties for their own direct marketing purposes.

10. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, including to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. When personal information is no longer needed, we will delete it or de-identify it.

11. Customer Data Processed on Behalf of Our Customers

When DIAMO operates customer websites, booking engines, advertising campaigns, or distribution channels on behalf of our hotel customers, we may process personal information about the hotel’s own end users (such as the hotel’s prospective or actual guests) at the direction of, and on behalf of, the hotel.

In these cases, the hotel is the controller of the personal information, and its privacy policy governs that processing. DIAMO acts as a service provider or processor, processing the information only as instructed by the hotel and as permitted by our agreement with the hotel.

If you are a guest or website visitor of one of our hotel customers and have questions about how your personal information is processed, please contact the hotel directly. If you contact us, we may forward your request to the relevant hotel.

12. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, and destruction. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.

13. Children

Our Site and Services are directed to businesses and are not intended for children under the age of 16. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will take steps to delete it.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the “Last Updated” date at the top of this Policy and, where required by applicable law, provide additional notice. Your continued use of the Site or Services after the updated Policy takes effect constitutes your acceptance of the updated Policy.

15. Terms of Service

This Privacy Policy is incorporated by reference into the DIAMO Terms of Service (the “Terms”). Capitalized terms not defined in this Privacy Policy have the meanings given in the Terms.

16. Contact Us

If you have any questions or requests about this Privacy Policy or our privacy practices, please contact us at:

D2I0A2M5O Inc. (DBA DIAMO)

New York, NY

Email: Info@diamo.ai