Dividandy Privacy Notice

Last Revised: 6, May, 2026

INTRODUCTION

Dividandy, including its affiliates, is deeply committed to safeguarding the privacy expectations of its users (“User(s)”, “you” or “your”). Dividandy is operated by Dividandy Limited, a company incorporated in Cyprus and having its registered address at Kallipoleos, 15, AMARAL 30, 4th floor, Flat/Office 402, 1055, Nicosia, Cyprus,  (collectively, the “Company”, “we“, “our” or “us“).  

This privacy notice (“Notice“) aims to make our practices regarding your personal data (“Personal Data”, as defined below) more transparent and clearer. Accordingly, this Notice provides information regarding how we collect, use, share, transfer, retain and protect your Personal Data, as well as your rights with respect to your Personal Data.

Please read this Notice very carefully and use it to make informed decisions. By using our services, whether by visiting our website, Web Store, accessing our iOS or Android mobile applications, backoffice tools, or any other interaction with our products or services (“Service“), you confirm that you have read and understand all the terms detailed herein and you hereby agree to this Notice and to the collection, use, retention and disclosure of your Personal Data in accordance with these terms. If you do not agree to the terms of this Notice, please do not use our Services. 

You are not legally required to provide us with any Personal Data, but without it, we will not be able to provide you with the full range or with the best experience of using our Services.

Your Personal Data will be processed by us (including any of our agents and/or employees), and (where appropriate) any other company in our company group and/or our partners and subcontractors, in accordance with this Notice. 

In this Notice, you can learn about – 

1. WHAT TYPES OF DATA WE COLLECT?
2. PURPOSES AND CONDITIONS FOR PROCESSING PERSONAL DATA
3. MINORS
4. MARKETING
5. WITH WHOM WE SHARE INFORMATION?
6. INTERNATIONAL TRANSFER OF PERSONAL DATA
7. THIRD PARTY TRACKING TECHNOLOGIES
8. RETENTION AND SECURITY OF PERSONAL DATA
9. YOUR RIGHTS
10. CHANGES TO THE PRIVACY NOTICE
11. HOW TO CONTACT US?

1. WHAT TYPES OF DATA WE COLLECT?

When you engage with our Services, we collect Personal Data about you. Personal Data means any information which potentially allows your identification with reasonable means (for example, email address or name, collectively: “Personal Data“). This section sets out how and when we collect and process Personal Data about you.

• Registration and login: When you open an account and register to use our Service, you will be asked to provide us with certain details about yourself, such as your username, password, age, address a profile photo or similar identifier. Please note that when you wish to update your account profile, we also collect Personal Data from you.
• Voluntary information: We also collect information which you provide us voluntarily to personalize your account or for a specific function, which you voluntarily provide to us at your discretion for a specific function. In addition, we collect your communication when you respond to communications from us, provide us with feedback, or share additional information about yourself through your use of the Service. 
• Gameplay and simulated trading information: We collect certain usage and information about your interaction with our Services, including your participation within the game and in tournaments. Such information may include information regarding your deposit, transactions, virtual balances, simulated trading activity, virtual currency, withdrawals, bonuses, scoring, win/loss rates, prizes, rankings, performance statistics, portfolio balances, results during a gameplay and other data which relates to your activity in the Services. All trading activity within the Services is simulated and uses virtual funds.
• Payment information: We collect certain payment information including information related to your deposit, withdrawal and your purchase. Payments are processed by third-party payment providers. We do not store full payment card details. We may store limited, non-sensitive payment metadata such as payment method identifiers, transaction IDs, timestamps, amounts, and payment status.
• Device information: We collect specific types of connection details and information with regard to your device, software or hardware that could identify you, such as: device’s unique identifiers (e.g. UDID), browser fingerprinting, IP address and geo-location data.
• Information we collect from third parties: We sometimes collect Personal Data from third party service providers, such as information to verify your identity, prevent fraudulent or illegal activity or where we have a legitimate interest do so.

• Log-in history and technical information: To enhance the functionality of the Service and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, access time, etc.).
• Analytics information: We collect information about your use of the Service, such as applications’ usage, log files, user activity (e.g. pages viewed, user’s movements, time spent, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Service.
• Identity verification data (AML, KYC, fraud and risk): We collect certain information as required under applicable regulations, including Anti-Money Laundering (“AML“) and Know Your Client (“KYC“) obligations. Such information may include details regarding ownership of the payment method, PEP status, and other relevant data. We do not store copies of identity documents submitted for verification; such documents are processed by third-party verification providers, and we retain only verification statuses, reference identifiers, and audit-related metadata.

•  PURPOSES AND CONDITIONS FOR PROCESSING PERSONAL DATA 

This section outlines the underlying purposes and legal bases for the processing of your Personal Data:

1. MINORS

The Service is not designed or directed to persons under the age of 18 or persons under the age of legal consent with respect to the use of the Service of any jurisdiction, whichever is higher (“Legally of Age”). 

We do not knowingly collect or solicit Personal Data from minors (“Minor(s)“). Our Services are not designed or directed to Minors. If you are a Minor, you are prohibited from accessing or using the Services and you are prohibited from providing any Personal Data to us. By accessing, using, or interacting with our Services, you certify to us that you are not a Minor. In the event that we have collected Personal Data from a Minor, we will delete that information upon discovery. If you believe that we may have any information from or about a Minor, then please contact us through the contact details available below.

We reserve the right to access and verify any Personal Data collected from you. In the event that we become aware that a user who is not Legally of Age has shared any information, we shall discard such information. 

1. MARKETING

We will use your Personal Data, such as your name, home address, email address, telephone number, etc., collected by ourselves and/or through our third party subcontractors for the purpose of providing you with promotional materials via different marketing techniques such as direct email, telephone marketing, SMS and post concerning the Service as well as products, services, website and applications that may be of interest to you including administering contest, promotions, surveys or other site features which relate to: (i) other companies within the Company’s group; or (ii) the Company’s business partners and affiliates (collectively, “Marketing Affiliates“), which we believe may interest you.

We may also share and disclose Personal Data with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this Personal Data for different marketing techniques, such as direct email, post and SMS telephone marketing purposes. We will use your Personal Data for the purpose of providing you with promotional materials solely where we have a legitimate interest in doing so, or where we have obtained your affirmative consent.

You may at any time decline receiving further marketing offers from us or from our business partners and Marketing Affiliates by following the unsubscribe instructions provided in the message or by contacting us at support@dividandy.com  

Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you in-app service-related updates and notifications.

1. WITH WHOM WE SHARE INFORMATION?

We do not rent, sell, or share your Personal Data with third parties (“Recipients”) except as described in this Notice. The Personal Data will be disclosed to Recipients only to the extent required for the specific purpose, as stipulated in this Notice.

We disclose Personal Data with any of the following Recipients:

• Companies within the Company and other affiliated companies;
• Subcontractors and third-party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, identity verification and fraud prevention services, and other data verifiers;
• Payment service providers, payment processors; 
• To any third parties who provide services in relation to the operation or promotion of the Service;
• Auditors, contractors or advisers of any of the Company’s business processes;
• To any third parties who investigate, detect or prevent fraudulent or illegal activity (e.g. governmental authorities, police, banks and other investigatory organizations);
• Governmental and regulatory bodies, in accordance with applicable laws and regulations;
• Law enforcement agencies or authorities, as a response to their request; 
• Potential purchasers or investors in any of the companies within the Company’s group (if applicable), or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to any company within the Company (in such event, the acquiring company or transferee will assume the rights and obligations as described in this Notice).
• Research, technical diagnostics and analytics vendors; 
• Marketing and advertising partners, in accordance with our marketing Notice (see above, under section 4. “Marketing“); and
• Whenever we believe in good faith that disclosure is necessary to protect our rights or legal claims, enforce our policies (including our Terms of Use and Notice), protect your safety or the safety of others, as well as to investigate or prevent any fraud, for security reasons or to help us with any other related technical issue.

1. INTERNATIONAL TRANSFER OF INFORMATION

We operate globally, thus any information we collect, process, disclose or share, including your Personal Data, can be stored and processed in various jurisdictions around the world, including (but not limited to) the European Economic Area (“EEA”) for the purposes detailed in this Notice. The data protection and other laws of these countries may not be as comprehensive as those in the EEA. In such circumstances and where required by law, we have put in place contractual measures to ensure that the recipients of your Personal Data provide appropriate safeguards for your data (for example, by training its staff and implementing effective technological and organizational security measures) and are only using it for the purposes of performing their services, or otherwise for those purposes for which we have disclosed your information to them.

For more information about the transfer of your Personal Data, our contact details are available under section 11. “HOW TO CONTACT US?”.

1. THIRD PARTY TRACKING TECHNOLOGIES

When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies (“Tracking Technologies”). These allow us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation in our Services, improve our Services performance, perform analytics, customize your experience, and offer your, for example, tailored content and advertising that better correspond with your interests.

Tracking Technologies may be placed by us or by our third parties such as analytics providers. 

To learn more about our practices related to Tracking Technologies, please see our Cookie Notice. 

1. RETENTION AND SECURITY OF PERSONAL DATA

If you have registered with an account through our Service, we will retain your Personal Data during the period your account is active. In addition, we will retain your Personal Data for additional periods, to enable the Company to meet its legal obligations under applicable laws or regulations.

In addition, the Company shall retain your Personal Data for longer periods, provided that retaining such information is only necessary for the Company’s legitimate interests, such as fraud prevention and record keeping, resolving or excising claims regarding potential disputes. We will keep any relevant Personal Data that we may need to defend ourselves against any claim(s), challenge(s) or other such action(s) by you or third parties for such time as it is necessary. Where your Personal Data is no longer required by us, we will either securely delete or anonymize the Personal Data in question.

If you wish to delete your Personal Data, please send us an e-mail to: contact@dividandy.com and we will make reasonable efforts to address your requests.

We implement reasonable technical and organizational security measures designed to protect Personal Data against unauthorized access, loss, misuse, or alteration. However, no system is entirely secure, and we cannot guarantee absolute security of information.

1. YOUR RIGHTS

Depending on your jurisdictions, you may have certain rights regarding the collection and processing of your Personal Data. To the extent these rights apply to and concern you, you can exercise them by contacting us via the contact details available under the section 11 below “HOW TO CONTACT US?” and exercise the following rights: 

1. Rights of access. You can obtain a copy of the Personal Data held by the Company at any time;
2. Right of data portability. You have the right to receive your Personal Data, in a structured, commonly used and machine-readable format and to request that your Personal Data be transmitted to a third party of your choice;
3. Right of rectification. In the event that the data held about you by the Company is inaccurate, incomplete or outdated, you have the possibility to request the rectification of said data (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
4. Right of erasure. You have the possibility at any time to request that the Company erases data held about you. However, you are advised that with the deletion of your Personal Data, you might not be able to use the Service anymore;
5. Right to restriction of processing, objection to processing. At any time, you have the right to request that the Company restricts or ceases to conduct certain data processes provided that there is no other lawful basis on which the Company is authorized to process said data;
6. Right to withdraw your consent. You have the right to withdraw your given consent at any time. The withdrawal of consent will not affect the lawfulness of processing;
7. Right to lodge a complaint. All requests, complaints or queries may be addressed to the Company following email address: contact@dividandy.com, with the subject “Privacy”. We will consider any request, complaints or queries, and provide you with a reply in a timely manner.
8. Right to limit use and disclosure of your Personal Data. You have the right to request to limit the collection of your sensitive Personal Data, to that use which is necessary to perform our Services. 
9. Right to opt-out of the sale and share of Personal Data. In the event that we sell or share your Personal Data for behavioral advertising purposes, you have the right to submit a request to opt-out of the sale or share of your Personal Data. After you opt-out, we may continue disclosing some Personal Data to our partners to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and preventing fraud. 
10. Right to non-discrimination. You have the right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request. 

Please note that these rights are not absolute and can be subject to our own legitimate interests and regulatory requirements. You are welcome to contact us for any questions, requests or complaints through our contact details below. Note that we may ask you to provide us with additional information in order to adequately verify your identity upon your request.

We will make an effort to reply within a reasonable timeframe and in compliance with applicable laws and regulations. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can lodge a complaint with the competent supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the competent supervisory authority, so please contact us in the first instance.

Authorized Agent

1. You can use an authorized agent to make a request to exercise your right under applicable laws on your behalf if:

1. The authorized agent is a natural person or business entity; and
2. You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on you behalf using the contact information below.

1. The request must:

1. Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Data or an authorized agent. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you; and
2. Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.

1. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
2. Making a verifiable consumer request does not require you to create an account with us. 

1. CHANGES TO THE PRIVACY NOTICE

We reserve the right to change this Notice at any time, so please re-visit this page frequently. We will use reasonable efforts to notify you in the event substantial changes are made to this Notice, as required by law. Any modifications, updates, alteration will be effective upon our publishing of this Privacy on our Services and as of the stated “Last Revised” date, and your continued use of the Service after the Last Revised date will constitute acceptance of, and agreement to be bound by those changes. 

1. HOW TO CONTACT US

If you have any general question about the Service or the information that we collect about you and how we process it, please contact us at: contact@dividandy.com

We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can reach out to the applicable data protection supervisory authority.