Privacy Policy
1. Who is responsible for your data?
The data controller during the pre-registration phase is Sebastian Mandrysz, operating the DIVENIQ project. KVK registration number and legal-form details will be added after formal registration.
Privacy contact: hello@diveniq.com.
2. What data do we process?
When you join the waitlist, we process only the data needed to operate the email subscription:
- your email address;
- your optional description of the hardest part of your research process;
- your consent selection and subscription status;
- the date and time of form submission and double opt-in confirmation;
- records needed to send, deliver and unsubscribe from waitlist emails.
If you separately allow optional analytics, we also process page paths without query parameters, page titles, general browser and device information, approximate location, visit timing and a randomly generated analytics identifier. We do not send your beta-form responses to Google Analytics.
3. Why do we process it?
We use your email and subscription records to verify your subscription, manage the DIVENIQ private-beta list and send product, demo and beta updates. If you choose to answer the optional research question, we may use your response to understand user research needs and improve DIVENIQ.
The legal basis is your consent under Article 6(1)(a) GDPR. Joining is voluntary. You can join without answering the optional research question. If you do not provide and confirm your email address, you will not be added to the waitlist.
Optional website analytics has a separate consent. Refusing analytics does not affect access to the website or the waitlist.
4. Brevo as our email provider
We use Brevo to receive waitlist submissions, run the double opt-in process, store the mailing list, send emails and keep subscription records. Data submitted through the form is transferred directly to Brevo, which acts as an email-marketing service provider and data processor on our behalf.
More information is available in Brevo's Privacy Policy and its Data Processing Agreement information.
Brevo's Data Processing Agreement (DPA) applies automatically as part of its Terms of Service; no additional signature or activation is required. Brevo maintains its current list of subprocessors in the DPA annex.
According to Brevo support, its core infrastructure and databases, including contact data, double opt-in confirmations and related email-delivery records, are processed and stored in the EU by default. Primary hosting uses Google Cloud in Belgium and European providers Scaleway and OVH in France. Limited support or technical-maintenance access may occur outside the EEA, including from the United States, Canada and India. International transfers are protected by Standard Contractual Clauses and, where applicable, the EU-US Data Privacy Framework, together with supplementary measures such as data minimization and encryption.
5. How long do we keep the data?
- An active contact is kept until you unsubscribe or the DIVENIQ waitlist and launch-update purpose ends.
- An unconfirmed double opt-in submission is deleted after 30 days.
- If you unsubscribe or withdraw consent, further waitlist emails are suppressed immediately and your contact is removed from the active mailing list.
- Only the minimal consent or opt-out record is retained for as long as needed to demonstrate consent and opt-out compliance and prevent unwanted messages.
- The analytics consent choice remains in your browser until you change it. If allowed, DIVENIQ limits Google Analytics cookies to 90 days and configures user- and event-level analytics retention to 2 months.
6. Your rights
You may request access to, correction of, deletion of, restriction of or portability of your personal data where applicable. You may object to direct marketing and withdraw consent at any time without affecting processing that took place before withdrawal.
Privacy and data-subject requests are handled through hello@diveniq.com. We may request information reasonably necessary to verify your identity before acting on a request. Access, rectification, deletion and other applicable GDPR rights are handled through this channel. You may also lodge a complaint with the Dutch Data Protection Authority.
7. Unsubscribing
Every marketing email will include an unsubscribe link. You can also withdraw consent by contacting hello@diveniq.com.
8. Automated decisions and sale of data
We do not use waitlist data for automated decision-making and we do not sell it.
9. Optional analytics and hosting data
DIVENIQ uses Google Analytics 4 only after you select “Allow analyticsâ€. Until then, the Google tag is not loaded and no analytics data is sent to Google. Advertising storage, advertising user data, ad personalisation and Google Signals are disabled. You can withdraw consent at any time through “Analytics settings†in the footer; analytics cookies are then removed and the tag stays blocked on later page loads.
When analytics is allowed, Google LLC provides the analytics service. The Google tag may set cookies beginning with _ga and receive the limited website-use information described above. Google uses IP addresses at collection time to derive approximate location and says those IP addresses are discarded before the data is logged. See Google's Privacy Policy and Google Analytics privacy information.
Public deployment is planned on TransIP webhosting, which is hosted in the Netherlands according to TransIP support. The hosting service mainly generates access and error logs containing IP addresses. These logs are retained for 3 days, and this retention cannot be configured or disabled. TransIP support also confirmed that it currently has no subprocessors or employees outside the EEA with access to these data.
10. Effective date and changes
Effective date: 2026-10-12.
We will update this policy if the waitlist process, providers or legal requirements change.