Privacy policy

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Privacy policy

Last update: January 2021.
DIVINE ("DIVINE") respects User’s privacy and is committed to protecting User’s personal information or, as otherwise termed, User’s "Personal Data". In that regard, DIVINE has launched and offers a service which provides people (the "Users") visit and donate on the web-site (the "Site") and in all pages on this domain (together, the,,,, and,,,, "mobile API"). User agree that User has read, understood and accepted all of the terms and conditions contained in Privacy Policy (the "Policy"), Agreement on Terms of Use and all policies and related notices which have incorporated the General Data Protection Regulation (Regulation (EU) 2016/679) (the "GDPR"). As this is a legally binding contract, please carefully read through this Policy and related notices before using any of the services provided by DIVINE or its affiliates (the "Services"). By using Services, User has agreed to the terms and conditions as laid out in this Policy. If User disagrees to this Policy, please inform DIVINE by all available methods (for existing Users) and stop the usage of DIVINE and any Services.
This Privacy Policy explains how information about User is collected, used, and disclosed by DIVINE and sets out the basis on which DIVINE will process User’s Personal Data when User:
• visits and uses the Site (regardless of where User visits or uses them from); and
• applies for, receives or uses any Services.
This includes any data that User may provide for and in relation to DIVINE’s or its affiliates newsletters, updates, events and other marketing and promotional communications.
This Privacy Policy also informs User about: (i) how DIVINE will handle and look after User’s personal data, (ii) DIVINE’s obligations in regard to processing User’s Personal Data responsibly and securely, (iii) User’s data protection rights as a data subject, and (iv) how the law protects User.
Purpose of this Privacy Notice
DIVINE processes User’s Personal Data in an appropriate and lawful manner, in accordance with the GDPR and UK legislation.
This Policy aims to give information on how DIVINE collects and processes User’s Personal Data in the scenarios outlined above in the ‘Introduction’ (namely, about User who uses the Site, including any data that User may provide to DIVINE or which DIVINE may receive).
The Site are not intended for minors and DIVINE does not knowingly collect Personal Data relating to minors.
It is important that User reads this Policy together with Agreement on Terms of Use and other binding DIVINE policies, notices, agreements and documents related to the Services which DIVINE may provide on specific occasions when DIVINE is collecting or processing Personal Data about User so that User is fully aware of how and why DIVINE is using User’s data. This Policy supplements the other notices and is not intended to override them.
Within DIVINE app, a feature allows users to share their current location in order for an App to calculate an estimate time left until a satellite reaches the user’s location. Once a satellite is positioned above the user’s location, a user will have access to information which is only available to read/download when a satellite is positioned above their current location.
DIVINE requests the consent of the user of the App to use his location and Divine uses information about the user's location only during the period of visiting the App
DIVINE as defined above is the controller and responsible for User’s personal data.
If User has any questions or requests, including any requests to exercise User’s legal rights as a data subject, please contact DIVINE using the details set out below.
Contact Details
Full name of legal entity: DIVINE
Email address: [email protected]
Postal address: 52A ST. OWEN STREET. HEREFORD HR1 2PU. UK
It is imperative that the Personal Data DIVINE holds about User is accurate and actual at all times. Otherwise, this will impair DIVINE’s ability to provide User with the availability of DIVINE’s Services (amongst other potential and salient issues). The User must inform DIVINE if User’s Personal Data changes during User’s relationship with DIVINE.
Third-Party Links
The Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about User. DIVINE does not control these third-party websites and are not responsible for their privacy notices, statements or policies.
DIVINE encourages User to read the privacy policy of every website User visits.
Set out below are key definitions of certain data protection terms which appear in this Policy.
"Consent Form" refers to separate documents which DIVINE might from time to time provide User with where DIVINE asks for User’s explicit consent for any processing which is not for purposes set out in this Policy.
"Data subjects" means living individuals (i.e. natural persons) about whom DIVINE collects and processes personal data.
"Data controller" or "controller" means any entity or individual who determines the purposes for which, and the manner in which, any Personal Data is processed.
"Data processor" or "processor" means any entity or individual that processes data on DIVINE`s behalf and with DIVINE’s instructions (DIVINE being the data controller).
"Personal data" means data relating to a living individual (i.e. natural person) who can be identified from the data (information) DIVINE holds or possesses. This includes, but is not limited to, User’s name and surname (including maiden name where applicable), address, date of birth, nationality, gender, civil status, tax status, identity card number & passport number, contact details (including mobile and home phone number and personal email address), photographic image, bank account details, emergency contact information as well as online identifiers. The term "personal information", where and when is used in this Privacy Policy, shall be taken the same meaning as personal data.
"Processing" means any activity that involves use of personal data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including, organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring Personal Data to third parties.
"Sensitive personal data", "sensitive data" or "special categories of personal data" includes information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. This type of sensitive data can only be processed under strict conditions.
Note that Personal Data does not include information relating to entities (for example, a company or other legal entity’s information). In that regard, information such as company name, its company number, registered address, VAT number and any other any other publicly available information do not amount to Personal Data in terms of the GDPR Act. Therefore, the collection and use of information strictly pertaining to a legal person does not give rise to data controller obligations at law. Naturally, DIVINE will still treat any and all such information in a confidential and secure manner.
Personal data, or personal information, means any information about an individual by which that person can be identified (as stated above). It does not include data where the identity has been removed (anonymous data). In the course of User’s relationship with DIVINE, DIVINE may collect, use, store and transfer different kinds of Personal Data about User which DIVINE has grouped together.
DIVINE collects information User provide directly to DIVINE. For example, DIVINE collects information when User participate in any interactive feature of the Services, fill out a form, participate in a community or forum discussion, request user support or otherwise communicate with DIVINE. The types of information DIVINE may collect include User’s name, social security number or other government ID number, date of birth, email address, postal address, phone number, certain virtual currency information, and any other information User chooses to provide.
DIVINE shall request this information in order to be able to Identify User on DIVINE web-site.
Identity Data includes User’s first name, maiden name (where applicable), last name, address, username or similar identifier, marital status, title, nationality, date of birth, gender, photograph, identity card and/or passport.
Contact Data includes User’s billing address, email address and contact number (telephone and/or mobile).
Financial Data includes User’s bank account and payment details.
Marketing and Communications Data includes User’s preferences in receiving marketing from DIVINE and DIVINE’s third parties and User’s communication preferences.
Transaction Data includes details about:
• the payments which DIVINE receives,
• In all cases, DIVINE collects the following information upon access to DIVINE’s Site:
Technical/LOG Data includes the IP address, User’s login data (username and password), device type, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and other technology on the devices User use to access the Site. This also includes information about User’s use of the Services, including the type of browser User uses, access times, pages viewed, User’s IP address, and the page User visited before navigating to DIVINE Services.
Device Data includes information about the computer or mobile device User uses to access DIVINE Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
Usage Data includes information about how User uses the Site.
DIVINE also collects, uses and shares Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from User’s Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal User’s identity. For example, DIVINE may aggregate User’s Usage Data to calculate the percentage of users accessing a specific feature of the Site. However, if DIVINE combines or connects Aggregated Data with User’s Personal Data so that it can directly or indirectly identifies User, DIVINE treats the combined data as Personal Data which will be used in accordance with this Policy.
If User fail to provide Personal Data
Where DIVINE needs to collect Personal Data about User:
• By law; or
• under the terms of, or in connection with, the contract that DIVINE has with User (as discussed in Section 1 above); or
• as part of DIVINE legitimate (business) interests to verify the identity of DIVINE applicants and Users, mitigate against risks (such as potential or suspected fraud) and in particular, to assess and take a decision on whether DIVINE will or should enter into a relationship with User (as subject to User acceptance criteria and policies);
and User either fail to provide that data when requested, or else provide incomplete or insufficient data, DIVINE may not be able to perform or conclude the contract which DIVINE has or is otherwise trying to enter into with User.
In certain instances, DIVINE may to exercise DIVINE prerogative to terminate DIVINE contract with User, and thus withdraw the availability of DIVINE Services to User, or else, if still at application stage, DIVINE may have to decline to enter into a relationship with User. DIVINE will however notify User if this is the case at that point in time.
Sensitive Personal Data
DIVINE does not knowingly collect Special Categories of Personal Data (or Sensitive Personal Data) about User. Should DIVINE receive sensitive Personal Data about User, DIVINE will only process that data where there is a legitimate reason to do so and, in all circumstances, in accordance with DIVINE obligations at law and under the appropriate safeguards.
(A) Direct Interactions.
User mays also give DIVINE User’s Identity, Contact, Financial by filling in DIVINE other forms (i.e. separate to DIVINE donate form), or by corresponding with DIVINE by post, phone, e-mail or otherwise. This includes Personal Data that User provides when User, as applicable:
• subscribes to DIVINE site;
• donate;
• contacts DIVINE with complaints or queries;
• reports issues;
• requests marketing to be sent to User;
• participates in a survey; or
• provides DIVINE with feedback.
(B) Automated Technologies or Interactions.
As User interact with the Site, DIVINE may automatically collect Technical Data about User’s equipment, browsing actions and patterns. DIVINE collects this Personal Data by using cookies, server logs and other similar technologies.
Cookies are small data files stored on User’s hard drive or in device memory that helps DIVINE improve DIVINE Services and User’s experience, see which areas and features of DIVINE Services are popular and count visits, remember User’s site preferences, and retain information to provide User with support. Web beacons are electronic images that may be used on DIVINE site or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness.
Most web browsers are set to accept cookies by default. If User prefer, User could usually choose to set User’s browser to remove or reject browser cookies. Please note that choosing to remove or reject cookies could affect the availability and functionality of DIVINE Services.
Please see DIVINE’s Cookie Policy for further details on website
(C) Third Parties or Publicly Available Sources.
DIVINE may also obtain information from other sources and combine that with information DIVINE collects through DIVINE Services. For example, DIVINE may collect information about User from third parties, including but not limited to social media platforms and publicly available sources.
DIVINE may also receive Personal Data about User from various third parties and public sources, as set out below:
Technical Data from the following parties:
○ analytic providers such as Google Analytics;
○ advertising networks;
○ search information providers.
DIVINE will only use User’s Personal Data when UK legislation and International Acts allow DIVINE to. Most commonly, DIVINE will use User’s Personal Data in the following circumstances:
• Where DIVINE needs to perform the contract DIVINE is about to enter into or has entered into with User in respect of User’s relationship with DIVINE.
• Where it is necessary for DIVINE legitimate interests (or those of a third party) and User’s interests and fundamental rights do not override those interests.
• Where DIVINE needs to comply with a legal or regulatory obligation. Purposes for which DIVINE will use User’s Personal Data
DIVINE makes sure DIVINE considers and balances any potential impact on User (both positive and negative) and User’s rights before DIVINE processes User’s Personal Data for DIVINE legitimate interests. DIVINE does not use User’s Personal Data for activities where DIVINE interests are overridden by the impact on User (unless DIVINE has User`s consent or is otherwise required or permitted to by UK legislation and International Acts).
User may receive marketing communications from DIVINE (which may consist of newsletters, industry updates, mailshots, publications, promotional materials and/or information about DIVINE events) where:
User provides User’s consent to receiving such marketing material; or
User has an ongoing commercial or contractual relationship with DIVINE (e.g. where DIVINE considers User to be an active User of the site); and
• provided User has not opted out of receiving marketing from DIVINE.
Third-Party Marketing
DIVINE will get User’s express opt-in consent before DIVINE shares User’s Personal Data with any third parties (including DIVINE associated or related corporate entities) for marketing purposes.
Opting Out
User can ask DIVINE to stop sending such advertising and marketing communications at any time by:
• following the opt-out links on any marketing messages sent to User;
• contacting DIVINE at any time at [email protected].
Where User opt out of receiving such communications, this will not apply to Personal Data processed or provided to DIVINE as a result of User’s entry into relationship with DIVINE.
Change of Purpose
DIVINE will only use User’s Personal Data for the purposes for which DIVINE collected it, unless DIVINE reasonably considers that DIVINE needs to use it for another reason and that reason is compatible with the original purpose, or DIVINE is obliged to process User’s data by UK legislation or court or other enforceable orders.
Please note that DIVINE may process User’s Personal Data without the need to obtain User’s consent, in compliance with the above rules, where this is required or permitted by UK legislation and International Acts.
DIVINE may have to share User’s Personal Data with the parties set out below.
• External third parties.
• Suppliers and external agencies that DIVINE engages to process information on DIVINE and/or User’s behalf, including to provide User with the information and/or materials that User has requested.
• Our subsidiaries, associates and agents where necessary to facilitate User’s relationship with DIVINE.
• The regulators, law enforcement agencies and other authorities who require reporting of processing activities, or may request information from DIVINE, in terms of UK legislation and in certain circumstances.
• Professional advisers such as consultants, bankers, professional indemnity insurers, brokers and auditors.
• Other organizations where exchange of information is for the purpose of fraud protection or credit risk reduction.
• Debt recovery agencies who assist DIVINE with the recovery of debts owed to DIVINE.
• Third parties to whom DIVINE may choose to sell, transfer, or merge parts of DIVINE business or DIVINE assets (successors in title). Alternatively, DIVINE may seek to acquire other businesses or merge with them. If a change happens to DIVINE business, then the new owners may use User’s Personal Data in the same way as set out in this notice.
DIVINE requires all third parties to respect the security of User’s Personal Data and to treat it in accordance with the UK legislation and International Acts (including applicable data protection). DIVINE does not allow DIVINE third party business partners or service providers to use User’s Personal Data for their own purposes and only permit them to process User’s Personal Data for specified purposes and in accordance with DIVINE documented instructions. Furthermore, these third parties access and process User’s Personal Data on the basis of strict confidentiality and subject to the appropriate security measures and safeguards.
DIVINE may also disclose User’s Personal Data:
• If DIVINE is under a duty to disclose or share User’s Personal Data to comply with any legal obligation, judgment or under an order from a court, tribunal or authority, or
• If DIVINE believes User’s actions are inconsistent with DIVINE user agreements or policies, or to protect the rights, property and safety of DIVINE or others, or
• in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of DIVINE business by another company; or
• if DIVINE has User’s consent or at User’s direction. DIVINE may also share aggregated or de-identified information, which cannot reasonably be used to identify User.
User consents to the transfer of data to entities outside the European Economic Area ("EEA") including, and acknowledges such transfers, which will only take place for the purposes set forth in Section 5, are necessary for the performance of a contract between the data subject and the controller or the implementation of pre-contractual measures taken at the data subject's request. Such transfers may take place to countries for which there is no adequate decision pursuant to Article 45 of the GDPR and may lack EU-type privacy protections.
While no online or electronic system is guaranteed to be secure, DIVINE takes reasonable measures to help protect information about User from loss, theft, misuse, and unauthorized access, disclosure, alteration and destruction.
DIVINE has put in place appropriate security measures to prevent User’s Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, DIVINE limits access to User’s Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process User’s Personal Data on DIVINE instructions and they are subject to a duty of confidentiality.
DIVINE has put in place procedures to deal with any suspected Personal Data breach and will notify User and any applicable regulator of a breach where DIVINE is legally required to do so.
"Confidential Information" means any non-public information of the discloser, whether of a financial, business or other nature (including, but not limited to, trade secrets, and information relating to the Users, business plans, promotional and marketing activities, IT, finances and other business affairs of the discloser) that is disclosed to or obtained by the recipient and that the recipient knows or has reason to know is confidential, proprietary or trade secret information of discloser. Confidential Information also includes any information that has been made available to discloser by third parties that discloser is obligated to keep confidential. Confidential Information does not include any information that:
(a) was known to the recipient before receiving the same from the discloser in connection with this Policy;
(b) is independently developed by the recipient without reliance on any Confidential Information of the discloser;
(c) is acquired by the recipient from another source without restriction as to use or disclosure; or
(d) is or becomes generally known to the public through no fault or action of the recipient.
Each party guarantees:
(a) use the other's Confidential Information solely for the purposes of performing this Policy,
(b) disclose the other party’s Confidential Information only to those employees and contractors that need to know the same for purposes of performing this Policy, and
(c) inform its employees and contractors with access to the other party’s Confidential Information that such Confidential Information is confidential and proprietary to the other party and is subject to this Policy.
DIVINE and User will preserve and protect each other`s Confidential Information and will not divert or misappropriate any Confidential Information for its own or any third party’s benefit. Without limiting the generality of the foregoing, DIVINE and User will keep Confidential Information confidential and accessible and use restrictions at least as stringent as those applied to protect its own information of similar type
How long will use my Personal Data for?
Please note that DIVINE considers DIVINE relationship with User to be an ongoing and continuous User relationship, until terminated.
DIVINE will only retain User’s Personal Data for as long as necessary to fulfill the purposes DIVINE collected it for (i.e. the ongoing service provision) and, thereafter, for the purpose of satisfying any legal, accounting, tax and reporting requirements or obligations to which DIVINE may be subject and/or to the extent that DIVINE may also need to retain User’s Personal Data to be able to assert, exercise or defend possible future legal claims against or otherwise involving User.
By and large, DIVINE retention of User’s Personal Data shall not exceed the period of five (5) years from the date of the termination of User’s relationship with DIVINE. This period of retention enables DIVINE to use the data in question for the possible filing, exercise or defense of legal claims.
In some circumstances, User can ask DIVINE to delete User’s Personal Data. See below for further information.
Kindly, contact DIVINE for further details about the retention periods that DIVINE applies.
Data Minimization
Whenever and to the extent possible, DIVINE anonymous data which DIVINE holds about User when it is no longer necessary to identify User from the data which DIVINE holds about User (anonymous data).
In some circumstances, DIVINE may even anonymize User’s Personal Data (so that it can no longer be associated with User) for research or statistical purposes, in which case DIVINE may use this information indefinitely without further notice.
Under certain circumstances, User has rights under data protection laws in relation to User’s Personal Dataaccording with UK legislation and International Acts.
• Request access to User’s Personal Data.
• Request correction of User’s Personal Data.
• Request erasure of User’s Personal Data.
• Object to processing of User’s Personal Data.
• Request restriction of processing User’s Personal Data.
• Request transfer of User’s Personal Data.
• Right to withdraw consent.
If User wish to exercise any of the rights set out above, please contact DIVINE at [email protected]. These rights are explained below.
No Fee usually required
User will not normally have to pay a fee to exercise User’s Personal Data subject rights.
However, DIVINE may charge a reasonable fee if User’s request is clearly unfounded, repetitive or excessive. Alternatively, DIVINE may refuse to comply with User’s request in the above circumstances.
What DIVINE may need from User
DIVINE may need to request specific information from User to help DIVINE confirm User’s identity and ensure User’s right to access User’s Personal Data (or to exercise any of User’s other data subject rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. DIVINE may also contact User to ask for further information in relation to User’s request to speed up DIVINE response.
Time limit to Respond
DIVINE tries to respond to all legitimate requests within the period of one month from receipt of the request.
Occasionally it may take DIVINE longer than a month if User’s request is particularly complex or User has made a number of requests. In this case, DIVINE will notify User and keep User updated. User’s Legal Rights
User has the right to:
1. Request access to User’s Personal Data (commonly known as a "data subject access request"). This enables User to receive a copy of the Personal Data DIVINE holds about User and to check that DIVINE is lawfully processing it. User may send an email to [email protected] requesting information how the Personal Data is processed by DIVINE. User shall receive one copy free of charge via email of the Personal Data which is undergoing processing. Any further copies of the information processed may incur a charge of € 30.00.
2. Right to information when collecting and processing Personal Data about User from publicly accessible or third party sources. When this take places, DIVINE will inform User, within a reasonable and practicable timeframe, about the third party or publicly accessible source from which DIVINE has collected User’s Personal Data.
3. Request correction or rectification of the Personal Data that DIVINE holds about User. This enables User to have any incomplete or inaccurate data DIVINE holds about User corrected and/or updated, though DIVINE may need to verify the accuracy of the new data User provide to DIVINE. As mentioned, it is in User’s interest to keep DIVINE informed of any changes or updates to User’s Personal Data which occur during the course of User’s relationship with DIVINE.
4. Request erasure of User’s Personal Data. This enables User to ask DIVINE to delete or remove Personal Data where:
○ there is no good reason for DIVINE continuing to process it;
User has successfully exercised User’s right to object to processing (see below);
DIVINE may have processed User’s information unlawfully; or o DIVINE is required to erase User’s Personal Data to comply with UK legislation. Note, however, that DIVINE may not always be able to comply with User’s request of erasure for specific legal reasons which will be notified to User, if applicable, at the time of User’s request. These may include instances where continued processing is necessary in order to be able to:
○ comply with a legal or regulatory obligation to which DIVINE is subject; or
○ file, exercise or defense of legal claims.
5. Object to processing of User’s Personal Data where DIVINE is relying on a legitimate interest (or those of a third party) and there is something about User’s particular situation which makes User want to object to processing on this ground as User feel it impacts User’s fundamental rights and freedoms. User also has the right to object where DIVINE is processing User’s Personal Data for direct marketing purposes (see Marketing in Section 5 above).
In some cases, DIVINE may demonstrate that DIVINE has compelling legitimate grounds to process User’s information which overrides User’s rights and freedoms.
6. Request restriction of processing of User’s Personal Data. This enables User to ask DIVINE to suspend the processing of User’s Personal Data in the following scenarios:
○ if User want DIVINE to establish the data's accuracy;
○ where DIVINE uses of the data is unlawful but User do not want DIVINE to erase it;
○ where User needs DIVINE to hold the data even if DIVINE no longer requires it as User need it to establish, exercise or defend legal claims; or
User has objected to DIVINE use of User’s data but DIVINE needs to verify whether DIVINE has overriding legitimate grounds to use it.
7. Request the transfer (data portability) of User’s Personal Data to User or to a third party. DIVINE will provide User, or a third party User has chosen, with User’s Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which User initially provided consent for DIVINE to use or where DIVINE used the information to perform a contract with User in accordance with Policy together with Agreement on Terms of Use and other binding DIVINE policies, notices, agreements and documents related to the Services.
8. Withdraw consent at any time where DIVINE is relying on consent to process User’s Personal Data (which will not generally be the case). This will not however affect the lawfulness of any processing which DIVINE carried out before User withdrew User’s consent. Any processing activities that are not based on User’s consent will remain unaffected.
Kindly, note that none of these data subject rights are absolute, and must generally be weighed against DIVINE own legal obligations and legitimate interests. If a decision is taken to override User’s data subject request, User will be informed of this by DIVINE data protection team along with the reasons for DIVINE decision.
DIVINE may change this Policy or another information from time to time, particularly where DIVINE needs to take into account and cater for any (i) business developments and/or (ii) legal or regulatory developments. If DIVINE makes changes, DIVINE will notify User by revising the date at the top of the Policy and, in some cases, DIVINE may provide User with additional notice (such as adding a statement to DIVINE homepage or sending User notification). DIVINE encourages User to review the Privacy Policy whenever User access the Services or otherwise interact with DIVINE to stay informed about DIVINE information practices and the ways User can help protect User’s privacy.
The language of the original documents is English.