Review history
Version 2.0, in force from 3 November 2026: the cookie policy is now part of this policy. It now covers tutoring and lessons, adds how we treat AI tools and your data, states plainly what the delivery server records about campaigns, and no longer links to other websites.
Version 1.0, in force from 23 October 2026: first published, with a separate cookie policy.
We review this policy at least once a year and whenever the way we use data changes.
Who is responsible for your data?
The company that operates Dividario is responsible for the personal data collected through this website and through tutoring. In data protection terms, it is the controller: it decides why and how the data is used. The service providers that run this website and our email act only on our instructions.
Questions about privacy go to the same email address as everything else. You'll also find it on our contact page.
Our email address is consulting@dividario.com.
What information do we collect?
We collect three kinds of personal data: technical data that the server delivering our pages records when you visit, anything you send us by email, and, if you take tutoring, what you choose to share in lessons. The site has no forms, accounts or newsletter, and its pages contain no analytics tools, so there is nowhere else to give us information.
When you visit the website
The server that delivers our pages also records which of our campaigns or links brought each visit. It records these details automatically:
- your IP address;
- your browser and device type, and its operating system;
- your browser's language setting;
- the page you came from (the referring page);
- your approximate location, worked out from your IP address, such as the country or city, never your street address;
- the parameters in the link you followed, which tell us which campaign it belonged to;
- the date and time of the visit.
When you email us
We receive your email address, your name and anything in your email signature, and whatever you write or attach.
Please don't send passwords, bank login details or identity documents by email. We never need them.
When you take tutoring
We receive your name, your email address and the questions, notes and documents you choose to share in lessons. You decide what to share, and you can blank out anything you'd rather keep private. Lessons never need passwords, account numbers or copies of ID.
What we don't collect
- We have no forms, accounts or newsletter, so we hold nothing you've typed into the website.
- Our pages contain no analytics or advertising tools, and we don't build profiles of visitors.
- We don't ask for identity documents, account details or other sensitive information.
All of this comes directly from you or from your device.
Why do we use your data, and on what basis?
We use visit data to deliver the pages, to see which campaigns bring visitors and to protect the site against abuse and automated bots. We use your emails to reply to you and, if you take tutoring, to arrange and give the lessons. The table below gives the lawful basis for each purpose.
| Purpose | Data used | Lawful basis |
|---|---|---|
| Delivering the website's pages to your device | Visit data | Legitimate interests: running a website that people can read. |
| Seeing which campaigns bring visitors | Visit data, especially the campaign link parameters, the referring page and the time | Legitimate interests: understanding which campaigns work, using visit statistics rather than profiles of individuals. |
| Protecting the site against abuse and bots | Visit data, especially the IP address, device details and time | Legitimate interests: keeping the site, its visitors and our systems safe. |
| Replying to your email | Your email address, name and message | Legitimate interests in answering people who contact us, or steps you ask us to take before a tutoring agreement. |
| Arranging and giving tutoring | Your contact details, our correspondence and what you share in lessons | Performance of a contract with you, or steps you ask us to take before one. |
| Keeping the records the law requires | Correspondence and tutoring records | Legal obligation, for example accounting and tax record-keeping rules. |
Where we rely on legitimate interests, we have weighed our interests against your rights and what you would reasonably expect. You can object at any time: see your rights.
We don't use your data for marketing, and we don't make decisions about you by automated means.
Do we put your data into AI tools?
No. We don't enter learners' names, contact details, or the documents and figures they share with us into AI tools. In lessons on using AI, you work in your own AI assistant with public documents or made-up figures, and we show you how to keep private data out of it.
Any AI assistant you use is a separate service with its own privacy terms, which we don't control. Check them before you use it.
Do we share your data with third parties?
No. We don't pass your data to third parties, and we never sell, rent or trade it. The only outside organisations that handle it are the service providers that run this website and our email for us, acting on our instructions under contract. Public authorities receive it only when the law requires.
| Type of provider | What it does |
|---|---|
| Website delivery provider | Runs the servers that deliver our pages, records visit data and filters out abusive traffic |
| Email provider | Stores and delivers the emails you send us and our replies |
Our service providers may not use your data for anything except providing their service to us. We disclose personal data to courts, regulators, the police or other public authorities only where the law requires us to, and we tell you about it where the law allows.
Is your data sent to other countries?
Possibly. Our service providers may store or access data in a country other than yours. Where data protection law requires it, we allow this only when that country is recognised as protecting data adequately, or when standard contract terms approved for that purpose, or another recognised safeguard, are in place.
You can ask us for details of the safeguard that applies to your data.
How long do we keep your data?
We keep visit data for a limited period, and no longer than needed to deliver the site, measure our campaigns and protect against abuse. We keep emails and tutoring records for as long as we need them, and longer only where the law requires us to keep records.
| Data | How long |
|---|---|
| Visit data recorded by the delivery server | For a limited period, and no longer than needed for delivering the pages, campaign statistics and protection against abuse |
| Emails from people who don't take tutoring | As long as needed to deal with the enquiry, and any longer period the law requires us to keep records |
| Correspondence and records of tutoring | As long as needed for the tutoring, and any longer period the law requires us to keep records |
When a period ends, we delete the data or make it permanently anonymous.
What are your rights?
Depending on where you live, you may have the right to see the personal data we hold about you, correct it, have it deleted, limit how we use it, receive a copy in a portable format and object to how we use it. Using these rights costs you nothing, and you can ask by email.
- Access: ask for a copy of the personal data we hold about you and how we use it.
- Correction: ask us to correct data that is wrong or incomplete.
- Deletion: ask us to delete your data, for example when we no longer need it.
- Restriction: ask us to keep your data but stop using it, for example while we check a correction.
- Portability: receive data you gave us in a common machine-readable format, or ask us to send it to someone else.
- Objection: object to any use based on our legitimate interests. We must then stop unless we have compelling grounds or need the data for a legal claim.
- Complaint: complain to a data protection authority. See how to complain.
To use any of these rights, email us and say what you'd like us to do. We may ask you to confirm your identity before we act, so that we don't give your data to someone else.
Our email address is consulting@dividario.com.
Visit data is linked to an IP address rather than a name, so to find it we may need your IP address and the date and time of your visit.
We reply within the time limits that data protection law sets. If a request is complex and the law allows more time, we'll tell you why and when to expect a full reply.
How do you complain about our use of your data?
Contact us first: most concerns can be sorted out quickly by email. If you're not satisfied with our answer, or you'd rather not come to us, you can complain to a data protection authority, usually the one in the country where you live or work, or where you think the problem happened.
Our email address is consulting@dividario.com.
You don't have to contact us before going to an authority, but it is often the quickest way to put things right.
How do we keep your data safe?
The site is served over an encrypted (HTTPS) connection. Access to visit data, our email and tutoring records is limited to the people who need it for the purposes on this page.
No system is perfectly secure. If a breach ever puts your rights at risk, we will tell you, and the data protection authority, where the law requires it.
Email is not a secure way to send sensitive information. Please don't send us passwords, bank login details or identity documents.
Children
This website and our tutoring are for adults and are not aimed at anyone under 18. We don't knowingly collect personal data from children. If you believe a child has emailed us, tell us and we will delete the message.
Changes to this policy
We update this policy when the law, our services or our service providers change. Each version has a number and the date it took effect, shown under the heading, and the review history at the top of this page says what changed. If you need an earlier version, ask us by email and we'll send it to you.