Privacy Policy

Last Updated: February 22, 2026

Divine Asset Management (“we,” “us,” or “our”) respects your privacy and is committed to safeguarding the personal information entrusted to us. This Privacy Policy describes how we collect, use, disclose, and protect information obtained through our website, communications, and advisory relationships.

This policy is designed to comply with applicable privacy laws and regulations, including Regulation S-P and relevant state privacy requirements. This policy applies to both current and former clients.

1. Information We Collect

Personal Information

Depending on your relationship with us, we may collect:

  • Name, mailing address, email address, and phone number

  • Financial, investment, and tax-related information (for advisory clients)

  • Information voluntarily provided through forms, scheduling tools, email, or other communications

Non-Personal / Technical Information

We may automatically collect:

  • IP address, browser type, device identifiers

  • Website usage data, referring URLs, and interaction data

  • Information collected via cookies, analytics tools, or similar technologies

2. How We Use Your Information

We use collected information to:

  • Communicate with you and respond to inquiries

  • Provide investment advisory and related services

  • Comply with regulatory, legal, and recordkeeping obligations

  • Operate, maintain, and improve our website and services

  • Send informational or marketing communications (where permitted)

3. Confidentiality of Client Information (Regulation S-P)

Consistent with Regulation S-P, we maintain policies and procedures designed to protect the confidentiality and security of nonpublic personal information (“NPI”) relating to current and former clients.

We do not disclose NPI to non-affiliated third parties except:

  • As necessary to provide advisory services

  • As required or permitted by law

  • With client authorization

4. How We Share Information

We do not sell personal information.

We may disclose nonpublic personal information as permitted by law to service providers and non-affiliated third parties as necessary to provide advisory services. Categories of information that may be disclosed include identifying information (such as name, address, and contact information), financial account information, transaction history, and other information necessary to service your account.

We may share information with:

  • Custodians and broker-dealers

  • Service providers supporting operations (e.g., technology platforms, CRM systems, compliance vendors)

  • Legal, regulatory, or governmental authorities when required

  • Professional advisors (legal, tax, compliance) as necessary

We do not disclose nonpublic personal information to non-affiliated third parties for marketing purposes.

All service providers are required to maintain appropriate confidentiality and data security safeguards.

5. Data Security

We maintain administrative, technical, and physical safeguards designed to protect nonpublic personal information consistent with federal and state regulatory requirements. Access to sensitive information is restricted to authorized personnel only.

No system can be guaranteed to be 100% secure, but we regularly review and update our safeguards.

6. Data Retention

We retain personal information as required to:

  • Provide services

  • Meet regulatory and legal obligations

  • Maintain business and compliance records

As a registered investment adviser, certain records must be retained for legally mandated periods and may not be deleted upon request.

7. Your Rights and Choices

Depending on your jurisdiction, you may have the right to:

  • Request access to personal information we hold

  • Request correction of inaccurate information

  • Opt out of marketing communications

  • Request deletion of certain information, subject to regulatory limitations

Requests may be submitted to:
📧 admin@divineassetmgt.com

8. Cookies, Analytics & Tracking

We may use cookies and analytics tools to improve website functionality and understand usage patterns. You may control cookies through your browser settings. Disabling cookies may affect site performance.

We do not currently respond to browser “Do Not Track” signals.

9. Children’s Privacy

Our website and services are not directed to individuals under the age of 13. We do not knowingly collect personal information from children.

10. Third-Party Websites

Our website may include links to third-party sites. We are not responsible for their privacy practices. Please review their policies independently.

11. Changes to This Policy

We may update this Privacy Policy periodically. The revised version will be posted on this page with an updated effective date. Continued use of our website constitutes acceptance of the updated policy.

12. Contact Information

For any questions about this Privacy Policy or how we manage your information, contact us:

Divine Asset Management
📧 admin@divineassetmgt.com