Privacy Policy

Privacy Policy

Effective Date: 7 April, 2026

TheAfterEve, Inc., a Delaware corporation, including its successors and assigns, doing business as Divisly (“Divisly,” “we,” “us,” or “our”), is committed to protecting the privacy and security of Personal Information.

This Privacy Policy (“Privacy Policy”) describes and governs the manner in which Divisly collects, uses, maintains, discloses, and otherwise processes information about you when you visit or use our website, mobile application, and any pages, features, content, purchases, accounts, communications, exports, reports, AI-enabled functionality, and other online services that link to this Privacy Policy (collectively, the “Services”).

Divisly is a property and asset inventory documentation platform used by individuals in connection with divorce, separation, and related legal matters, and by attorneys and other professionals or individuals who are granted access by those individuals. This Privacy Policy applies to all users of the Services, including individuals who create accounts directly and professionals who access the Services through an invitation or access grant from an individual user.

Please read this Privacy Policy carefully before you start to use the Services. By downloading, installing, accessing, or using the Services, or by clicking to accept these terms, you acknowledge that you have read and understood this Privacy Policy and agree to be bound by it, as well as by our Terms of Use available at divisly.com/terms (the “Terms of Use”), which are incorporated herein by reference.

If you do not agree to this Privacy Policy or the Terms of Use, you must not access or use the Services.

I. CATEGORIES OF PERSONAL INFORMATION WE COLLECT.

We may collect information that identifies, relates to, describes, or could reasonably be linked to an identifiable individual (“Personal Information”) in a variety of ways, including the following key categories:

• General Personal Information: Name, username and password used as login credentials, address, email address and phone number, date of birth, and any other Personal Information requested by our team for account creation, identity verification, and to comply with applicable laws.
• Information you upload: Any content you provide, submit, generate, or upload using the Services (“Content” which may include Personal Information), including but not limited to:
  • Property and real estate information (e.g., addresses, purchase details, mortgage information);
  • Item-level inventory data (descriptions, categories, ownership preferences, tags/flags);
  • Free-form notes or written descriptions;
  • Photos or images of homes, rooms, or personal property; and
  • Documents or reports generated through the Service.

Because Divisly includes free-form text and image uploads, Content may contain sensitive information depending on what you choose to include. You are responsible for the content you upload.

• Payment information: We may collect information related to the fees we charge for use of our Services. For purchases made through a third-party app store platform (such as Apple App Store or Google Play), payment is processed entirely by the applicable app store, and Divisly does not directly collect or store your payment card information for such transactions. For purchases made directly through our website, payment card information is processed by third-party payment processors and is not stored directly by Divisly, except as provided to us by such processors. We may retain transaction records associated with your account.
• Device and Usage Information: Information about how you access and use the Services, including:
  • IP address;
  • Device type, operating system, and app version;
  • Browser type (if accessing via web);
  • Login and authentication events;
  • Feature usage events (e.g., creation of inventory entries, uploads, exports, AI feature interactions);
  • Crash logs, error reports, and performance metrics; and
  • Timestamps associated with activity.

We collect this information to maintain security, ensure system reliability, prevent fraud or misuse, and improve the functionality and performance of the Services.

• Geolocation data: The general region or area from which you access the Services, typically derived from your IP address. We do not collect precise GPS location unless clearly disclosed for a specific feature you enable.
• Inferences: We may make inferences based on the information we collect. We may also collect diagnostic data (e.g., error logs, performance metrics) and session-level events (e.g., scrolls, cursor movements) configured to avoid capturing sensitive fields.
• Information from public or third-party sources: We may receive limited information from service providers or publicly available sources as necessary for fraud prevention, security, or compliance purposes. We do not purchase consumer marketing data.
• Sensitive personal information: We do not seek to collect sensitive Personal Information (e.g., government identifiers, health information) through the Services. Please do not submit sensitive Personal Information unless requested or required for a specific purpose. If you choose to upload documents or other content that includes Protected Health Information (“PHI”), we will process such content only as described in this Privacy Policy and only as necessary to provide the Services.
• II.‍  ‍HOW WE COLLECT PERSONAL INFORMATION.

We collect Personal Information from the following sources:

• Directly. We collect Personal Information directly from you. When you register for the Services, submit information in an online form, request information from us, upload content to our website or mobile application, or otherwise communicate with us or our support personnel, you may provide us with information, for example, your name, email address, and various other Personal Information. By providing us with this information, you consent to your information being collected, used, disclosed, processed, and stored by us in accordance with this Privacy Policy.
• Passively. We and our service providers collect Personal Information from you passively from the internet and other automatic data collection tools, such as cookies and web beacons, which are summarized below:
  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or stored on your device. Cookies and similar technologies help enable core functionality of the Services, maintain session integrity, authenticate users, and support security, analytics, and performance monitoring. You may refuse to accept browser cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain parts or features of the Services. Unless you have adjusted your browser or device settings so that cookies will be refused, our systems may issue cookies or similar technologies when you direct your browser or device to access the Services.
  • Web Beacons. Pages of our website, communications, or certain areas of the Services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, or single-pixel gifs) that permit Divisly, for example, to count users who have visited those pages, measure engagement, record the popularity of certain content, and verify system and server integrity.
  • Tracking Tools. We use the following tracking tools:
    • Session-replay/experience tools: We use session tools to help us diagnose issues and understand how users interact with our interfaces. We configure such tools not to record sensitive input fields and to mask on-screen text where feasible.
    • Monitoring/observability tools: These tools collect logs and performance metrics (such as request metadata, IP address, device and browser information, and error traces) to maintain the security, availability, and reliability of the Services.
    • Other tracking tools: We may deploy other automatic tracking tools in the future. Similar to the tools we currently use, such future tracking tools will track data about our visitors only in the aggregate and on an anonymized basis and will not reveal Personal Information about you.
    • Cookie and tracking choices: You may manage cookies and similar technologies through your browser or device settings. If we provide a cookie banner or preference center, you may use it to manage non-essential cookies. Disabling certain technologies may affect the availability or functionality of some features of the Services.
    • Mobile Application Permissions: If you access the Services through our mobile application, we may request permission to access certain device features, such as your camera or photo library, solely to enable functionality such as uploading images to document property or inventory items. We access such features only with your permission and only for the purposes described at the time of the request. You may revoke these permissions through your device settings.
  III. WHERE YOUR INFORMATION IS STORED AND PROCESSED.

We store and process Personal Information in the following ways:

• Cloud infrastructure. Personal Information and Content are stored and processed using secure cloud infrastructure and vetted service providers located primarily in the United States.
• Service providers. Personal Information may be processed by third-party service providers that support the operation, hosting, security, analytics, monitoring, and AI functionality of the Services. These providers process information on our behalf pursuant to written confidentiality, data protection, and security obligations.
• International transfers. If you access the Services from outside the United States, your Personal Information may be transferred to and processed in the United States or other jurisdictions where our service providers operate. By using the Services, you acknowledge and understand that your Personal Information may be transferred to and processed in jurisdictions that may have data protection laws different from those in your country of residence.
• Cross-border safeguards. Where required by applicable law, we rely on recognized legal transfer mechanisms for cross-border transfers of Personal Information.
• V. USE OF PERSONAL INFORMATION.

Some of the ways in which we may use the Personal Information provided include:

• to enable you to create, manage, and share reports, exports, or access to your Content with attorneys or other professionals at your direction;
• to create, manage, secure, and authenticate your account credentials and access to the Services;
• to process one-time purchases and maintain transaction records;
• to provide customer support and respond to inquiries;
• to operate, maintain, secure, monitor, debug, and improve the Services;
• to maintain system integrity, prevent fraud, detect security incidents, and protect against misuse of the Services;
• to perform analytics and diagnostic activities to understand feature usage, performance, and reliability;
• to develop de-identified or aggregated insights that do not identify you;
• to operate AI-enabled features (including retrieval-augmented generation) using your inputs and Content solely to provide the outputs and functionality you request;
• to send service-related communications, administrative notices, and product updates; and
• to comply with legal obligations and enforce our agreements.

We process Content (including uploaded documents, photos, and property inventory materials) only as necessary to provide, maintain, secure, and support the Services in accordance with this Privacy Policy and our Terms of Use. We do not use Content or PHI to train foundation models or general-purpose artificial intelligence systems. We do not sell Personal Information, and we do not share Personal Information for cross-context behavioral advertising or targeted advertising.

V. HOW YOU CONTROL AND SHARE YOUR INFORMATION.

You control your account and determine who can access your Content. When you grant an attorney, mediator, special master, or other professional access to your Workspace through the Services, you are directing Divisly to make your Content available to that individual. In such cases:

• You determine which individuals are granted access to your Workspace and what they can see.
• Divisly facilitates that access at your direction and does not independently decide to share your Content with any professional.
• Professionals who access your Workspace do so only as permitted by you and subject to their own independent professional obligations.

Divisly does not control how professionals use, store, or act upon information they access through your Workspace, and is not responsible for their use of that information in their professional capacity.

If you have questions about how a professional is handling information they accessed through your Workspace, you should direct that inquiry to the applicable professional.

VI. MANAGEMENT OF PERSONAL INFORMATION.

Our goal is to keep Personal Information accurate and up-to-date.  If you find that your Personal Information is not accurate, please let us know.  We will use reasonable efforts to investigate your concerns after we receive your inquiry and make the necessary corrections, additions, and/or deletions.

VII. SHARING PERSONAL INFORMATION.

We may share your Personal Information with third parties under the following circumstances:

• At your direction. We may share your Personal Information or Content with attorneys, mediators, special masters, or other professionals you choose to grant access to through the Services. Such sharing occurs entirely at your direction and with your authorization.
• With service providers who take action on our behalf. For example, we may share Personal Information with vendors and contractors who assist us with hosting, infrastructure, analytics, monitoring, security, billing, payment processing, customer support, and related service operations. We require service providers to use Personal Information only as instructed by us and to implement appropriate security measures. We also require our service providers to be bound by written confidentiality, data-protection, and security obligations at least as protective as those described in this Privacy Policy. Such service providers may reside outside the United States and in countries that may not provide the same level of protections as the laws of the United States.
• To comply with applicable law. We may share your information with the appropriate authorities without your consent if we believe disclosure is in accordance with, or required by, any applicable law, including in response to lawful requests by public authorities to provide information to deter and combat fraud, money-laundering, securities violation, data and privacy breaches, or for other legal purposes. Where permitted by law, we will provide you with prompt notice of any such required disclosure so that you may seek a protective order or other appropriate remedy.
• To protect the rights and property of Divisly. We may also share your Personal Information with third parties to protect the property and rights belonging to us or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.
• In connection with sale of Divisly. In the event of a reorganization, merger, or sale we may transfer your Personal Information we collect to the relevant third party. We will continue to protect Personal Information as described in this Privacy Policy and will notify you of any material changes as required by law.

VIII.  RETENTION.

We will retain your Personal Information only for as long as is necessary to provide the Services and in accordance with our internal retention and deletion policies. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our products and services, or we are legally obligated to retain this data for longer time periods.

Upon account termination or expiration, we will delete or de-identify Content and Personal Information in accordance with our retention policies unless continued retention is required by law. You may request deletion of your account at any time by contacting us at the email address listed in Section XVI below, and Divisly will process such requests within thirty (30) days of receipt, subject to any legal or regulatory obligations requiring Divisly to retain certain information for a longer period.

IX. OUR SERVICES ARE NOT INTENDED FOR CHILDREN.

The Services are not intended for, and may not be used by, individuals under eighteen (18) years of age. We do not knowingly collect Personal Information from anyone under 18. In addition, we do not knowingly collect Personal Information, as defined under the Children’s Online Privacy Protection Act (“COPPA”), from children under 13 years of age. If we obtain actual knowledge that we have collected Personal Information from a child under 13, we will promptly delete such information in accordance with applicable law. If you believe that we may have collected Personal Information from a child under 13, please contact us at privacy@divisly.com. If you are a parent or legal guardian and believe your child has provided Personal Information to us, you may contact us to request deletion, and we will take appropriate steps to investigate and respond.

Divisly strictly prohibits the upload, submission, or storage of any content that sexually exploits or depicts minors, including any content that constitutes child sexual abuse material (“CSAM”). Divisly complies with all applicable federal reporting obligations, including the requirement under 18 U.S.C. § 2258A to report known or apparent CSAM to the National Center for Missing and Exploited Children (“NCMEC”). In connection with such reporting, Divisly may disclose account information, User Content, and related Personal Information to NCMEC and to law enforcement authorities as required by applicable law. Any account found to contain or transmit CSAM will be immediately and permanently terminated.

X. SECURITY OF YOUR PERSONAL INFORMATION.

The security of your Personal Information is important to us, but no method of transmission over the Internet, or method of electronic storage, is secure.  While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. We employ administrative, technical, and physical safeguards appropriate to the nature of the Personal Information, including encryption in transit and at rest (where applicable), access controls, and least-privilege practices across our infrastructure and with service providers.

XI. WE DO NOT SELL OR SHARE PERSONAL INFORMATION.

Divisly does not sell Personal Information for monetary consideration. Divisly does not share Personal Information for cross-context behavioral advertising or targeted advertising. We do not use Content for advertising purposes.

XII. U.S. STATE PRIVACY RIGHTS.

If you reside in a U.S. state that provides privacy rights under applicable data protection laws (including, without limitation, California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia), you may have certain rights with respect to your Personal Information, subject to applicable limitations and exceptions.

Depending on your state of residence, these rights may include:

• Right to Access. You may request confirmation of whether we process your Personal Information and request access to, or a copy of, the Personal Information we maintain about you.
• Right to Correction. You may request that we correct inaccuracies in Personal Information we maintain about you.
• Right to Deletion. You may request that we delete Personal Information we have collected from or about you, subject to certain exceptions permitted by applicable law.
• Right to Data Portability. You may request a copy of certain Personal Information in a portable and, to the extent technically feasible, readily usable format.
• Right to Opt Out of Sale or Sharing. You may have the right to opt out of the sale or sharing of Personal Information. As described in Section XI (We Do Not Sell or Share Personal Information), Divisly does not sell Personal Information for monetary consideration and does not share Personal Information for cross-context behavioral advertising or targeted advertising.
• Right to Appeal. If we deny your request, you may have the right to appeal our decision as permitted by applicable law.

You have the right to exercise these rights without being subject to unlawful discrimination.

XIII. EXERCISING YOUR PRIVACY RIGHTS.

To exercise any of the rights described above, please submit a request by contacting us at privacy@divisly.com.

To protect your privacy and security, we may take reasonable steps to verify your identity before responding to your request. If you submit a request through an authorized agent, we may require proof of the agent’s authority and may also require you to verify your identity directly with us.

We may decline or limit requests where permitted by applicable law, including where we are required to retain information to:

• Complete a transaction or provide the Services requested by you;
• Comply with legal obligations;
• Detect or prevent fraud, abuse, or security incidents;
• Enforce our agreements; or
• Protect our rights or the rights and safety of others.

Where permitted by applicable law, we may limit the number of requests we are required to fulfill within a twelve (12) month period.

XIV. ACCOUNT AND COMMUNICATION CHOICES.

You may choose whether to provide certain Personal Information to us; however, some features of the Services may not function properly without it.

If you receive service-related or administrative communications from us, you may not opt out of those communications. You may opt out of non-essential communications (such as newsletters or product updates, if offered) by following the unsubscribe instructions included in those communications or by contacting us at unsubscribe@divisly.com

XV. CHANGES TO THIS PRIVACY POLICY.

We reserve the right, at our sole discretion, to change, modify, add, or remove any portion of this Privacy Policy, in whole or in part, at any time. Notification of changes in this Privacy Policy will be posted on our website and may be communicated through the Services or by other means as required by applicable law. Amendments to this Privacy Policy will be effective when posted. Your continued use of the Services following the posting of any amendment shall constitute your acceptance thereof.

XVI. CONTACT INFORMATION.

If you would like to contact us with questions or comments concerning our Privacy Policy, please e-mail us at privacy@divisly.com.

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