Privacy Policy

At Divido ("we," "us," or "our"), operated by Divido Realestate Investments S.A.E, we are committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, store, share, and protect your information when you visit our website at projectdivido.com, use our mobile application, or interact with our fractional real estate investment platform (collectively, the "Platform").

This policy applies to all users of the Platform, including visitors, registered users, and investors. By accessing or using our Platform, you consent to the practices described in this Privacy Policy.

1. Information We Collect

1.1 Information You Provide Directly

We collect personal information that you voluntarily provide when you:

• Register an account: Full name, email address, phone number, and password
• Complete KYC/AML verification: National ID card or passport, proof of address, and selfie verification
• Make investments: Financial information, bank account details, and payment transaction records
• Join our waitlist or leaderboard: Email address and referral activity data
• Contact us: Any messages, inquiries, or feedback you send through our Platform
• Subscribe to communications: Marketing preferences and newsletter subscriptions

1.2 Information Collected Automatically

When you access our Platform, we automatically collect:

• Device information: Browser type, operating system, device identifiers, and screen resolution
• Usage data: Pages visited, time spent on pages, click patterns, and navigation paths
• Location data: IP address and approximate geographic location (country/city level)
• Technical data: Referring URLs, access timestamps, and error logs

1.3 Information from Third Parties

We may receive information about you from:

• KYC/AML verification service providers who confirm your identity
• Payment processors who facilitate your transactions
• Regulatory authorities, including GAFI, as required by law

2. How We Use Your Information

We use the personal data we collect for the following purposes:

• Platform operations: To create and manage your account, process investments, distribute rental income, and facilitate transactions
• Identity verification: To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations under Egyptian financial regulations
• Regulatory compliance: To fulfill our reporting obligations to GAFI and other regulatory authorities
• Communications: To send you transaction confirmations, platform updates, regulatory disclosures, and (with your consent) marketing materials
• Platform improvement: To analyze usage patterns, fix bugs, optimize performance, and develop new features
• Security: To detect and prevent fraud, unauthorized access, and other security threats
• Legal obligations: To respond to lawful requests from authorities and enforce our terms of service

3. Cookies and Tracking Technologies

Our Platform uses cookies and similar tracking technologies to enhance your experience:

3.1 Types of Cookies We Use

• Essential cookies: Required for the Platform to function properly (authentication, session management, security). These cannot be disabled.
• Analytics cookies: Help us understand how visitors interact with our Platform (Google Analytics, with IP anonymization enabled).
• Marketing cookies: Used to deliver relevant advertisements and measure campaign effectiveness (Meta Pixel, with your consent where required).
• Preference cookies: Remember your settings, such as language preference and display options.

3.2 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to block, delete, or manage cookies. Please note that disabling essential cookies may prevent certain features of the Platform from functioning correctly.

We use Google Analytics (with anonymized IP addresses) to analyze Platform traffic. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

4. Third-Party Services and Data Sharing

We do not sell your personal data to third parties. We may share your information with the following categories of recipients:

4.1 Service Providers

• KYC/AML providers: Identity verification services that process your documents securely
• Payment processors: Secure payment gateways that handle your financial transactions
• Cloud hosting: Infrastructure providers that store and process data on our behalf
• Analytics providers: Services that help us understand Platform usage (Google Analytics)
• Communication services: Email delivery and notification services

All service providers are contractually bound to process data only on our instructions and in compliance with applicable data protection laws.

4.2 Regulatory and Legal Disclosures

• GAFI and other Egyptian regulatory authorities, as required by law
• Law enforcement agencies, in response to lawful requests
• Courts and tribunals, in connection with legal proceedings

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity. We will notify you of any such transfer and any changes to your privacy rights.

5. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes described in this policy:

• Account data: Retained for the duration of your account plus 5 years after closure, as required by Egyptian financial regulations
• Transaction records: Retained for a minimum of 5 years following the transaction date, per GAFI requirements
• KYC/AML documents: Retained for 5 years after the business relationship ends, per anti-money laundering regulations
• Marketing communications: Retained until you withdraw consent or request deletion
• Waitlist/leaderboard data: Retained for 5 years following the competition close date

6. Your Rights

Under Egyptian data protection law and consistent with GDPR principles, you have the following rights regarding your personal data:

• Right of access: You may request a copy of the personal data we hold about you
• Right to rectification: You may request correction of inaccurate or incomplete data
• Right to erasure: You may request deletion of your data, subject to regulatory retention obligations
• Right to restrict processing: You may request that we limit how we use your data in certain circumstances
• Right to data portability: You may request a machine-readable copy of your data
• Right to object: You may object to processing based on legitimate interests, including direct marketing
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time

To exercise any of these rights, please contact us at info@projectdivido.com. We will respond to your request within 30 days.

7. Data Security

We implement comprehensive technical and organizational measures to protect your personal data, including:

• End-to-end encryption for sensitive data in transit (TLS 1.2+)
• Encryption at rest for stored personal data
• Access controls and authentication for all personnel handling personal data
• Regular security audits and vulnerability assessments
• Incident response procedures with mandatory breach notification within 72 hours
• Employee training on data protection and confidentiality obligations

8. International Data Transfers

Your data is primarily stored on servers located within Egypt. Where we engage service providers outside Egypt, we ensure appropriate safeguards are in place, including:

• Standard contractual clauses approved under applicable data protection frameworks
• Adequacy decisions recognizing the recipient country's data protection standards
• Certification under recognized privacy frameworks (e.g., EU-US Data Privacy Framework)

9. Children's Privacy

Our Platform is not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a minor, please contact us immediately and we will delete such data.

10. GDPR Compliance for Egyptian Users

While the EU General Data Protection Regulation (GDPR) does not directly apply to our operations in Egypt, we have voluntarily adopted GDPR-aligned practices as a benchmark for data protection excellence. This includes:

• Lawful basis assessment for all data processing activities
• Data Protection Impact Assessments (DPIAs) for high-risk processing
• Privacy by design and by default in our Platform development
• Transparent privacy notices and clear consent mechanisms
• Data minimization — we only collect data that is necessary
• Regular review and update of our data protection practices

If you are an EU/EEA resident accessing our Platform, the GDPR provisions apply to the processing of your personal data, and you may exercise all GDPR rights as outlined in Section 6.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Material changes will be communicated through:

• A prominent notice on our Platform
• Email notification to registered users
• An updated "Last Updated" date at the top of this policy

We encourage you to review this Privacy Policy periodically. Your continued use of the Platform after changes are posted constitutes acceptance of the updated policy.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

You also have the right to lodge a complaint with the relevant Egyptian data protection authority if you believe your data protection rights have been violated.