This Privacy Policy explains how Divitae Assets handles personal data collected through this website. Divitae Assets is a technology and research company specialising in the development of proprietary quantitative trading algorithms. We are not a regulated financial institution and do not provide investment services, accept client funds, or manage assets.
01Introduction
This document details how this technology firm handles limited data from its website. Algorithms are licensed exclusively to independent regulated partners authorised by the FCA, CySEC, or SEC depending on jurisdiction, which handle all client-facing regulatory activities. For information about how our regulated partners handle personal data of their clients, please consult the relevant partner privacy policy directly.
02Data Controller
Two entities operate jointly under the trading name "Divitae Assets":
- DKZ INFORMATION TECHNOLOGY SERVICES L.L.C — registered in the United Arab Emirates.
- Stratinova LTD — registered in the Republic of Cyprus.
Data protection inquiries should be directed to info@divitaeassets.com.
03Data We Collect
Collection is strictly limited to website interactions:
- Contact form submissions (name, email, company name, message content).
- Website analytics — anonymised usage patterns, browser/device data, country-level location.
- Cookie and tracking data (see Section 07).
- Server log data — IP address, timestamps, URLs, HTTP codes, user agent strings.
04Purpose of Processing
Personal data is processed for:
- Responding to contact form enquiries and partnership communications.
- Website improvement through aggregated usage analysis.
- Technical operation, security, and infrastructure stability.
- Legal compliance.
05Legal Basis for Processing
Processing occurs under three grounds:
- Consent — explicit approval for contact forms or non-essential cookies; withdrawable at any time via email.
- Legitimate interest — analytics and security monitoring using anonymised or pseudonymised data.
- Legal obligation — compliance with applicable regulatory and statutory requirements.
06Data Sharing & Third Parties
We do not sell, rent, or trade personal data. Limited sharing occurs with:
- Service providers assisting with website operations (hosting, analytics, email) under data processing agreements.
- Parties where disclosure is legally required.
- Acquiring parties in merger or acquisition scenarios, provided they assume the obligations stated in this policy.
07Cookies & Tracking
Three cookie types are used:
- Strictly necessary cookies, mandatory for functionality.
- Analytics cookies, anonymised, consent-based.
- Preference cookies for user settings.
The site does not employ advertising, retargeting, or social media tracking cookies.
08Data Retention
Retention periods vary by data type:
- Contact form data — up to 24 months from submission or until enquiry resolution.
- Analytics data — aggregated/anonymised data retained indefinitely; pseudonymised data retained a maximum of 14 months.
- Server logs — up to 90 days.
After retention periods expire, data is securely deleted or irreversibly anonymised.
09Your Rights
Depending on jurisdiction, individuals may exercise:
- Right of access — confirmation and copy of processed data.
- Right to rectification — correction of inaccurate data.
- Right to erasure — deletion where no compelling reason exists.
- Right to restrict processing — limitation in certain circumstances.
- Right to data portability — receipt in machine-readable format.
- Right to object — to processing based on legitimate interest.
- Right to withdraw consent — without affecting prior lawful processing.
Requests should be sent to info@divitaeassets.com with a 30-day response target. Unsatisfied individuals may lodge complaints with their local data protection authority.
10International Data Transfers
Personal data may be transferred across jurisdictions. Safeguards include standard contractual clauses approved by relevant authorities, transfers to countries with an adequacy determination, and other legally recognised mechanisms.
11Children's Privacy
The website targets institutional and professional audiences, not those under 18. We do not knowingly collect children's data and will promptly delete any inadvertently collected information if discovered.
12Data Security
Appropriate technical and organisational protections are implemented, including encryption in transit (TLS/SSL), access controls, and regular security reviews. However, no method of internet transmission can guarantee absolute security.
13Changes to This Policy
Updates may occur to reflect changes in practice, technology, legal requirements, or other relevant factors. Material modifications appear on this page with an updated date. Continued website use after posting constitutes acceptance of revisions.
14Contact Us
For questions, rights exercises, or concerns:
- Email: info@divitaeassets.com
- Trading name: Divitae Assets
- Legal entities: DKZ Information Technology Services L.L.C & Stratinova LTD