DRAFT — for review by a solicitor. This text has not yet been approved; it is governed by the law of England and Wales. Divvent will publish a final version and ask you to accept it.

Privacy policy

Version 1, in effect from 2026-09-28

1. Who we are

Divvent ([company form, number and registered office to be completed]) is the controller of the personal data this policy describes. Contact: privacy@divvent.co.uk.

This policy is about the people who use Divvent’s website and portal. The data inside a customer’s own Application is that customer’s, and their own privacy notice covers it; Divvent processes it only on their behalf, under the Data Processing Agreement.

2. What we collect

Account data: your name, email address, the company you belong to and your role in it.

Security data: a password hash, your passkeys’ public keys or your authenticator app’s secret, recovery codes (stored hashed), and your sessions.

Records: an audit record of what you do in the portal, with the time, your network address and your browser’s description of itself.

Your requests: the words of change requests you make, which may be sent to our AI provider.

Billing: the billing contact and invoices; card details go to Stripe, never to us.

The public website sets no cookies, runs no scripts and uses no analytics.

3. Why, and on what basis

To provide the service you or your company signed up for (contract). To keep it secure, prevent abuse and keep records of who did what (legitimate interests, and our legal obligations). To bill (contract, and legal obligations for tax records). To tell you about changes to these documents and the service (contract).

We do not sell personal data, and we do not use it to train AI models.

4. Who we share it with

Only our sub-processors, listed with what each does and where, and anyone the law requires us to.

5. How long we keep it

Account data for as long as you have an account, and ninety days after. Audit records for six years, holding your identifier rather than your address, so an erasure removes your address everywhere it is shown. Billing records for the period tax law requires.

6. Your rights

You may ask for a copy of your data, to correct it, to erase it, to restrict or object to its use, or to move it. Write to privacy@divvent.co.uk. You may also complain to the Information Commissioner’s Office (ico.org.uk).

7. Changes

We publish every version with its number and the day it takes effect, and ask you to acknowledge a material change.