Cybersecurity & Artificial Intelligence Use Disclosure

Effective Date: January 1, 2026

Divine Asset Management (“Divine”) uses technology to support secure operations, regulatory compliance, and high-quality client service. Divine remains a human-led investment advisory firm and does not delegate fiduciary responsibility or investment decision-making to automated systems.

Cybersecurity & Protection of Client Information

Consistent with U.S. Securities and Exchange Commission Regulation S-P, Divine maintains administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and security of nonpublic personal information.

Our cybersecurity practices are designed to scale with the size, complexity, and scope of the firm and include:

  • Controlled access to systems and data

  • Secure, cloud-based infrastructure

  • Oversight of third-party technology and data service providers

  • Periodic review of information security and data-handling practices

Divine retains and protects client records in accordance with applicable regulatory and legal requirements.

Cybersecurity Incident Awareness & Response

Divine maintains procedures designed to identify, assess, and respond to unauthorized access to or misuse of sensitive client information.

In the event of a reportable data security incident, Divine will act in accordance with applicable regulatory, legal, and notification requirements.

Use of Artificial Intelligence & Automation

Divine may use limited automation or AI-enabled tools to support internal business functions such as administrative workflows, document organization, research assistance, and content preparation.

AI tools are not used to:

  • Provide personalized investment advice

  • Make or implement investment decisions

  • Trade client accounts

  • Replace human judgment, discretion, or fiduciary oversight

All investment advice and portfolio decisions are reviewed and approved by a qualified human adviser.

AI Risk Management & Data Controls

Consistent with emerging SEC guidance related to artificial intelligence, predictive data analytics, and conflicts of interest, Divine seeks to:

  • Maintain human oversight over all advisory functions

  • Limit AI use to low-risk, non-client-decision activities

  • Avoid conflicts of interest introduced by automated systems

  • Protect client confidentiality when engaging third-party technology providers

Divine does not knowingly input client nonpublic personal information into public or unrestricted AI systems.

Ongoing Review & Governance

Divine periodically reviews its cybersecurity and technology practices to ensure alignment with evolving regulatory expectations, operational risk considerations, and fiduciary obligations as our firm grows.

Questions

For questions regarding this disclosure or Divine’s cybersecurity practices, please contact:
📧 admin@divineassetmgt.com