DivInsights - Privacy Policy
Last Modified: 26 FEB 2026
CONTENTS
PRIVACY POLICY OVERVIEW
- We are committed to protecting the privacy, confidentiality and security of the personal data we hold by complying with the requirements of Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (“PDPO”) with respect to the management of personal data. We are equally committed to ensuring that all our employees and agents uphold these obligations.
- This policy explains how DivInsights Ltd. (“DivInsights”, “we”, “us”, “our”) collects, uses, shares, stores and protects the personal data of users (“you”, “your”) of our Services, as defined in the Terms of Use. “Personal data” means information individually or collectively that identifies you as an individual, such as your name, address, email address, phone number, and any other information that is not otherwise publicly available.
- This policy also covers how DivInsights uses cookies and other similar technologies. Cookies are small text files that are placed on your device when you visit a website. They are used to remember your preferences, login information, and other information related to your use of our Services
- This policy does not apply to the practices of companies that DivInsights does not own or control, or to people that DivInsights does not employ or manage. For third-party websites or services, please refer to their respective privacy policies.
- By accessing or using our Services, you agree to be legally bound by this policy and our terms of service, which can be accessed on our website.
- This policy may be modified from time to time and changes will be posted on our website.
- This policy describes what personal data DivInsights collects, including through websites, newsletters, social media groups, and mobile applications. This policy also describes how DivInsights uses such personal data and respects your choices.
- Except for the purposes outlined below or with your prior consent, DivInsights will not trade, share or sell your personal data with or to any person other than a registered user who agrees to be bound by this policy. Please refer to the details below for more information.
- For privacy law purposes, DivInsights is the data user or controller for your personal data, and you are the data subject.
- If you have any questions about this policy or any data privacy request, please contact our data privacy officer, Rody Koliloedjoer, by email at info@divinsights.com
COLLECTION OF INFORMATION ABOUT YOU
DivInsights collects your personal data in two ways:
- When you use our Services, certain personal data about you is collected automatically using various technologies and in a way that is passive with respect to you. See section below headed “PASSIVE COLLECTION OF YOUR PERSONAL DATA”.
- When you register, you are asked to provide certain information in order to complete the registration process, and you actively provide your personal data to DivInsights. See section below headed “ACTIVE COLLECTION OF YOUR PERSONAL DATA”.
PASSIVE COLLECTION OF YOUR PERSONAL DATA
- Some personal data about you may be collected automatically by DivInsights. For example, when you use our Services, we are able to automatically collect personal data such as your internet protocol (IP) address, internet service provider (ISP), operating system, browser, mobile device, and preferred language.
- Our Services may also use cookies and similar technologies to collect personal data about your interaction with our Services, including the referring webpage, pages visited on our website, and crash data. Please see section below headed “COOKIES” for more information on cookies, including how to manage cookies and similar technologies.
- In particular, our Services are able to collect personal data about your location (“Location Data”) either through your IP address, which can identify the city and state from where you have logged in to our website, or through your mobile device, which can identify your precise geolocation.
- However, we are aware that the data privacy laws of many jurisdictions prohibit the collection of certain types of Location Data without your specific consent. Accordingly, when you log in to our website for the first time, we automatically introduce you to a pop-up location data screen that will ask you if you consent to Location Data about you being collected.
- If you do not allow us to access your Location Data, we will not be able to store or use your Location Data. This may limit the functionality of our website for you.
- You may change your Location Data access permission at any time by granting or withdrawing such permission through the settings of your operating system.
- Another way in which we may collect personal data about you without your active involvement is that we may obtain such personal data from other sources, including your organisation, business partners, professional references, publicly available sources, third-party analytics providers, and other third parties. For example, we may collect your personal data if someone at your organisation designates you as a contact person for that organisation or includes personal data about you in proposal documents; if another member includes it in any feedback, comments, photographs, videos, or other information submitted via online portals, electronic forms, surveys, or interactive portions of our website; or if one of our employees, service providers, or a third party acting on your apparent authority, provides it to us when registering you to access our Services.
ACTIVE COLLECTION OF YOUR PERSONAL DATA
- You may choose to provide certain personal data about yourself to DivInsights actively. You may provide such personal data when registering an account with us and filling out an application.
- To do this, you may use our Services by (i) entering your personal data into the fields of an online form on our website; (ii) emailing, texting, or instant messaging personal data to us; (iii) accessing online portals, forms, surveys, or interactive portions of our website; or (iv) providing personal data to us in any other way.
- Such personal data may include your (i) name; (ii) email address; (iii) residential address; (iv) country of residence; (v) age and date of birth; (vi) address and/or copy of address proof; (vii) number, issuing authority and/or copy of personal identification document; (viii) other contact information; (ix) username and/or password for use of our Services; (x) photograph; and (xi) any other personal data you choose to provide.
- We collect only personal data that is reasonable or necessary to accomplish the purpose of your interaction with us as a registered user to our Services.
- You may choose not to provide any personal data requested by us, but you need to understand that if you do not provide certain requested personal data, you may not be able to engage in certain activities or make full use of our Services.
PROVISION BY YOU OF PERSONAL DATA ABOUT OTHER PERSONS
Please provide personal data about another person only if you are authorised or required to do so by the express consent of the data subject, a contract between you and that person, or applicable law, and you have disclosed to that person a copy of this policy and any applicable supplemental privacy notice. We may ask you to provide evidence of that consent, contract, law, and/or disclosure.
OUR USE OF YOUR PERSONAL DATA
DivInsights uses the personal data that you provide or that we obtain, as well as the personal data comprising technical information logged by our servers to:
- verify your identity and status;
- enable you to benefit from use of Services;
- customize the advertising and content you see;
- fulfill your requests for products and services;
- contact you;
- conduct research;
- comply with our legal or regulatory obligations, for example, to pass relevant data to a tax, enforcement, regulatory, or other competent authority;
- improve your experience on our Services (such as remembering your name or your preferences) or prevent fraudulent activity; and
- anonymous reporting for internal and external clients.
DATA SHARING AND DISCLOSURE
DivInsights does not rent, sell, or share personal data about you with other people or non-affiliated companies except to provide products or services you have requested, when we have your prior consent, or under the following circumstances:
- We provide information to trusted partners who work on behalf of or with DivInsights under confidentiality agreements. These companies may use your personal data to help DivInsights communicate with you about offers from DivInsights and our marketing partners. However, these companies do not have any independent right to share this information.
- We may also share your personal data with our agents, representatives, service providers, and contractors in order to:
- process your requests and commitments;
- offer and/or provide our Services to you;
- communicate news and information about DivInsights; and
- advertise our Services supported by us.
- We respond to subpoenas, court orders, or legal processes, or to establish or exercise our legal rights or defend against legal claims.
- We may also be required to disclose your personal data to meet national security, anti-money laundering, anti-terrorist financing, or other legal and regulatory requirements.
- We believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of DivInsights’ terms of use, or as otherwise required by law.
- In an emergency situation, we may disclose your personal data before your permission can be obtained.
- If it is determined that disclosure is needed to protect our rights or property, or the rights or property of another person, we will implement appropriate safeguards to ensure that your personal data continues to be protected.
- We transfer information about you if DivInsights is acquired by or merged with another company. In this event, DivInsights will notify you before information about you is transferred and becomes subject to a different privacy policy.
- If your personal data is to be used for a new purpose that is materially different from the purpose for which it was collected or authorised, or is to be disclosed to third parties other than our agents, we will notify you and provide you with an opportunity to opt out of such use or disclosure. You may exercise this right by contacting us at info@divinsights.com.
- DivInsights displays targeted advertisements based on personal data. Advertisers (including ad serving companies) may assume that people who interact with, view, or click on targeted ads meet the targeting criteria – for example, women ages 18-24 from a particular geographic area.
- DivInsights does not provide any personal data to the advertiser when you interact with or view a targeted ad. However, by interacting with or viewing an ad you are consenting to the possibility that the advertiser will make the assumption that you meet the targeting criteria used to display the ad.
- Except as stated elsewhere in this policy or with your prior consent, DivInsights will not voluntarily trade, share, or sell your personal data with or to anyone else.
TRANSFERRING PERSONAL DATA INTERNATIONALLY
- Due to the international nature of our business, your personal data may be transferred to and processed in jurisdictions outside of Hong Kong, including those that may not offer an equivalent level of data protection as under the PDPO. In such cases, we will ensure that your personal data is processed in accordance with the requirements of the PDPO. This may include implementing appropriate contractual safeguards, such as data protection clauses in agreements with service providers who process personal data on our behalf.
DIRECT MARKETING
- As a voluntary purpose only, and with your consent or indication of no objection, we may use your personal data for the purpose of direct marketing to you in relation to offers and promotions relating to DivInsights and our website.
- Direct marketing may be made by post, e-mail, phone call, SMS text messaging, social media or any other type of media.
- You may opt-out of receiving direct marketing materials from us at any time, free of charge, by contacting us at info@divinsights.com.
- Only personal data regarding your browsing preference, personal information and contact details held by us from time to time may be used by us in direct marketing.
- The following classes of services and products may be marketed:
- investment research services available or contemplated to be made available through our website; and
- trends and news relating to the above.
DATA RETENTION
- We only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. Once your personal data is no longer necessary for the purposes for which we collected it, we will securely delete, destroy, or anonymize it in accordance with our data retention policy. If it is not possible to delete or anonymise your personal data immediately, we will securely store your personal data and isolate it from any further use until deletion is possible. We may, at our discretion and subject to applicable law, dispose of your personal data without notice.
- We may retain certain personal data for longer periods if required by law or if necessary to establish, exercise, or defend our legal rights. In such cases, we will ensure that your personal data is protected and only used for the purposes of fulfilling and complying with our contractual or legal obligations and/or audit requirements and/or to resolve disputes or prevent abuse.
- We understand that you may want to limit the ways in which we collect and use your personal data. You can opt-out of receiving direct marketing materials from us at any time. Additionally, you have the right to object to the processing of your personal data in certain circumstances. If you wish to exercise any of these rights or have any questions regarding your privacy, please contact us at info@divinsights.com.
COOKIES
- A cookie is a small piece of data that a website stores on your device when you visit, typically containing information about the website itself, a unique identifier that allows the site to recognise your web browser when you return, additional data that serves the purpose of the cookie, and the lifespan of the cookie itself.
- Cookies are used to:
- enable certain features (e.g. logging in),
- personalise your content (e.g. advertising, language),
- store your user settings (e.g. time zone, notification preferences); and
- track site usage (e.g. analytics).
- We use cookies to help improve your experience of our Services. The cookie policy is part of the privacy policy of DivInsights and covers the use of cookies between your devices and our website.
- DivInsights also provides basic information on third-party service providers it may use, which may also use cookies as part of their service, though they are not covered by this policy.
- DivInsights may set and access its own cookies on your computer. These cookies are used to personalize your experience with our Services, such as remembering your preferences, logging you in, and tracking your usage of our products and services.
- In addition, DivInsights allows other companies that show advertisements on some of our pages set and access their cookies on your computer. These cookies are subject to the privacy policies of the respective companies and DivInsights has no control over their use.
- You can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.
- Cookies set by the website you are visiting are normally referred to as ‘first-party cookies’, and typically only track your activity on that particular site. Cookies set by other sites and companies (i.e. third parties) are called ‘third-party cookies’ and can be used to track you on other websites that use the same third-party service.
- We may employ third-party companies and individuals to work on our websites – for example, analytics providers and content partners. We grant these third parties’ access to selected information to perform specific tasks on our behalf. The personal data that may be shared includes any personal data described in section 3 above headed “PASSIVE COLLECTION OF YOUR PERSONAL DATA”.
- Third parties may also set third-party cookies in order to deliver the services they are providing. Third-party cookies can be used to track you on other websites that use the same third-party service. As we have no control over third-party cookies, they are not covered by our cookie policy. We review the privacy policies of all our third-party service providers before enlisting their services to ensure their practices align with ours. We will never knowingly use third-party services that compromise or violate your privacy.
- DivInsights also uses web beacons to access DivInsights cookies inside and outside our network of websites and in connection with DivInsights products and services. A web beacon is an electronic image that can be used to recognize a cookie on your computer when you view a web page or email.
LEGAL BASIS FOR PROCESSING
We will only collect, use, share and store your personal data when we have a legal basis to do so. The legal basis for processing your personal data may vary depending on the purpose for which it is being processed. Generally, we will process your personal data for the following purposes:
- To fulfill a contract: We may process your personal data when we need to fulfill a contract with you, such as when you make a purchase or use our Services.
- Legitimate interests: We may process your personal data when it is necessary for our legitimate interests, such as to improve our products and services or to prevent fraud.
- Consent: We may process your personal data when you have given us explicit consent to do so, such as when you sign up for our newsletter.
- Legal and regulatory obligations: We may process your personal data when we are obligated to do so under the applicable legal and regulatory requirements, such as to comply with a court order or a law enforcement request.
In addition, we are committed to respecting and upholding your rights as a data subject. Under applicable data protection laws, you may have certain rights with respect to your personal data, including the right to access, update, correct, delete, or restrict the processing of your personal data, as well as the right to data portability and the right to object and limit the processing and disclosure of your personal data.
To exercise any of these rights, please contact us at info@divinsights.com and we will respond to your request in accordance with applicable data protection laws. Please note that in some cases, we may be unable to fulfill your request, such as where it would interfere with our legal obligations or the rights of others.
YOUR RIGHTS REGARDING YOUR PERSONAL DATA
- You can edit your DivInsights Account Information, including your preferences, at any time by logging in to your account and updating your profile. DivInsights takes reasonable care to keep your personal data accurate and up to date, to the extent that you provide us with the necessary information. If your personal data changes (for example, if you have a new email address), you are responsible for notifying us of those changes.
- Upon request, we will provide you with a copy of the personal data that we hold about you. Registered users can submit such a request by emailing us at info@divinsights.com.
- If you wish to cancel your registration or have your personal data removed from our records, you can do so by sending an email to info@divinsights.com. For privacy and security reasons, requests must come from the email address associated with your registration.
- If your personal data as stored by DivInsights is inaccurate or incomplete, you are entitled to ask us to correct or complete it. If we have shared your incorrect or incomplete personal data with others, we will inform them about the correction where possible. If you request it, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
- You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to our processing of it (please see below for information on your right to object). We will inform you before we lift any restriction on processing. If we have shared your personal data with others, we will notify them about the restriction where possible. If you request it, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
- You have the right to obtain from us your personal data that you consented to give us or that was provided to us as necessary in connection with our relationship with you. We will provide your personal data in a structured, commonly used, and machine-readable format so you may reuse it elsewhere.
- You may ask us at any time to stop processing your personal data.
- If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect any processing of your personal data that has already taken place.
- We reserve the right to send you certain communications relating to the DivInsights service, such as service announcements, administrative messages, and the DivInsights Newsletter, that are considered part of your DivInsights account, without offering you the opportunity to opt-out of receiving them.
If you have a concern about our privacy practices, including the way we handle your personal data, you can report it to the Hong Kong Privacy Commissioner’s Office, or contact the data protection authority in your jurisdiction that is authorized to hear such concerns (details on how to do so can be found on the relevant authority’s website).
LINKS TO OTHER WEBSITES
- This policy does not apply to any third-party sites that may link to, or be accessible from, our website. Your interactions with these sites are governed by the third parties’ applicable privacy notices, statements, or policies. We encourage you to read them.
- You should take additional steps to safeguard your personal data online. To learn more about how to protect yourself, visit the website of the Hong Kong Privacy Commissioner’s Office, or contact the data protection authority in your jurisdiction (details on how to do so can be found on the relevant authority’s website).
SAFEGUARDING YOUR PERSONAL DATA
- We understand the importance of keeping your personal data secure and confidential. We have implemented security measures to safeguard the confidentiality of your personal data, including but not limited to the use of industry-standard SSL encryption to protect data transmissions.
- We take reasonable and appropriate measures to protect your personal data from loss, misuse, unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal data.
- We limit access to your personal data to employees who we reasonably believe need to come into contact with that information on a need-to-know basis in order to provide products or services to you or to perform their job duties.
- As the transmission of personal data via the internet is not completely secure, we cannot guarantee the security of your personal data transmitted to our website and any such transmission is at your own risk. However, DivInsights maintains appropriate technical and organizational measures, including performing regular self-assessments, to prevent unauthorized disclosure of, or access to, personal data. DivInsights limits access to your personal data and requires that employees authorized to access your personal data maintain the confidentiality of that personal data. DivInsights holds its service providers to at least the same data privacy and security standards to which it holds itself.
CHANGES TO THIS POLICY
DivInsights may update this policy from time to time. We will notify you about significant changes in the way we treat personal data by sending a notice to the primary email address specified in your DivInsights account or by placing a prominent notice on our site. We will ensure that each such change is brought to your attention.
CONTACT INFORMATION
If you have any questions, concerns, or complaints about this policy or our data practices, please contact us at info@divinsights.com.
We will reply promptly to every message we receive. The information in any such message is used to respond directly to your questions or comments. We may file your comments and share them with our user care team to improve our service in the future. We commit to resolving complaints about our processing of your personal data.
