Privacy Policy

Divica (“we”, “us”, “our”) respects your privacy. We are a UK-based platform providing free tools for individuals to trace and reclaim lost shares and unpaid dividends, and a subscription-based case management service (Divica Pro) for solicitors, accountants, and probate researchers.

This policy explains how we handle your personal data in line with the UK GDPR and the Data Protection Act 2018. We follow a strict principle of data minimisation: we collect only what we need to provide our services, and no more.

1. Who We Are

Divica is the Data Controller for the personal information collected through this website. You can contact us at any time at hello@divica.co.uk.

2. What We Collect

The personal data we collect depends on how you use Divica:

• Free search and reclaim tools: These run in your browser. You don’t need an account to use them. Nothing you type into the search or the DIY Reclaim Kit is transmitted to or stored on our servers.
• Pro Partner enquiries: If you use the Pro Partners directory to contact a professional, we collect your name, contact details, and any message you send so we can route it to the professional you’ve chosen.
• Divica Pro account details: When you register for a paid Divica Pro subscription, we collect your name, firm name, and email address.
• Divica Pro case data: Inside the Pro dashboard, we save the information you choose to store there, specifically: case references, company names, share quantities, and valuation dates, along with the resulting valuations and unclaimed dividend totals. Sensitive correspondence you draft inside Divica Pro is held only in your browser session and is not saved to our servers.
• Payment data: For Divica Pro subscribers, all payments are processed by Stripe. We do not see or store your card number. We only retain the transaction confirmation and your subscription status.
• Technical data: IP address, browser type, and basic usage data, collected for security, fraud prevention, and site performance.

3. Why We Use Your Data (Lawful Basis)

Under UK GDPR, we must have a lawful basis for processing each category of personal data. Our bases are:

• Contract: To provide you with your Divica Pro subscription, manage your account, and process payments.
• Legitimate interests: To route your Pro Partner enquiries to the professional you’ve chosen, maintain security, prevent fraud, and improve our service.
• Consent: For any optional communications you opt into. You can withdraw this consent at any time.
• Legal obligation: Where we need to keep records for tax, accounting, or regulatory purposes.

4. How Long We Keep Your Data

• Free tools: Nothing is retained. Data stays in your browser only.
• Pro Partner enquiries: Held for up to 12 months so we can resolve any questions about the enquiry, then deleted.
• Divica Pro accounts and case data: Held for the duration of your active subscription. If you cancel, your account and case data are deleted within 90 days, unless we’re required to retain certain information (e.g. for tax or accounting).
• Payment records: Kept for 6 years to meet UK accounting and tax requirements.
• Technical logs: Typically held for up to 90 days.

5. Sharing Your Data

We are independent. Divica is not affiliated with Equiniti, Computershare, or MUFG.

• We do not send data to registrars for you. Everything you generate with the free Reclaim Kit is for you to download, sign, and send yourself. We never auto-submit on your behalf.
• Pro Partner enquiries: When you contact a professional via the directory, your enquiry is sent to that independent firm. Once they receive it, they become the Data Controller of that information and their own privacy policy and terms apply. Divica is not responsible for how they handle your data or the services they provide.
• Infrastructure providers: We share data only with the providers needed to run the service. This includes Stripe (payment processing), our hosting provider, and our transactional email provider.

We never sell your personal data to third-party marketers or asset-tracing firms.

6. International Data Transfers

Some of our processors (for example, Stripe) may store or process data outside the UK. Where this happens, we ensure that the transfer is protected by appropriate safeguards required under UK GDPR, such as the International Data Transfer Agreement or Standard Contractual Clauses.

7. Data Security

Your connection to Divica is protected by TLS encryption. Account passwords are stored using industry-standard one-way hashing and are never readable by us or anyone else. We regularly review our systems and access controls to keep your data safe.

8. Your Rights

Under UK GDPR, you have the right to:

• Access the personal data we hold about you.
• Request correction of inaccurate or incomplete data.
• Request deletion of your data (“right to be forgotten”).
• Request a copy of your data in a portable format.
• Object to or restrict certain types of processing.
• Withdraw consent for any processing based on consent.

To exercise any of these rights, email hello@divica.co.uk. We’ll respond within one calendar month, as required by UK GDPR.

9. Cookies

We use essential cookies to keep you signed in to Divica Pro, maintain your session, and make the platform work correctly. We do not use intrusive third-party advertising or tracking cookies.

10. Children

Divica is intended for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with their data, please contact us so we can delete it.

11. Changes to This Policy

We may update this policy from time to time, for example if we add new features or change how we handle data. The “Last Updated” date at the top of the page reflects the most recent change. Material changes will be communicated directly to Divica Pro subscribers by email.

12. Contact and Complaints

For any questions about this policy or how your data is handled, contact us at hello@divica.co.uk.

If you are not satisfied with how we have handled your data, you have the right to make a complaint to the Information Commissioner’s Office (ICO) at ico.org.uk.