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Effective: 21 May 2025
DiviGain (hereinafter referred to as “we,” “us,” or “our”) values your privacy and is committed to protecting your personal and financial information. Whether you interact with us directly as an individual investor, through an investment professional, or via employer-provided services, we recognize your trust and aim to safeguard your data responsibly. This Privacy Policy outlines the types of personal data we collect, how we use it, your rights, and the safeguards we implement to ensure its protection.
This Privacy Policy applies to users who engage with DiviGain’s investment services (hereinafter referred to as “Services”). It governs the processing of personal data collected through our website, applications, and other service platforms. Our commitments to customers and service providers may be further outlined in separate agreements, including our Data Protection Addendum and Terms of Service at www.divigain.com/legal.
At DiviGain, we are committed to safeguarding user privacy and ensuring responsible data practices. Our core privacy principles include:
3.1.No Targeted Advertising
We do not use personal data for advertising purposes, ensuring a distraction-free and privacy-focused experience.
3.2.Minimal Data Collection
We only collect and retain the data necessary for service functionality, security, and regulatory compliance, avoiding excessive data storage.
3.3.Transparency and Accountability
We provide clear disclosures on how we collect, process, and share personal data, ensuring users understand our data practices.
3.4.Robust Data Security
We implement industry-standard security measures, including encryption, restricted access controls, and real-time monitoring to protect personal and financial information from unauthorized access or breaches.
DiviGain processes personal data based on legitimate business and regulatory requirements. Our legal basis for handling personal information includes:
4.1.Contractual Necessity
We process data to fulfill our obligations under agreements with users, including account management, transaction processing, and investment services.
4.2.Legal and Regulatory Compliance
DiviGain adheres to applicable financial regulations, including AML/KYC requirements, fraud prevention protocols, and local data protection laws. Personal data is processed as required to maintain compliance with authorities and ensure responsible financial operations.
4.3.Legitimate Business Interests
We process data to improve our services, enhance security, prevent fraud, and optimize user experience. This includes data analytics, system monitoring, and investment customization while ensuring transparency and ethical data usage.
4.4.Security and Fraud Prevention
We use personal data to detect, investigate, and mitigate security threats, unauthorized access, and fraudulent activities. This helps maintain the integrity and safety of our platform.
4.5.User Consent (Where Required)
In cases where explicit consent is needed, such as optional data collection or additional services, users have the right to accept or withdraw their consent at any time.
DiviGain collects various types of personal data to comply with international AML/KYC regulations and ensure secure investment transactions. The data collected falls into the following categories:
5.1.Basic Account Information
To create and maintain an account, users must provide the following information as required by regulatory standards: (a) Full Legal Name; (b) Mobile Number; (c) Identification Documents (e.g., passport, national ID); (d) Proof of Address (utility bills, official government correspondence); (e) Bank Account Details for investment transactions; and (f) other personal details.
5.2.Transaction and Investment Data
DiviGain collects and processes information related to investment activities, including: (a) Investment Preferences to tailor financial services; (b) Account Activity, including deposits, withdrawals, and portfolio changes; and (c) Payment Records for transactions conducted through DiviGain.
5.3.Technical and Analytical Data
To improve functionality and ensure platform security, our systems may automatically collect: (a) Browser Type & Device Information to optimize user experience; (b) IP Address & Geolocation (if applicable) for fraud prevention and compliance monitoring; and (c) Usage Patterns to analyze service performance and enhance operational efficiency.
DiviGain processes personal data to provide secure and efficient investment services. The ways in which we use your data include, but are not limited to:
6.1.Service Provision and Account Management
(a) Creating and maintaining your investment account; (b) Facilitating transactions, fund transfers, and investment activities; and (c) Personalizing user experience based on investment preferences.
6.2.Regulatory and Compliance Obligations
(a) Ensuring compliance with financial laws and local regulatory requirements; (b) Conducting necessary due diligence and fraud prevention measures; and (c) Assisting with audits and reporting obligations.
6.3.Security and Fraud Prevention
(a) Detecting, preventing, or mitigating security threats, unauthorized access, or fraudulent activities; and (b) Maintaining system integrity through monitoring and risk management processes.
6.4.Data Analytics and Service Enhancement
(a) Evaluating usage trends to improve platform functionality and user experience; (b) Developing new investment solutions based on data insights; and (c) Maintaining operational efficiency through technical optimization.
We do not sell your personal data. However, we may share it with third parties when necessary to operate our services, comply with regulations, or improve security and functionality. Such third parties include:
7.1.Subsidiaries and Affiliates
We may share data within our corporate group to facilitate investment services, internal operations, and compliance efforts. This allows for seamless integration across DiviGain’s subsidiaries and affiliates while maintaining strict data protection standards.
7.2.Regulatory Authorities
To comply with financial and legal requirements, we may disclose personal data to relevant regulators, auditors, or law enforcement agencies where required by law.
7.3.Payment Processors and Financial Institutions
For secure transactions, we collaborate with payment gateways, banking institutions, and financial service providers that require certain personal and account details for processing payments.
7.4.Service Providers and Technical Partners
We work with trusted third-party service providers that support our infrastructure, cybersecurity, and data management. Such entities are contractually bound to uphold strict confidentiality and security measures.
7.5.Fraud Prevention and Security Agencies
In cases of suspected fraudulent activities or security threats, we may share information with fraud prevention organizations to mitigate risks and protect user accounts.
We retain personal data for as long as necessary to fulfill our operational, legal, and regulatory obligations. Retention periods may vary depending on the nature of the data and applicable laws. Specifically:
8.1.Account Information
Retained as long as your account remains active.
8.2.Transaction Records
Maintained for compliance with financial regulations.
8.3.Security Logs
Stored for fraud prevention and system integrity
8.4.Request for Deletion
Upon request, users may request deletion of certain data, subject to regulatory requirements that may mandate retention.
To ensure confidentiality and integrity, DiviGain employs advanced security protocols, including:
9.1.Data Encryption
Sensitive financial data is encrypted in storage and during transmission.
9.2.Access Controls
Restricted access to personal data, limited to authorized personnel
9.3.Fraud Detection Systems
Continuous monitoring to prevent unauthorized transactions.
9.4.Secure Storage Infrastructure
Data is hosted in secure, compliant environments with regular security audits.
9.5.Report Unauthorized Access
While we take extensive measures to protect your data, no system is entirely immune to security risks. If you suspect any unauthorized access, please report it immediately to legal@divigain.com
As a user of DiviGain’s services, you have several rights regarding your personal data, subject to applicable local data protection laws. These rights include:
10.1.Right to Access
You may request a copy of the personal data we hold about you, including transaction history, investment details, and account information.
10.2.Right to Rectification
If any of your personal data is inaccurate or incomplete, you have the right to request corrections or updates to ensure accuracy.
10.3.Right to Deletion (Right to Be Forgotten)
You may request the removal of your personal data from our systems where applicable. However, some data may be retained to comply with legal or regulatory requirements.
10.4.Right to Restrict Processing
In certain situations, you can request that we limit the use of your personal data, such as during ongoing dispute resolution or legal proceedings.
10.5.Right to Withdraw Consent
If you have given consent for specific data processing activities, you may withdraw your consent at any time. This may affect certain services requiring that data for functionality.
10.6.Right to Object
You may object to the processing of your data in certain circumstances, such as for direct marketing (though DiviGain does not use personal data for ads).
10.7.How to Exercise Your Rights
To submit a request regarding any of these rights, please contact our privacy team at legal@divigain.com. We will respond in accordance with applicable regulations and within a reasonable timeframe.
10.8.Complaints and Dispute Resolution
If you believe your data protection rights have been violated, you have the right to file a complaint with relevant regulatory authorities in your region or seek resolution through DiviGain’s internal compliance process.
DiviGain ensures compliance with relevant data protection regulations in the jurisdictions where we operate.
11.1.DiviGain operates in multiple jurisdictions and is committed to complying with local data protection laws in the countries where we conduct business. We ensure that personal data is processed securely and in accordance with the regulatory requirements of each authorized region.
11.2.Where applicable, we implement industry-standard safeguards to protect user data, including encryption, access controls, and secure storage measures.
11.3.Singapore
For Singapore, where our servers are located, we fully comply with the Personal Data Protection Act (PDPA), ensuring that all personal data is processed according to the principles of transparency, security, and lawful usage. Our data management practices align with Singapore’s regulatory framework to protect user privacy and maintain data security.
DiviGain reserve the right to update, modify, or revise this policy at our sole discretion, without prior notification to users. Any changes will take effect immediately upon publication on our platform. Users are encouraged to review this policy periodically to stay informed about how we handle relevant obligations. Continued use of our services constitutes acceptance of any updates.
The information provided in this material is for informational purposes only, and any reliance on it is at the sole discretion of the reader. DiviGain operates as a private, invitation-only club and this website does not constitute a public offering or a solicitation to invest in any regulated financial instrument, security, or fund.
