Privacy Policy

1. Introduction

DIVUZL DIGITAL SOLUTIONS PRIVATE LIMITED (“Divuzl”, “Company”, “we”, “us” or “our”) is committed to protecting personal information and respecting the privacy of individuals who interact with our website, products, services and business operations.

This Privacy Policy explains how we collect, use, process, store, disclose, retain and protect personal information, and the rights and choices available to individuals under applicable privacy laws.

It applies to individuals who visit our website, enquire about our services, engage us as clients, apply for employment or internships, participate in our programmes, work with us as vendors or partners, or use our software products, including Divuzl Care.

By using our website or services, you acknowledge that this Policy has been made available to you. Where applicable law requires consent, we will obtain consent through an appropriate mechanism.

2. Company Information

• Legal name: DIVUZL DIGITAL SOLUTIONS PRIVATE LIMITED
• Entity type: Private Limited Company
• Date of incorporation: 2 July 2025
• Website: https://divuzl.com
• Privacy and contact email: [email protected]

Address recorded in the Certificate of Incorporation: C/O Amit Kumar Singh, Behta Madho, Dataganj, Dataganj, Budaun – 243635, Uttar Pradesh, India.

3. Scope of This Policy

This Policy applies to personal information processed in connection with:

• Our website and associated digital platforms.
• Business enquiries, contact forms and quotation requests.
• Client onboarding, contracts and service delivery.
• Branding, website development and technology projects.
• Digital marketing, lead generation and advertising campaigns.
• Recruitment, internships, campus ambassador programmes and events.
• Vendor, partner and other business relationships.
• Divuzl Care and other digital products, subject to applicable product-specific terms.

Where Divuzl processes information on behalf of a client, the applicable service agreement and Data Processing Agreement may further define our responsibilities. This Policy does not govern independent third-party websites or services that operate under their own privacy policies.

4. Personal Information We Collect

4.1 Information provided directly

This may include your name, professional designation, email address, telephone number, company and business details, address, website and professional profile links, enquiry and onboarding submissions, project briefs, communications, quotations, contracts, project records, feedback, billing contacts, invoices, payment status, CVs, portfolios, employment information, event registrations and programme participation details.

4.2 Information collected automatically

When you visit our website or use our digital services, we may collect IP address, browser and device information, operating system, pages visited, referring websites, timestamps, session identifiers, website interaction and performance information, approximate location derived from IP address, and cookie identifiers or similar technology data. The information actually collected depends on the website configuration and tools enabled.

4.3 Information from third parties

Where lawful, we may obtain relevant business contact information from publicly available business directories, professional networking platforms, referrals, recruitment services, event organisers, advertising platforms and authorised business partners.

4.4 Financial and transaction information

We may maintain invoices, transaction references, billing information and payment status for accounting and service administration. Payment credentials should be submitted through authorised payment channels rather than ordinary email or chat. We do not intentionally collect unnecessary passwords, banking credentials or sensitive personal information through general enquiry forms.

5. Purposes of Processing

We may use personal information to:

1. Respond to enquiries and prepare proposals.
2. Deliver consulting, branding, marketing and technology services.
3. Manage client accounts, contracts and projects.
4. Coordinate project communications, approvals and deliverables.
5. Prepare invoices and maintain financial records.
6. Operate, secure and improve our website and products.
7. Measure website traffic and advertising performance.
8. Manage leads and communicate relevant services.
9. Administer recruitment, internships and events.
10. Manage vendors, partners and business relationships.
11. Detect fraud, unauthorised access and misuse.
12. Comply with legal obligations and resolve disputes.

We will not use personal information for materially unrelated purposes without an appropriate legal basis and any additional notice or consent required by law.

6. Legal Basis for Processing

Where applicable law requires a legal basis, our processing may rely on consent for specified purposes; necessity to enter into or perform a contract; compliance with legal obligations; legitimate interests where recognised by applicable law and appropriately balanced against individual rights; or other lawful grounds or statutory exceptions applicable to the circumstances.

For processing governed by India's Digital Personal Data Protection Act, 2023 (“DPDP Act”), Divuzl will comply with the provisions applicable to the relevant processing at the relevant time. The DPDP Act and Digital Personal Data Protection Rules, 2025 have phased commencement arrangements. Their applicability should be assessed against official commencement notifications and the date of processing.

Where UK GDPR, EU GDPR or applicable US state privacy legislation applies, additional requirements may govern lawful bases, notices, individual rights and international transfers.

7. Consent and Communication Preferences

Where consent is required, Divuzl will seek consent for the relevant purpose and provide appropriate information about the processing. You may withdraw consent, where applicable, by contacting [email protected] or using the relevant consent-management controls.

Withdrawal does not invalidate processing lawfully carried out before withdrawal. We may continue processing information where another lawful basis permits or requires it. Where required, we will maintain records of consent and withdrawal and provide appropriate ways to manage communication preferences.

If you submit an enquiry or lead form, we may contact you by phone, SMS or WhatsApp about your request.

8. Cookies, Analytics, Advertising and Tracking Technologies

Divuzl may use cookies, pixels, tags, scripts, software development kits (SDKs), server-side integrations and similar technologies on our website and digital platforms. These technologies may help us operate the website, understand visitor behaviour, manage consent, improve user experience and evaluate marketing activities. The tools described below are used only to the extent they are actually enabled and configured.

Currently active on divuzl.com: Vercel Web Analytics, provided by Vercel Inc., which hosts our website, and Cloudflare Web Analytics, provided by Cloudflare, Inc., our network provider. Both measure page views in aggregate and do not set cookies on your device. Vercel Web Analytics runs only if you choose “Accept all” in our cookie banner. The other tools described in this section are used only where and when they are enabled.

8.1 Google Analytics 4

Divuzl uses or intends to use Google Analytics 4 (GA4), a web analytics service provided by Google, to understand how visitors interact with our website. Depending on our configuration, GA4 may collect page views, referral sources, campaign information, browser and device information, approximate geographical information, session and analytics identifiers, engagement events, form submissions where configured, and technical information used to improve website performance.

Google Analytics may use first-party cookies and similar technologies to distinguish visitors and measure website usage. The information processed depends on our settings and enabled features. See Google's Privacy Policy and Google's explanation of information from sites and apps.

8.2 Google Tag Manager

Divuzl may use Google Tag Manager to manage website tags and measurement integrations. Tags deployed through it may collect or transmit information according to their respective configurations and privacy policies. We will configure tags to respect applicable consent requirements. Google Tag Manager is included here as a potential tool and is not represented as installed unless confirmed.

8.3 Google Ads and conversion tracking

Where Google Ads is used, conversion tracking may help us understand whether visitors complete actions after interacting with an advertisement. Depending on configuration, this may involve advertising clicks, campaign identifiers, enquiries, registrations and other conversion events. Where enabled and permitted, Google Ads may also support remarketing or personalised advertising. See Google's advertising privacy information. These features are conditional on actual implementation.

8.4 Meta Pixel and Meta Business Tools

Divuzl uses or intends to use Meta Pixel and related Meta Business Tools for advertising measurement and campaign optimisation, where enabled. These tools may help us understand website interactions following advertisements on Facebook, Instagram or other Meta services. Depending on the integration, events may include page views, landing-page visits, contact or enquiry submissions and lead form completions. Information transmitted may include event data, page URLs, browser information, identifiers and timestamps. See Meta's Privacy Policy.

8.5 Meta Conversions API

If Divuzl implements Meta Conversions API or another server-side conversion integration, relevant events may be transmitted from our server or an authorised provider to Meta. Depending on the implementation, event names, timestamps, event identifiers, source information and permitted matching information may be included. Any matching information must be handled in accordance with applicable law, required permissions and Meta's terms. Server-side tracking will not be used to bypass valid privacy choices. This integration is conditional on actual implementation.

8.6 LinkedIn Insight Tag and other advertising platforms

Divuzl may use LinkedIn Insight Tag or comparable technologies from other advertising platforms if introduced and enabled. Such tools may support campaign measurement, conversion tracking, audience analysis and advertising optimisation. Their use will be reflected in relevant disclosures when applicable.

8.7 CRM, enquiry forms and lead tracking

When you submit a contact form, quotation request, advertisement lead form or other business enquiry, we may record the information you provide in our CRM or another authorised business platform. This may include your name, business contact details, company information, enquiry, requested services and communication history. Where configured, we may also record the source of an enquiry, such as a referring webpage, campaign identifier or advertising channel.

8.8 Cookie categories

• Strictly necessary: Required for essential website functionality, security, session management or services you request.
• Analytics: Used to understand website traffic, engagement, navigation and technical performance.
• Advertising and conversion: Used to measure advertising performance and conversions and, where enabled, support remarketing.
• Preference: Used to remember selected settings and improve the user experience.

8.9 Consent and tracking controls

Where required by law, we will obtain appropriate consent before activating non-essential cookies and tracking technologies. Our consent mechanism should allow visitors to accept or reject non-essential categories and change preferences later. Where applicable, Google Consent Mode or equivalent controls may be configured so supported Google tags respond to consent choices. Consent Mode is not a substitute for a consent banner or for obtaining consent where required. Meta Pixel and other integrations will also be configured to respect applicable consent requirements.

8.10 Data sharing and retention

Analytics and advertising information may be processed by the relevant providers under their applicable terms. Retention depends on the provider, cookie type, account settings and event configuration. We will configure retention settings where available and retain information only as necessary for the relevant purposes and legal obligations.

8.11 No guaranteed anonymity

Analytics and advertising tools may use pseudonymous identifiers or other information that can relate to a device or browser. We will not describe information as anonymous unless individuals are no longer identifiable by means reasonably likely to be used.

8.12 Changes to tracking technologies

We may add, remove or modify tracking technologies as our business requirements evolve. Where a change requires additional notice or consent, we will take the steps required by applicable law and update the Cookie Policy and consent interface.

9. Third-Party Technology Providers and Integrations

Depending on our actual configuration, Divuzl may use third-party providers for:

• Vercel: Website hosting and privacy-friendly page-view analytics (Vercel Web Analytics).
• Cloudflare: Content delivery, security and cookieless page-view analytics (Cloudflare Web Analytics).
• Google Analytics: Website analytics and visitor engagement measurement.
• Google Tag Manager: Management of website tags and tracking integrations, if enabled.
• Google Ads: Advertising, conversion measurement and, where enabled, remarketing.
• Meta Business Tools: Advertising measurement, campaign optimisation and conversions.
• LinkedIn: Professional marketing and campaign measurement, if enabled.
• Hosting and cloud providers: Hosting, storage, availability and infrastructure.
• CRM and sales platforms: Lead management, customer communications and sales administration.
• Email and communication providers: Business communications and customer support.
• Project management platforms: Client delivery, task management and collaboration.
• Payment providers: Payment processing and transaction administration.
• Security and monitoring providers: Fraud prevention, system security and technical diagnostics.

This list identifies providers or categories that may be relevant to Divuzl's operations; it does not confirm that every provider is currently installed or active. Third-party providers may act as processors, independent controllers or other legally recognised recipients depending on the service. Where required, we will establish appropriate contractual safeguards and provide additional disclosures.

10. Disclosure of Personal Information

We may disclose relevant personal information to service providers; authorised personnel; clients and their representatives; professional advisers; government, regulatory, judicial or law-enforcement authorities where legally required or permitted; parties involved in a business transaction; and other recipients where you authorise disclosure or another lawful basis applies.

We do not sell personal information for monetary consideration as a routine business practice. Where applicable law regulates advertising-related disclosures as a sale or sharing, we will comply with relevant disclosure and opt-out requirements.

11. Divuzl Care and Healthcare Data

Divuzl Care is a clinic and healthcare-practice management software product. Depending on the features used, it may process clinic, doctor, staff, appointment, patient and practice-administration information. This may include patient names and contact details, appointment schedules, visit records, medical history, diagnoses, prescriptions, clinical notes, doctor and staff account information, billing records, and user access or audit logs.

11.1 Roles and responsibilities

The clinic or healthcare provider will generally determine the purposes for which patient information is collected and used. Depending on applicable law and the contract, the clinic may act as the relevant data fiduciary or controller, while Divuzl may act as a data processor or service provider. The precise roles depend on the processing activity and contractual terms.

11.2 Permitted processing

Where Divuzl acts as a processor, it will handle information according to the applicable agreement, documented instructions, access permissions and legal requirements. Divuzl does not intend to use identifiable patient records for unrelated advertising or independent commercial purposes.

11.3 Clinic responsibilities

Clinics are responsible for providing appropriate patient notices, obtaining required permissions, maintaining accurate records, determining authorised access and meeting their professional and legal obligations.

11.4 Security and access

Access to patient and clinic information should be limited to authorised users. Relevant safeguards may include role-based access controls, authentication, access logging, secure backups and technical monitoring, depending on product configuration.

11.5 Retention, export and deletion

The applicable product agreement should define how clinic information is retained, exported, returned and deleted when an account or subscription ends, including treatment of backups and legally required records.

11.6 Separate product documentation

Divuzl Care should have a separate product-specific Privacy Notice and Data Processing Agreement explaining the parties' roles, data categories, subprocessors, security measures, retention periods, incident reporting, data export and deletion procedures.

12. Confidentiality of Client Information

Clients may provide confidential business plans, customer lists, financial information, internal documents, project credentials and other commercially sensitive material. We use such information for authorised service delivery, account administration and related lawful purposes. Access should be restricted to authorised personnel and providers who need it. Additional confidentiality obligations may be set out in service contracts and non-disclosure agreements. Clients should avoid sending passwords, private keys or unnecessary sensitive information through unsecured channels.

13. Recruitment, Internships and Events

When individuals apply for employment, internships, campus ambassador programmes, virtual live projects or other opportunities, we may process their contact details, CVs, portfolios, educational qualifications, work experience, interview records and programme participation information. We use such information to evaluate applications, communicate with candidates and administer the relevant programme or employment relationship. Access will be restricted to authorised personnel and relevant service providers. Information will be retained only as justified by recruitment needs, legal obligations or other lawful purposes.

14. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, subject to applicable legal and contractual obligations. Retention may depend on the duration of a client relationship, status of an enquiry, financial recordkeeping requirements, recruitment needs, security and dispute-resolution requirements, product-specific arrangements and statutory retention periods.

When information is no longer required, we will take appropriate steps to delete, anonymise or securely dispose of it, subject to lawful retention requirements. Backup copies may remain for a limited period under our backup and recovery processes. Specific retention periods should be documented internally and disclosed where required by law.

15. Data Security

Divuzl uses reasonable technical and organisational measures designed to protect personal information against unauthorised access, disclosure, alteration, loss, destruction and misuse. Depending on the system and risk involved, measures may include role-based access controls, authentication, encryption in transit and where appropriate at rest, security logging, backups, software updates, vulnerability management, confidentiality obligations, vendor due diligence and incident response procedures.

No system can be guaranteed to be completely secure. We will take appropriate measures consistent with applicable law and contractual commitments. Where a personal data breach occurs, we will assess and respond to it and notify affected individuals and relevant authorities where required by applicable law.

16. International Data Transfers

Divuzl serves or may serve clients in India, the United Kingdom, the United States, Singapore, Australia, the European Union and other markets. Personal information may be processed in different countries through our systems or third-party providers.

Where international transfers are subject to legal requirements, we will implement the required safeguards, contractual mechanisms and other measures. For transfers governed by UK GDPR or EU GDPR, this may include an adequacy decision, appropriate contractual safeguards or another legally recognised transfer mechanism, where applicable. International transfers involving Divuzl Care or client information will also be governed by applicable product and client agreements.

17. Your Privacy Rights

Depending on your location, applicable law and our role in processing the information, you may have rights to request access, correction, deletion or erasure; withdraw consent; request portability where provided by law; object to or restrict certain processing; opt out of specified advertising-related processing where required; request information about relevant processing and disclosures; lodge a complaint with a relevant privacy authority; and exercise other rights available under applicable law.

These rights are subject to legal conditions, exemptions and retention obligations. To submit a request, email [email protected] and describe the request with sufficient information to help us identify the relevant records. We may request reasonable identity verification before disclosing or changing personal information and will respond within the time required by applicable law.

Where a request concerns patient information held by a clinic through Divuzl Care, you may need to contact the relevant clinic first. Divuzl will assist as required by the applicable agreement and law.

18. Children and Minors

Our general business website and professional services are not directed towards children. Where a product or programme involves children, Divuzl will implement the notices, consent requirements, restrictions and safeguards required by applicable law. If you believe a child has provided personal information to us in circumstances that are not appropriate, contact [email protected].

19. Third-Party Websites and Services

Our website may contain links to external websites, social networks, payment providers, scheduling tools and other services. Divuzl does not control the independent privacy practices of those providers. Their processing is governed by their own terms and privacy policies. We encourage users to review the relevant privacy documentation before submitting personal information to third-party services.

20. Automation and Artificial Intelligence

Divuzl may use automation, analytics and artificial intelligence tools for appropriate business activities, including workflow management, content development, reporting, software assistance and operational efficiency. Where these tools process personal information, processing will be subject to applicable contracts, configurations, permissions and legal requirements. We will not knowingly use these tools in a manner that violates applicable privacy law. Confidential client information, patient information and sensitive personal information should not be submitted to third-party AI tools unless the use is authorised and appropriate safeguards are in place.

21. Business Transfers

If Divuzl undergoes a merger, acquisition, restructuring, financing, sale of assets or similar transaction, relevant personal information may be disclosed or transferred where permitted by law and subject to applicable privacy obligations.

22. Region-Specific Privacy Information

India

Divuzl will comply with applicable Indian data-protection laws, including the DPDP Act and the Digital Personal Data Protection Rules, 2025, to the extent their provisions are in force and apply to the relevant processing. Other applicable Indian laws may also govern particular activities.

United Kingdom

Where UK GDPR and related legislation apply, individuals may have additional rights concerning access, rectification, erasure, restriction, portability, objection and consent withdrawal. International transfers must meet applicable requirements.

United States

Where applicable US state privacy laws apply, eligible residents may have rights concerning access, correction, deletion, portability and specified advertising or data-sharing practices. Additional disclosures and opt-out mechanisms will be provided where required.

Other jurisdictions

Where Divuzl's activities are subject to other national or regional privacy laws, we will apply the requirements relevant to the processing activity and affected individuals.

23. Complaints and Grievances

If you have a privacy concern or complaint, contact [email protected]. Please describe the concern and provide sufficient details for us to investigate. We will review and respond in accordance with applicable law and our internal procedures. Where applicable, you may also contact the relevant data-protection authority or exercise other statutory remedies.

Grievance Officer: Devang Vikram Singh, Director
Email: [email protected]

24. Changes to This Policy

We may update this Policy to reflect changes in our business, services, technologies, security practices or legal obligations. The updated version will be published on https://divuzl.com with a revised “Last Updated” date. Where required by law, we will provide additional notice or obtain renewed consent before implementing changes that require it.

25. Contact Us

For privacy requests, questions, complaints or consent withdrawal, contact:

DIVUZL DIGITAL SOLUTIONS PRIVATE LIMITED
Website: https://divuzl.com
Privacy and contact email: [email protected]
Address recorded in the Certificate of Incorporation: C/O Amit Kumar Singh, Behta Madho, Dataganj, Dataganj, Budaun – 243635, Uttar Pradesh, India.
Grievance Officer: Devang Vikram Singh, Director — [email protected]

Where applicable law requires a designated Data Protection Officer, grievance officer or other privacy representative, the relevant details will be provided here.

26. Related Policies and Agreements

This Policy should be read alongside the following documents, where applicable:

• Terms and Conditions.
• Cookie Policy.
• Client Service Agreement.
• Data Processing Agreement.
• Divuzl Care Privacy Notice.
• Information Security and Confidentiality Terms.
• Recruitment and Event Privacy Notices.

Where a separate notice or agreement provides more specific terms for a particular processing activity, it should be read together with this Policy, subject to applicable law.

End of Privacy Policy