Notice on Privacy and Personal Information

Divendary regards careful personal-information management as a fundamental responsibility. We handle data transparently, for defined purposes and in line with applicable obligations, including the UK GDPR. This notice explains what we collect, why we process it, how long we retain it and the protections we apply.

1. Parties responsible for your personal information

Under the UK GDPR, the website operator and the Divendary platform act as controllers of your personal information. Our legal notice provides the relevant contact details and additional information. You may also send privacy-related questions to our data protection officer.

2. Personal information we gather

We collect and use the information necessary to deliver the service, fulfil legal duties and protect the platform. This can include:

  • Identity details: your first name, surname and date of birth, used to verify who you are and confirm your age.
  • Contact details: your email address, any telephone number supplied, country of residence and, where applicable, postal address.
  • Account and payment records: payment information, deposit and withdrawal activity, and details connected with transactions.
  • Technical and usage data: IP address, browser and device information, login timestamps and network connection details.
  • Verification material: identity documents, address evidence and other information required for KYC/AML procedures where applicable.

We generally avoid collecting special-category data, including health information or religious beliefs, unless the law requires it or you have expressly authorised its use.

3. Where your information comes from

We may receive your information through a number of protected channels, including:

  • Details you submit: for example, when opening an account, changing your profile, uploading documents or contacting our team.
  • Data gathered automatically: including cookies, server logs, analytics information and technical data created as you interact with the platform.
  • Data supplied by other organisations: such as payment providers supporting deposits or withdrawals, KYC/AML screening partners and social-login services where you permit access.

4. Uses of personal information

Where relevant, we process personal information for specific and lawful purposes, including:

  • Opening, managing and supporting your account, together with the platform features available to you.
  • Handling and protecting payment operations, including money credited to or withdrawn from your account.
  • Offering suitable assistance and dealing with your questions, requests and reported problems.
  • Fulfilling legal and regulatory duties, including KYC, AML and tax requirements.
  • Protecting our systems and detecting or preventing fraud, misuse and attempted unauthorised access.
  • Improving the customer experience and developing platform features over time.
  • Sending service updates or marketing communications when you have opted to receive them.

5. Legal grounds for processing

  • Performing our agreement with you or taking requested steps before an agreement is made (Article 6(1)(b) UK GDPR).
  • Complying with statutory duties (Article 6(1)(c) UK GDPR), including anti-money-laundering requirements.
  • Pursuing legitimate interests (Article 6(1)(f) UK GDPR), such as platform security, service resilience and dependable operations.
  • Relying on your explicit consent (Article 6(1)(a) UK GDPR), for example for marketing or optional features.

6. Circumstances for sharing information

We disclose information only where necessary, to selected recipients and service providers such as:

  • Banks and payment providers that accept deposits or facilitate withdrawals.
  • Authorised specialist providers performing KYC and AML verification.
  • Cloud-hosting and technical suppliers working under appropriate data-processing agreements.
  • Analytics and information-security providers, using anonymised or pseudonymised data where reasonably possible.
  • Professional consultants, including legal and tax advisers, where legal or regulatory support is required.
  • Courts and public authorities where disclosure is required by law or needed to establish, pursue or defend legal claims.

We do not sell personal information or disclose it to third parties for their separate commercial purposes.

7. Transfers of information abroad

Certain suppliers, such as hosting or analytics providers, may be based outside the UK or European Economic Area. For international transfers, we apply recognised safeguards, including the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, binding corporate rules or an applicable adequacy decision, to preserve an appropriate level of protection.

8. Security measures for your information

We use a blend of technical measures and organisational controls to safeguard personal information:

  • Protected connections using current security protocols, including TLS 1.3 or a later version.
  • Strong encryption for sensitive data held in our systems, including AES-256 where appropriate.
  • Planned security reviews, penetration testing and assessments by independent specialists.
  • Continuous monitoring intended to flag unusual activity and attempted breaches.
  • Access rights assigned according to employees’ responsibilities and job requirements.
  • Client funds held in segregated accounts via regulated service providers.

No online service can eliminate every security threat; these measures are intended to reduce risks that can reasonably be foreseen.

9. Information retention periods

We retain personal information only for as long as necessary for the purposes described here or as the law requires:

  • For as long as your account and contractual relationship continue.
  • After closure, for the period required by applicable rules, which may be 5–10 years for tax or regulatory records.
  • Where consent provides the legal basis, such as marketing, until you revoke that consent.

Once data is no longer needed, we securely delete it or convert it into anonymous information.

10. Your rights under data protection law

Data protection legislation provides several rights concerning your personal information, including the right to:

  • Find out whether we hold or use personal information about you.
  • Ask us to correct incorrect information or fill in incomplete records.
  • Request erasure when there is no valid legal basis for continued retention.
  • Ask us to restrict processing in situations recognised by applicable law.
  • Receive your information in a structured, commonly used, machine-readable format so it can be transferred to another provider.
  • Revoke consent at any time where consent is the basis for processing.
  • Complain to the relevant data protection supervisory authority.

11. Cookies and similar technologies

Cookies and similar technologies allow the website to function, show us how visitors use it and guide service improvements. Essential cookies operate by default; analytics and advertising cookies are placed only with consent. Please see our separate cookie notice for more detail.

12. Changes to this privacy notice

This notice may be revised periodically to reflect changes in law, regulation or the platform. The latest version will appear on our website. If a change significantly affects you, we will contact you by email or display an alert within the platform.

13. Contacting us about privacy

For privacy questions, enquiries about this notice or requests concerning your rights, email $site_gmail or use our website contact form. Our data protection officer will review your request and seek to respond within a reasonable period.

By using Divendary, you acknowledge that you have read this notice and agree to its terms.