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Privacy Policy

Privacy Policy And Your Privacy Rights

Last Updated: Nov 22, 2022

This Privacy Policy applies to the information Divinité and its subsidiaries and affiliates (collectively, “Divinite,” “we,” or “us,” or “our”) collect through the websites, mobile-optimized websites, mobile applications, electronic devices, kiosks, and all other interactive services we provide at and and all of the associated content, functionalities, and advertising (collectively, the “Services”). This Privacy Policy governs the Services regardless of how you access them. The Privacy Policy describes:​


Some Services may have a specific, separate privacy policy that will govern use of those Services. In the event of a conflict between the terms of the Privacy Policy and the terms of the privacy governing a specific Service, the terms of the Service’s privacy policy shall govern.

1. The personal information we collect and how we collect it.

Personal information is any information that relates to an identified person or information which, together with other information, may identify a person. Below we describe the types of personal information that we collect, how that information is used, and the legal basis for the collection of such information.

How we collect and store information depends on the websites you visit, the activities in which you participate, and the Services you use. You can use some of the Services without providing any information other than what is automatically collected as described in section 1.4. For certain Services, you are required to provide personal information or you will not be able to use the Services.

1.1 Information you provide to use the Services

We collect any information that you provide during your use of the Services, including your first and last name, username, password, email address, postal address, phone number, mobile phone number, payment information, gender, and birth year. We also collect information you provide or allow us to access when you do certain things, such as:

  • Enter registration information for one or more of our Services;

  • Enter a sweepstakes or contest or register for a promotion;

  • Participate in voting or polling activities;

  • Make a purchase;

  • Request certain features (e.g., newsletters, updates, and other products);

  • Sign up to receive SMS (text message) notifications;

  • Download or use one of our mobile applications; or

  • Connect with the Services or otherwise allow us to access certain information about you via a social networking site (SNS).

We may collect and store your user ID associated with a social networking service (SNS) account that you use to sign in to your divinite account or connect or use with the Services. When you sign in to your divinite website account or mobile application with your SNS account information or otherwise connect to your SNS account with the Services, you authorize divinite to collect, store, and use in accordance with this Privacy Policy any and all information available to divinite through the SNS interface, including without limitation any information that you have made public in connection with your divinite account, information that the site shares with us, or information that is disclosed as being shared during the sign-in process.

You can choose not to provide us with certain personal information, but that may result in you being unable to use certain features of the Service because such information may be required in order for you to register as a member; purchase products or services; participate in a contest, promotion, survey, or sweepstakes; ask a question; or initiate other transactions through the Services.

1.2 Information you post on or to the Services

We also collect content, such as comments, that you choose to post to or on any of the Services. Other than the information described in section 1.1, posting content to the Services is completely optional and you may still use the Services if you do not choose to post content.

Please be careful and responsible whenever you are online. If you use a forum, blog, channel, bulletin board, chat room, user commenting features, or other interactive sharing or social features that may be offered through the Services, any personal information you submit, disclose, or otherwise publish is considered publicly available and can be read, collected, used, and disclosed by other users of those features, by us, and other third parties. In addition, such postings may appear on other websites or when searches are performed on the subject of your posting. If you post your email address or other personal information, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information. Once you have posted information, you may not be able to edit or delete such information if it has been reproduced on other websites or shared with third parties outside of our control.

1.3 Payment information

If you choose to access our paid Services or to make a purchase, we will collect information such as your credit or debit card information, billing address, shipping address, and transaction history.

1.4 Automatically-collected information

We automatically collect certain information when you use the Services:

  • Device information: We collect information about the device that you use to access or use the Services, such as hardware model, operating system, browser information, and IP addresses.

  • Mobile device information: In addition to the device information described above, we collect certain information when you access the Services via a mobile device, such as the unique device identifier assigned to your device, operating system, and other device attributes.

  • Location information: We collect information about your location, such as general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information, advertising, and features. For example, if your IP address indicates an origin in Los Angeles, the Services may be customized with Los Angeles-specific information and advertisements. In order to do this, your location information may be shared with our agents, vendors or advertisers. If you access the Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

  • Usage information: We collect information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information.

As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting and analyzing this information.

We may also capture other data, such as search criteria and results. In some cases, we will associate this information with a unique identifier (that is not intended to be used by itself to identify you) for our internal use, in which case your identifier will be considered divinite information and nothing in this Privacy Policy restricts how divinite may use this information.

1.5 Cookies and other electronic technologies

We may send one or more Cookies to your computer or other device. We also use other similar technologies such as tracking pixels, tags, web beacons, or similar tools when you visit our Site. We may also use these tools in emails and newsletters to determine when the messages have been opened and for other analytics purposes. These technologies can collect the data described in section 1.4, above. This information allows us to understand how you use the Site and when you interact with our emails.

What Are Cookies?

Cookies are small files created by websites, including our Site, that reside on your computer’s hard drive and that store information about your use of a particular website. When you access our Site, we use Cookies and other tracking technologies to:

  • Estimate our audience size and usage patterns;

  • Store information about your preferences, allowing us to customize our Site according to your individual needs;

  • Contact you to provide you with information or services that you request from us;

  • Advertise new content, events, and services that relate to your interests;

  • Provide you with more personalized content that is most relevant to your interest areas; and

  • Recognize when you return to our Site.

We set some Cookies ourselves and others are set by third parties. You can manage your Cookies preference as described in the “Managing Your Cookies” section below.

What Types of Cookies Do We Use and Why?

These are the different types of Cookies that we and our service providers use on the Site:

  • Essential Cookies. These Cookies are required for the operation of the Site and enable you to move around the Site and use its features. Disabling these Cookies can negatively impact the Site’s performance.

  • Analytics, Performance and Research Cookies. These Cookies allow us to analyze activities on the Site. They can be used to improve the functioning of the Site. For example, these Cookies recognize and count the number of visitors and see how they move around the Site. Analytics Cookies also help us measure the performance of our advertising campaigns to help us improve them and to optimize the Site’s content for those who engage with our advertising.

  • Functionality Cookies. These Cookies are used to recognize you when you return to the Site. This enables us to personalize content for you and remember your preferences.

  • Social Networking Cookies. These Cookies are used to enable you to share pages and content that you find interesting on our Site through third-party social networking and other websites. These Cookies may also be used for advertising purposes.

How Long Do Cookies Stay on My Device?

Some Cookies operate from the time you visit the Site until the end of that particular browsing session. These Cookies, which are called “session cookies,” expire and are automatically deleted when you close your Internet browser.

Some Cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser. These Cookies are called “persistent cookies” and the length of time they will remain on your device will vary from Cookie to Cookie. Persistent Cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the Site, how your use of the Site may change over time, and the effectiveness of advertising efforts.

Managing Your Cookies

It may be possible to block Cookies by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies), you may not be able to access all or parts of the Site.

Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove Flash cookies. To learn more about how to manage Flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel. You have the right to opt out of non-essential cookies, such as for analytics or advertising purposes, at any time.

You can find out more about Cookies and how to manage them by visiting

1.6 Information from third parties

We may obtain additional information about you from third parties such as marketers, partners, researchers, and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.

1.7 Aggregate or de-identified data

We may aggregate and/or de-identify information collected by the Services or via other means so that the information cannot reasonably be used to identify you. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.

1.8 Emails

You must provide your email when you signup to be a divinite member. We use your email to provide you with service related materials and correspondence. You may also opt-in to receiving promotional materials via email. Both members and non-members that have provided their email addresses may opt out of receiving promotional emails at any time.

2. What we do with the information we collect.

We use the information we collect to provide our services to you, to improve our services and site, and to protect our legal rights. We do not store, access, transmit, retain, or otherwise use personal information in any way that is incompatible with this Privacy Policy without your consent. Specifically, we may use the information we collect to:

  • Provide you with services you request;

  • Communicate with you about our site or services or to inform you of any changes to our site or services;

  • Identify new opportunities or services that may be of interest to you;

  • Provide support

  • Maintain and improve our site and services;

  • Defend our rights and the rights of others;

  • Efficiently maintain our business; and

  • Comply with applicable law.

The Services are supported in part by advertising revenue. We may send you commercial emails on behalf of ourselves, our Affiliates, and advertisers. Each such email we send you will have an opt-out that you can use to stop receiving such communications. It may take up to seven days for us to process an opt-out request. We may continue to send you other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving such emails. Please note that opting out of receiving promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.

3. How we share and disclose information with third parties.

  • We may share personal information with the following categories of third parties: Our service providers;

  • Our affiliates;

  • Other non-affiliated third parties on the basis of your consent or the legitimate interest of providing you with products or services that may be of interest to you; and

  • Government and regulatory agencies when required by law or in response to lawful requests from third law enforcement.

We may also share the information we collect in the event of a merger, acquisition, or sale of our business, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety, protect the safety of others, or prevent or investigate fraud.

We may aggregate and/or de-identify your information so that the information no longer relates to you individually. Our use and disclosure of such aggregated or de-identified information is not subject to this Privacy Policy, and may be disclosed to others without limitation and for any purpose. If you have any questions about how we share your personal information, please contact us via the methods identified in How to Contact Us section below.

4. Use of online analytics and tailored advertising.

4.1 Online analytics

We may use third-party web analytics services on our Services, such as those of Google Analytics. These service providers use the sort of technology described in Section 1.5 to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section. You may opt out from the use of cookies and other technology for analytics at any time. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here

4.2 Tailored advertising

When you use the Service, divinite may serve you with ads based on various factors such as the content of the page you are visiting, information you provide such as your age or gender, your searches, demographic data, user-generated content and other information that you provide to us. These ads may be based on your current activity or your activity over time and may be tailored to your interests. You have the right to opt out of cookies and other technologies that provide you with such tailored advertising, as described in Section 1.5.

If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiatives Consumer Opt-Out link, the Digital Advertising Alliances Consumer Opt-Out link or TRUSTe’s Advertising Choices Page to opt-out of receiving tailored advertising from companies that participate in those programs. You may also use any links that may be available in advertisements that appear in the Services to learn more.

To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored specifically to you. We do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

When using a mobile application you may also receive tailored in-application advertisements. Each operating system (iOS for Apple phones, Android for Android devices and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.

5. How you can access and update your information.

To ensure that you have some control over the information we have about you, you may review and update certain user profile information by logging in to the relevant portions of the Services where such information may be updated (may be available on some Services and not others) or by contacting us at

6. How we protect information.

We have implemented a variety of administrative, technical, and physical security measures to protect against the unauthorized access, destruction or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect, process and store and the current state of technology.

Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot guarantee that information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.

7. How long we retain your information.

We will retain your information for as long as you use the Services and for a limited period after you stop using the Services for billing and collection purposes.

8. Linked websites and advertisements.

The Services may contain links to third-party websites. We are not responsible for the privacy practices or the content of those third-party websites.

We have relationships with third-party providers to provide content, products, services, and functionality through the Services. When you visit websites or use any Services provided in conjunction with one or more of these third-party providers and the brands of those providers appear on the website or Services in connection with such content, products, services, or functionalities, we share any information you provide or that is collected during your use of those Services with those providers as set forth in Section 3. In some cases, the provider may collect information from you directly, in which case the provider’s privacy policy (which may differ from this Privacy Policy) would apply. If you have any questions regarding the privacy policy of any of our providers, you should contact the provider directly for more information.

9. Use of the Services by users from outside the United States.

Personal Data captured on this website may be transferred to, and stored or otherwise processed at, a destination outside the European Economic Area (hereinafter “EEA”), including destinations that are not subject to Data Privacy Provisions equivalent to those in the EEA countries in which you provided your Personal Data. We transfer your data to the US with your consent or where necessary to provide you with the services you have requested. We will take all steps reasonably necessary to ensure that your Personal Data is processed safely and in accordance with this Privacy Policy.

10. Use of the Services by children prohibited.

The Services are not intended for persons under the age of 18. By using the Services, you hereby represent that you are at least 18 years old. Some third parties, such as platform providers like the iTunes Store or Google Play may provide age-based ratings on some of the Services. These ratings shall have no bearing on this limitation. Third parties may also provide content categories on some of the Services. These categories shall have no bearing on this limitation.

If you become aware that your child has provided us with personal information, please contact us at We do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information, we take steps to remove such information and terminate the child’s account.

11. Do-Not-Track disclosure requirements.

We are committed to providing you with meaningful choices about the information collected on our Services for third-party purposes, and that is why we provide above the Network Advertising Initiatives Consumer Opt-out link, Digital Advertising Alliances Consumer Opt-Out Link, TRUSTe’s Advertising Choices page, and the Google opt-out link set forth in sections 4.1 and 4.2. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the US Internet industry is currently still working on Do Not Track standards, implementations and solutions.

12. California privacy rights.

If you are a California Consumer, you have certain rights with respect to the collection, use, transfer, and processing of your “Personal Information”, as defined by the California Consumer Privacy Act (CCPA). We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us via the contact information below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

12.1. Collection of Personal Information

When California Consumers access the divinite websites, use divinite services, purchase our products, or contact divinite, we collect the following Personal Information.

Categories of Consumer’s personal information collected


Business or Commercial Purposes for Collection

Categories of Sources from which information was collected

Categories of Third Parties with whom information is shared


Real Name, Alias, Post Address, Email, Phone number.

- Process your transactions.

- Provide you with the products and services you request.

- Administer Sweepstakes and contest.

- Communicate with you regarding your account or transactions with us.

- Send you offers and Promotions for our products and services.

This information is collected directly from you

Affiliates, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).

Financial Information

Credit Card Information

Process your transactions.

This information is collected directly from you.

Affiliates, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).

Commercial Information

Purchases obtained or considered.

- Provide you with the products you request.

- Process your transactions.

This information is collected directly from you or by logging our interactions with you.

Affiliates, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).

Internet or Electronic Network Activity Information

Browsing history, information regarding a consumer’s interaction with an Internet Web site, application, or advertisement, internet protocol address, device ID, cookies, beacons, pixel tags, mobile ad Identifiers.

- Provide you with targeted advertising based on your activity on our sites.

- Operate, understand, optimize, develop, or improve our sites, applications, products, services and operations.

- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

- Debugging to identify and repair errors that impair existing intended functionality.

- Investigate and prevent activities that may violate our policies.

We collect your internet or other electronic network activity information from your interactions with our website.

Affiliates, analytics providers, service providers, transactions processors, IT vendors, and law enforcement (if necessary).


In the preceding 12 months, we have not sold Personal Information about consumers.

In the preceding 12 months, we have not sold Personal Information about minors.

12.2 Individual Rights Under the CCPA

Individual Rights Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that divinite disclose the Personal Information it collects, uses, and discloses about you to third parties. There are two types of Right to Know requests you can make:

Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:

  • Category of personal information collected,

  • Categories of sources from which that information was collected,

  • The business or commercial purpose(s) for which the information was collected,

  • The categories of third parties to whom divinite sold or disclosed the category of personal information for a business purpose, and

  • The business or commercial purpose for which PBCI sold or disclosed the category of personal information.

Right to Know (Specific Pieces of Information Request): If you make a

Right to Know (Specific Pieces of Information Request), you will receive the following information about you:

  • Specific pieces of Personal Information collected about you.

PBCI does not sell any Personal Information of California consumers. This information will be provided to you free of charge, unless divinite determines that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.

Right of Deletion You have the right to request that divinite and our service providers delete any Personal Information about yourself that divinite has collected from you upon receipt of a verifiable request. This right is subject to exceptions.

Verifying Requests divinite provides California Consumers with the ability to submit requests through our request website, our telephone number, and our email address. divinite must verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request. To verify a California Consumer’s identity, we may request up to up to three pieces of Personal Information about you when you make a request to compare against our records. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request. divinite reserves the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is fraudulent.

Authorized Agent You may choose a person registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, PBCI requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with divinite. Failure to do so may result in divinite denying your request.

Right to Equal Service divinite will not discriminate against you because you exercised any of your rights, including, but not limited to, by:

  • Denying goods or services to you.

  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.

  • Providing a different level or quality of goods or services to you.

  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

EU and UK data subject rights.

Under the EU and UK General Data Protection Regulations (GDPR), if you are an EU or UK resident and we are processing your personal information, you have the following rights:

  • Right of access: You have the right to request a copy of the information that we hold about you.

  • Right of rectification: You have the right to have information that we hold about you that is inaccurate or incomplete corrected.

  • Right to be forgotten: In certain limited circumstances, you have the right to request that we erase from our records the information that we hold about you.

  • Right to restriction of processing: In certain limited circumstances, you have the right to restrict the processing of your information.

  • Right to withdraw consent: If you have provided consent for the processing of your information you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.

  • Right of portability: In certain limited circumstances, you have the right to have the information we hold about you transferred to another organization.

  • Right to object: You have the right to object to certain types of processing of your information such as direct marketing (to the extent applicable).

  • Right to object to automated processing, including profiling: You have the right to not be subject to the legal effects of automated processing or profiling.

  • Right to lodge a complaint: You have the right to lodge a complaint with your relevant Data Protection Authority if you believe that we have not complied with the requirements of the GDPR with regard to your personal information.

13.1 Legal basis for processing

If you are a resident of the United Kingdom or the European Union, you may be entitled to an explanation of the legal basis on which we rely to process your personal information. We process your personal information on the basis of:

Consent: We may process your personal information based on your consent such as when you purchase a service or ask us to send you certain kinds of marketing communications. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.

Our Legitimate Interests: We may process your personal information if doing so is necessary for our legitimate interests and your rights as an individual do not override those legitimate interests. We may process your information on the basis of our legitimate interest when managing your account and providing you services, providing you with notices and communications, administering sweepstakes, and performing analytics to improve our services. There may be other circumstances in which our legitimate interest is a secondary grounds for processing your information.

To Perform a Contract: We may process your personal information to administer and fulfill contractual obligations to you.

To Enable Us to Comply with a Legal Obligation: We may process your personal information to comply with legal obligations to which we are subject. This may include any requirement to produce audited accounts, any legal obligation to share information with law enforcement agencies, public or governmental authorities, and to comply with legal process.

Necessary for the Exercise or Defense of Legal Claims: If you bring a claim against us or we bring a claim against you, we may process your personal information in relation to that claim.

If you wish to assert any of your rights or if you have questions about our legal basis for processing, please contact us in accordance with the How to Contact Us section, below.

14. No rights of third parties.

This Privacy Policy does not create rights enforceable by third parties.

15. Changes to this Privacy Policy.

divinite reserves the right to change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this Privacy Policy will mean you accept those changes.

16. How to contact us.

If you have any questions, comments, or concerns regarding our Privacy Policy or practices, please send an email to

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