Last Updated: October 5, 2025

1. Introduction

Divv (“Divv,” “we,” “our,” and/or “us”) values and respects your privacy. This Privacy Policy explains the manner in which we collect, use, disclose, and otherwise process personal information through our website, applications, and services (collectively, the “Service”).

As used in this Privacy Policy, “personal information” means any information relating to an identified or identifiable individual. By using the Service, you agree to the collection, use, and disclosure procedures described in this Privacy Policy. Your use of our Service is also subject to our Terms of Service.

2. Collection and Use of Personal Information

We may collect the following types of personal information to provide and improve our Service:

• Information You Provide to Us:
  • Account Information: When you create an account, we collect information such as your name, email address, and password. We use this to create and administer your account and facilitate your access to the Service.
  • Payment Information: We collect information and details associated with your purchases. Any payments made via the Service are processed by third-party payment processors. We do not directly collect or store payment card information, but we may receive information associated with your payment card, such as billing details.
  • User Content: We collect the data, text, files, or other materials that you load, transmit to, or otherwise enter into the Service (e.g., CSV files or text descriptions), which may contain personal information. We use this User Content solely to provide the Service's core functionality to you, such as generating AI Users.
  • Communications: When you contact us with a comment, question, or complaint, we may collect the information you provide, such as your contact details and the content of your message, to respond to you.
• Information We Collect Automatically:
  • Usage Data: We may collect the IP addresses of all visitors to our Service and other related information such as page requests, browser type, operating system, and average time spent on our Service. We use this information to understand activity and to monitor and improve the Service.
  • Cookies and Other Technologies: Our Service uses "cookies," pixel tags, and other technologies to automatically collect information. A cookie is a tiny element of data that the Service sends to a user’s browser. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies, you may not be able to take advantage of all of the Service's features.

3. Disclosure of Personal Information

We do not disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law.

• Service Providers: Your personal information will be transferred (or otherwise made available) to certain third parties that provide services on our behalf. We use service providers for functions such as cloud computing, data storage, authentication, and payment processing. Our service providers are only provided with the information they need to perform their designated functions.
• Legal and Compliance: We may provide your personal information in response to a search warrant or other legally valid inquiry or order, or as otherwise may be required or permitted by applicable law.
• Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition, or sale involving all or part of Divv.

4. Legal Bases for Processing European Personal Information

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), we only process your personal information when we have a valid “legal basis,” including:

• Consent: Where you have consented to the use of your personal information, for example, to send you marketing communications.
• Contractual Necessity: Where it is necessary to provide you with the Service, such as to respond to your inquiries or create your account.
• Compliance with a Legal Obligation: Where we have a legal obligation to do so.
• Legitimate Interests: Where we have a legitimate interest in using your personal information, such as for product development and to improve the safety and security of the Service.

5. Your Privacy Choices and Rights