Loading...
Last Updated: 29/07/2026 · Version: 2026-07-29-v3
Divvio ("we", "us", or "our") is committed to protecting your privacy. We understand that you are trusting us with your most sensitive personal and financial information during a difficult time. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our web application (the "Service").
Please read this policy together with the short privacy information shown when you choose optional sharing inside Divvio.
Kintela Ltd, trading as Divvio, is the controller responsible for the processing described in this policy as Divvio's processing. A named mediator or practice is a separate controller for mediation information made accessible to it as explained below.
Email: support@divvio.co.uk
Address: Unit 82a James Carter Road, Mildenhall, Bury St. Edmunds, England, IP28 7DE
We collect various types of personal data to generate your Form E (Financial Statement). This includes:
We will only use your personal data when the law allows us to. Most commonly, we use your personal data in the following circumstances:
| Purpose | Type of Data | Lawful Basis for Processing |
|---|---|---|
| To register you as a new user | Identity, Contact | Performance of a contract |
| To generate your Form E PDF | Identity, Financial, Special Category, Documents | Performance of a contract for ordinary personal data; Article 9(2)(f) where special-category data is necessary to establish, exercise or defend legal rights |
| To provide AI assistance to a Form E user | Identity, Financial, User Queries | Consent; Legitimate Interests (to improve service accuracy) |
| To analyse supporting documents, create structured document summaries, and allow the named mediator to ask questions about the shared mediation case | Identity, Mediation Case, Financial, Documents, User Queries, Special Category where included | Consent for the account holder's ordinary personal data; explicit consent for special-category information about that account holder. Information about other people relies on the separate bases explained below. |
| To process payments | Contact, Financial, Transaction | Performance of a contract |
| To manage our relationship with you | Identity, Contact | Performance of a contract; Legal obligation |
| To share case-specific progress with the mediator you name | Identity, Mediation Case, Usage | Consent |
| To share your completed disclosure, financial schedule and attached supporting documents with the mediator you name for preparation and conduct of your mediation | Identity, Mediation Case, Financial, Documents, Special Category where included | Consent for the account holder's ordinary personal data; explicit consent for special-category information about that account holder. Information about other people relies on the separate bases explained below. |
| To retain the mediation consent audit and versioned schedules after withdrawal or case closure | Identity, Mediation Case, Financial, Consent records | Legitimate interests in consent accountability, service and data-sharing claims, and record consistency; Article 9(2)(f) only where retained special-category data is necessary for legal claims |
| To understand which pages and sources help users start Form E, sign up, and complete payment | Usage and Attribution Data, Technical Data, Transaction Data | Legitimate interests; consent where cookies or similar technologies require it |
If a user gives us relevant information about another person in a Form E or supporting document, we use it only to prepare, organise and, where authorised, share that financial disclosure. Our Article 6 basis is our legitimate interest in providing the requested service. Where another person's special-category information is necessary for legal rights, we rely on Article 9(2)(f). We do not treat the account holder's consent as consent given for another person.
Where Article 14 applies, Divvio must give that person privacy information within the required period unless a specific statutory exception applies. Before mediation disclosure is enabled, our launch process requires an approved and operational procedure either to provide that information safely or to record a case-specific exception, including its necessity, proportionality, risks and safeguards. Anyone may contact us to ask whether we hold information about them and exercise applicable rights.
Divvio uses contracted Artificial Intelligence API providers for specific assistance, document-analysis and mediation-case features.
When a Form E user asks the "Ask Divvio" assistant a question, relevant questionnaire information and the question are sent to the configured AI provider. When the named mediator uses the case assistant, Divvio rebuilds the current authorised case context for each request from the parties' shared Form Es, financial schedules, readiness, Review Centre state and any available document summaries.
Before ordinary case-chat text is sent, Divvio replaces known names, contact details, dates of birth, addresses and account identifiers with reversible labels. The provider sees those labels; the mediator sees the authorised real values after the answer returns. This is pseudonymisation, not anonymisation. Free text can name a person who does not appear in a structured field, so pseudonymisation is a defence in depth rather than the legal basis for the processing.
An uploaded statement or scanned document is different: its identifiers can be part of the image itself and cannot be replaced before a provider reads it. A document that has passed Divvio's security review may therefore be sent in its original form to the configured document-analysis provider. The same analysis can produce a short structured summary stored against the exact source file. Later case-assistant requests use a pseudonymised copy of that summary rather than resending the original file.
Divvio configures the contracted API services used for these features not to use submitted content to train general models. Mediator case chat uses stateless requests and does not create a provider-side assistant conversation. Stateless does not necessarily mean that no provider log exists: security or abuse-monitoring logs may retain submitted content for a limited period depending on the contracted provider and the account-level retention controls in force. The current provider, processing location, maximum retention period and transfer safeguards can be requested from support@divvio.co.uk.
The AI provides information and drafting assistance only. It does not make legal decisions or automated judgments about your case.
We have put in place appropriate security measures to prevent your personal data from being lost, used, or accessed in an unauthorized way.
We may share your personal data with the parties set out below for the purposes set out in Section 2:
Some providers may process personal data outside the United Kingdom. The locations and safeguards depend on the provider, service and configuration in use. Before relying on a provider for a restricted transfer, we must verify and record the applicable arrangement. Depending on the circumstances, that may be UK adequacy regulations, the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, together with any required transfer assessment. You may request the current verified information from support@divvio.co.uk.
Lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services (only if strictly necessary).
If you use a partner referral link, that partner may receive aggregated referral, conversion, product, and commission status needed to operate the programme. We do not disclose your Form E answers, documents, financial figures, court details, email address, or generated PDF through the partner dashboard.
Joining a mediation case does not share your answers or documents. You can separately opt in to share (1) Form E completion percentage and recent activity, and (2) your complete current Form E, including narrative and personal circumstances, the schedule created from it, and supporting documents attached to that Form E. The recipient is named beside each choice and sharing is limited to that mediation case. The second choice uses an express statement because material you provide may contain health information or other special category data.
If the case AI features are enabled, the second choice also permits Divvio to send security-cleared supporting documents to a contracted AI provider for analysis, store structured summaries against the source files, and supply pseudonymised copies of the complete shared Form E, case state and those summaries to the mediator's case assistant. The mediator receives the answer with the authorised names and identifiers restored. The case assistant is analytical support only: it does not make a legal decision, determine a fair settlement or replace the mediator's professional judgment.
The other party cannot open your supporting documents through Divvio. A combined schedule is available only after both parties separately consent. Divvio and the named mediator or practice are separate controllers for different processing. Divvio operates the platform, records your choices, maintains access records and applies Divvio's retention rules. The mediator or practice becomes an independent controller when it can access the information through Divvio, including when it views, downloads or places it in its professional case file. It is responsible for its own lawful basis, privacy notice, security, permitted disclosures, handling of rights and retention.
Contact Divvio about information retained in Divvio and the mediator or practice about its professional case file. You can withdraw either sharing permission in Settings at any time. Withdrawal stops future access and new sharing through Divvio and does not affect earlier lawful processing. It cannot recall a downloaded file, erase the mediator's independently controlled case file, or automatically erase records Divvio lawfully retains on another basis.
HM Revenue & Customs, regulators, and other authorities if required by law.
We do not sell your data to third parties.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Under the UK GDPR, you have rights in relation to your personal data, including:
To exercise any of these rights, please contact us at support@divvio.co.uk.
You can withdraw mediation sharing directly in Settings. This is as easy as granting it. Once Divvio records the withdrawal, it stops future access and new sharing through Divvio.
You may complain to us if you believe we handled information incorrectly. You also have the right to complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint or on 0303 123 1113. You do not lose that right by contacting us first.
This website may include links to third-party websites (e.g., Gov.uk, MoneyHelper). Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
We keep our privacy policy under regular review. This version was last updated on 29/07/2026. Historic versions can be obtained by contacting us.
If you have any questions about this Privacy Policy, please contact us.