1. About Sharedivi
Sharedivi is a global platform designed to connect people, businesses, and opportunities
through a unique
system of Shares
that can be transformed into real value worldwide. Whether you are a Sharer, a PowerSharer,
or an AdSharer,
our platform
gives you the tools to earn, grow, and expand your network.
By creating a community where every transaction generates Shares, we make earning accessible
to everyone —
from
individuals who simply want to share and earn, to businesses that seek to reach new
customers and reward
loyalty.
With Sharedivi, sharing truly means gaining — locally and globally.
Our platform includes three types of members:
- 1. Sharer
- 2. PowerSharer
- 3. AdSharer
All members receive access to a personal dashboard to track their activity in real time and
we provide
worldwide access.
2. Who We Are
Sharedivi F.Z.E is a company incorporated and registered in Ajman, United Arab Emirates.
Legal Entity Responsible for Your Data: Sharedivi F.Z.E. acts as the data controller for
your personal
information.
- Registered Address: Ajman Free Zone – B.C. 1307087
- Sharedivi F.Z.E.
- AJMAN, United Arab Emirates
Contact:
General privacy questions: [email protected]
Data protection matters / Data Protection Officer (DPO): [email protected]
If and when required under EU/EEA and UK data protection laws, we will appoint a
representative in the EU/EEA
and/or
the UK (Article 27 GDPR / UK GDPR). Once appointed, the contact details of this
representative will be
published
here and
in the “Contact Us” section.
3. Why You Should Read This Policy
This Privacy Policy explains
- What personal data we collect and why
- How we use and process your data
- Who we share your data with
- How long we keep your data
- The legal bases for processing
-
Your rights under applicable data protection laws (including GDPR and the UAE Federal
Personal Data
Protection Law (PDPL), where applicable)
- How we protect your information
- How you can exercise your rights
-
How data is visible within the Sharedivi platform (community and marketplace visibility)
4. What Personal Data We Collect
We collect personal data directly from you, from your use of our Services, and from third
parties. Personal data
means any
information that identifies you directly or indirectly.
4.1 Data You Provide to Us
We may collect the following information that you provide directly:
- Full name, date of birth, nationality.
- Username, password, and email address.
- Contact details: address, phone number, email.
-
Payment and billing details: bank account number, IBAN, credit/debit card details (card
number, expiry date,
CVC – not stored in full on our servers).
-
Tax identification number, VAT or business registration details (for AdSharers and
business accounts).
-
Identity documents (passport, ID card, driving license) and, where legally required or
where you consent,
biometric data (such as face scans) for verification and KYC (Know Your Customer)
checks.
-
Information provided in forms, surveys, support requests, or communications with us.
- Details about your business, products, or services (for AdSharers and merchants).
-
Content you upload or generate on the platform, such as reviews, ratings, comments,
profile photos, and
business listings.
4.2 Data We Collect Automatically
When you use our Services, we automatically collect certain information,
including:
-
Device information: device type, device IDs, operating system, unique
device identifiers, mobile network data,
browser type, system performance.
-
Log data: IP address, login times, pages visited, actions performed,
error logs, referral links used, and interaction
times.
-
Usage and interaction data (click and scroll behaviour):
-
Clickstream and interaction events (such as clicks, taps, scrolls, mouse
movements, page transitions)
- Time spent on pages, sections, or screens
- Page response times, download errors, and performance metrics
- Interaction with specific features, buttons, content, or adverts
- How often you open or use the App, and which functionalities you use most
-
Transaction data: payments, payouts, currency exchange, referral
bonuses, share purchases, redemptions, reward
allocations, and transaction timestamps.
-
Location data (if enabled): via GPS, Wi-Fi, or IP-based geolocation.
-
Cookie and tracking data: session identifiers, analytics identifiers,
advertising identifiers, and other online
identifiers associated with your device and browser.
4.3 Data From Third Parties
We may receive information about you from:
-
Social networks or identity providers (if you connect your account or sign in via e.g.,
Google, Apple.)
- Payment providers, banks, and financial institutions.
- Fraud-prevention and credit-checking agencies.
- Business partners involved in referrals, promotions, and reward programs.
-
Other users (for example, if someone refers you, invites you, or reports suspicious
activity).
5. How We Use Your Personal Data
We may use your data for the following purposes:
5.1 To Provide and Manage Sharedivi Services
We may receive information about you from:
- Creating, verifying, and managing your Sharedivi account
- Enabling and managing membership tiers (Sharer, PowerSharer, AdSharer)
- Processing payments, payouts, share exchanges, and rewards
- Providing access to and personalisation of your personal dashboard
- Facilitating referrals, invitations, and network growth
5.2 To Comply With Legal and Regulatory Obligations
- Performing identity verification (KYC) and anti-money laundering (AML) checks
- Performing identity verification (KYC) and anti-money laundering (AML) checks
-
Complying with laws and regulations in Dubai/UAE, the EU/EEA, the UK, and other
jurisdictions where our
users are located or where we operate.
5.3 For Security and Fraud Prevention
- Detecting, monitoring, and preventing fraudulent or suspicious activity
- Protecting accounts against unauthorized access.
-
Monitoring and mitigating financial crime risks, including AML, sanctions screening, and
risk scoring.
- Enforcing our User Agreement and other policies.
5.4 For Customer Support and Communication
- Responding to inquiries, support tickets, and complaints.
- Contacting you about account issues, security alerts, and service changes.
-
Recording and analysing certain communications (where legally permitted) for quality,
training, and
compliance
purposes.
5.5 For Marketing, Recommendations, and Community Engagement
We may use your data to:
-
Send you service-related messages (such as updates, technical notices, security alerts)
-
Send you marketing communications (such as offers, promotions, news, and events) where
allowed by law and
with your consent where required
-
Personalize marketing content, recommendations, and in-app suggestions based on your use
of the Services,
your interests, and behaviour
- Enable and manage referral and rewards programs
-
Allow AdSharers and merchants to promote their products and services through the
platform (e.g., sponsored
promotions, special offers)
You can control marketing communications at any time through your account settings or by
using the unsubscribe
link in
our emails. Service-related communications (e.g. security or account notifications) are
necessary for the proper
functioning
of your account and cannot usually be opted out of.
5.6 For Analytics, Research, and Product Improvement
-
Analysing user behaviour and feedback to improve our platform, user experience, and
features.
- Conducting statistical analysis, market research, and performance reports.
- Developing new functionalities, services, and monetisation models.
-
Creating anonymized or aggregated data sets (which no longer identify you) for business
analysis.
5.7 Automated Decision-Making and Profiling
We may use automated systems and profiling to:
-
Assess eligibility for certain features and membership tiers (such as PowerSharer or
AdSharer status).
- Detect and prevent fraud or abuse.
-
Tailor recommendations, promotions, rewards, or content to you based on your usage and
preferences.
Where required by law, we will ensure that significant decisions that produce legal or
similarly significant
effects about you
are not made solely by automated means, or we will provide you with information and an
opportunity to request
human
review.
6. Legal Basis for Processing
Depending on your location and applicable law (including the EU/EEA General Data Protection
Regulation (“GDPR”),
UK
GDPR, and the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data
(“PDPL”)), we process
your
personal data under the following legal grounds:
-
Contractual necessity – to provide the Services you request and fulfil our contract with
you (e.g., account
management, transactions, payouts, support).
-
Legal obligations – to comply with applicable laws and regulations (e.g., AML/KYC, tax,
accounting,
reporting,
sanctions screening).
-
Legitimate interests – to operate, protect, and improve our business and Services (e.g.,
fraud prevention,
analytics, security, product improvements, limited direct marketing to existing
customers), provided that
such
interests are not overridden by your rights.
-
Consent – where required by law for certain processing activities (e.g., some marketing
communications,
certain
cookies and similar technologies, biometric verification, or sharing data with specific
partners). You can
withdraw
your consent at any time, without affecting the lawfulness of processing based on
consent before withdrawal.
Where we combine different purposes or legal bases, we will clearly indicate this and
respect your rights under
applicable
law.
7. Sharing of Personal Data
We may share your personal data with the following categories of recipients:
-
Service providers and vendors: such as payment processors, IT and hosting providers,
cloud providers, analytics
tools, customer service providers, communication platforms, identity verification
services, and security providers.
These third parties only process personal data on our behalf and in accordance with our
instructions.
-
Business partners: where necessary for referral programs, reward distribution,
co-branded campaigns, or product
and service integrations connected to the platform.
-
Other members and users: when you make transactions, referrals, or purchases, limited
information may be
shared so that the other party can complete the transaction (for example, order details
or necessary contact
information, depending on the nature of the transaction).
-
Public authorities and regulators: law enforcement agencies, supervisory authorities,
tax authorities, and other
public bodies where required by law or to protect our rights or the rights of others.
-
Credit and risk assessment agencies: when conducting checks for financial transactions
or compliance purposes,
where permitted by law.
-
Advertising and analytics partners: as described below, and only in compliance with
applicable law.
Where we combine different purposes or legal bases, we will clearly indicate this and
respect your rights under
applicable
law.
7.1 Advertising and Analytics Partners
We may work with analytics and advertising partners to:
- measure the effectiveness of our campaigns;
- understand how users interact with our Services;
- show you more relevant Sharedivi content and offers.
When we share information with such partners:
- We do not sell your personal data.
-
We generally share pseudonymized or aggregated data, such as hashed identifiers (for
example, a hashed email
address), device identifiers, or cookie identifiers.
-
We do not share sensitive information such as full payment card numbers or identity
documents with advertising
networks.
You can control many analytics and advertising cookies and identifiers via your browser or
device settings and, where
legally required (e.g., in the EU/EEA), via our cookie consent tools.
7.2 Business Transfers
If we are involved in a merger, acquisition, restructuring, financing, sale of assets, or
similar corporate transaction, your
personal data may be transferred as part of that transaction. In such cases:
-
we will continue to protect your personal data in line with this Privacy Policy; and
-
we will inform you of any material changes or new controller, where required by law.
We do not sell your personal data to third parties.
8. International Data Transfers
Since Sharedivi operates globally, your personal data may be transferred to and stored in
countries other than your country
of residence — including the United Arab Emirates (UAE), countries in the European Economic
Area (EEA), the United
Kingdom, and other jurisdictions where our service providers or partners are located.
When transferring personal data internationally, we take steps to ensure an adequate
level of protection, for example by:
-
relying on an adequacy decision (where the receiving country is recognised as providing
an adequate level of data
protection);
- Enabling and managing membership tiers (Sharer, PowerSharer, AdSharer)
-
using Standard Contractual Clauses or similar contractual safeguards approved by
relevant authorities;
-
implementing additional technical and organisational safeguards (such as encryption and
access controls).
The UAE is currently not generally recognised by the EU as an “adequate” country for
unrestricted data transfers.
Therefore, where EU/EEA or UK data protection laws apply, we rely on appropriate safeguards
(such as Standard
Contractual Clauses) and only transfer personal data where this is lawful and protected by
enforceable rights and effective
remedies.
9. Cookies and Tracking Technologies
We use cookies and similar technologies (such as pixels, SDKs, and local storage) to support
and improve our
Services.
These technologies help us to:
- authenticate you and keep you logged in;
- remember your preferences and settings;
- understand how you use our Website and App;
- understand how you use our Website and App;
- prevent fraud and maintain security;
- measure and improve our marketing and campaigns.
We typically use the following categories of cookies:
-
Strictly necessary cookies – required for the functioning of the Services (e.g., login,
security,
transactions)
-
Performance and analytics cookies – help us understand how users use the Services, so we
can improve them
- Functional cookies – remember your preferences (such as language and region)
-
Advertising and marketing cookies – used to deliver more relevant Sharedivi content and
offers, and to
measure campaign effectiveness
Where required by law (for example, in the EU/EEA and UK), we will ask for your
consent before placing
non-essential
cookies or similar technologies. You can:
- manage or disable cookies in your browser or device settings; and
-
manage your preferences through any cookie banner or consent management tool we provide.
- Disabling certain cookies may affect the functionality of the Services.
10. Data Retention
We keep your personal data only for as long as necessary for the purposes for which
it was collected, including:
- providing and improving our Services;
- maintaining business records;
-
complying with legal and regulatory obligations (such as AML, tax, and accounting laws);
- resolving disputes and enforcing agreements.
In particular:
-
Data related to identity verification (KYC) and financial transactions may need to be
retained for a legally
required minimum period (for example, several years after the end of your relationship
with us), depending on
the applicable AML and financial regulations.
-
Where data is no longer required for any legitimate purpose, we will securely delete,
anonymize, or archive it in
accordance with legal requirements and our internal policies.
11. Age Restrictions and Children
Our Services are intended only for persons who are 18 years of age or older.
- We do not knowingly collect personal data from children or minors under 18.
-
If we discover that we have collected personal data from a person under 18 without valid
parental or guardian
consent where required, we will take steps to delete such data as soon as reasonably
practicable.
-
If you believe that a minor has provided personal data to us, please contact us using
the details in the “Contact
Us” section.
12. Your Rights
Depending on your location and the applicable data protection laws (including GDPR,
UK GDPR, and the UAE PDPL), you
may have some or all of the following rights:
-
Right of access: to obtain confirmation as to whether we process your personal data and
to request a copy of that data
- Right to rectification: to correct inaccurate or incomplete personal data
-
Right to erasure: to request deletion of your personal data, subject to legal or
legitimate retention obligations (for example, where we must keep data under AML or tax
laws)
-
Right to restriction of processing: to request that we limit the processing of your data
in certain circumstances (e.g., when you contest its accuracy)
-
Right to object: to object to certain processing, including direct marketing and
processing based on our legitimate interests, on grounds relating to your particular
situation
-
Right to data portability: to receive your personal data in a structured, commonly used,
and machine-readable format and to request that we transmit that data to another
controller, where technically feasible and where processing is based on consent or
contract and carried out by automated means
-
Right to withdraw consent: where processing is based on your consent, you can withdraw
this consent at any time. This will not affect the lawfulness of processing prior to
withdrawal
-
Right to lodge a complaint:
-
with a supervisory authority in the EU/EEA or UK if GDPR/UK GDPR applies to you
-
with the competent authority under the UAE PDPL (e.g., the UAE Data Office) or
any other applicable authority in your jurisdiction
We may need to request additional information from you to verify your identity before
responding to a rights request,
especially where we process sensitive information or where we need to protect other users.
You can exercise your rights by contacting us at [email protected] or as otherwise
indicated in your account or the
Services.
13. Information You Can Access in Your Dashboard
Through your Sharedivi account and dashboard, you may be able to view, update, or
manage certain personal data and
settings. For example, you may access and/or manage:
- Overview of your account details
- Contact information and profile settings
- Your membership tier (Sharer, PowerSharer, AdSharer)
- Transaction history and payouts
- Shares, rewards, and referral statistics
- Communication and marketing preferences
- Security and login settings (e.g., 2FA)
- Business profile information (for AdSharers/merchants)
14. Public Content, Reviews, and Visibility Within the Platform
We design our platform to give you control over what information is publicly
visible:
-
No public disclosure by default: We do not publicly display your personal data (such as
your full name,
address,
email, or phone number) unless you actively choose to make such information public (for
example, by
publishing
a review, setting up a public business profile, or posting content that includes such
details).
-
Reviews and community content: If you leave reviews, comments, or other public feedback,
the information you
include in that content (and any display name or avatar you choose to use) may be
visible to other users
and, in
some cases, to the public. Please do not share sensitive personal data in such public
areas.
-
Visibility to other members:
-
When you engage in a transaction (e.g., purchasing from an AdSharer or
merchant), certain necessary
information may be shared with the other party (such as order details and, where
necessary, contact
channels to complete fulfilment).
-
We aim to minimise the direct sharing of personal contact data between private
individuals wherever
possible and to facilitate communication through platform tools or anonymized
details where
feasible.
If you are an AdSharer or merchant, see also the section “Business and Merchant Data &
Visibility” below.
15. Business and Merchant Data & Visibility
If you use Sharedivi as a business, AdSharer, merchant, or other professional user,
we process additional
information about
your business (“Business Data”), which may include:
- Business name and trading name
- Business registration details (e.g., trade license number, VAT number)
- Business address and country of operation
-
Business contact channels (such as business email, website, business phone, or social
media profiles)
- Business logos, images, descriptions, and marketing materials
- Product and service information, pricing, and availability
-
Performance indicators (such as rating scores, review summaries, and other reputational
metrics)
15.1 Visibility for buyers and users:
-
We may display certain Business Data publicly or to potential buyers, including business
name, logo, general
location (e.g., city and country), business category, and description, as well as
reviews and ratings
-
We generally do not publish the personal home address or private contact details of
natural-person sellers
unless they choose to provide a business address and contact details for public display
-
Transaction-related information (such as order details and delivery information) is
shared only as needed to
complete the transaction and comply with legal requirements
Where Business Data relates to an identifiable natural person (for example, a sole trader),
we will treat it as
personal data
and protect it in accordance with this Privacy Policy and applicable laws.
16. Security
We apply strict technical, organisational, and administrative measures to protect
your personal data,
including:
- Encryption (e.g., TLS/SSL) for data in transit
- Secure storage of sensitive data
- Access controls and multi-factor authentication where appropriate
- Regular security monitoring, audits, and testing
- Segregation of duties and least-privilege access for staff
- Employee training in data protection and security
Where we handle payment card data, we follow industry standards such as the Payment Card
Industry Data Security
Standard (PCI DSS) and we require our payment providers to maintain robust security and
compliance in line with
these
standards.
Because no system can be completely secure, we cannot guarantee absolute security of your
data. If we become
aware of a
data breach that affects your personal data, we will notify you and the relevant authorities
where required by
law.
When you contact us to exercise your rights or request access to your data, we may ask you
to provide additional
information to verify your identity before we disclose personal data.
17. Jurisdiction-Specific Information
17.1 European Union (EU), European Economic Area (EEA), and UK
If GDPR/UK GDPR applies to you:
-
Sharedivi FZ-LLC is the data controller for your personal data in relation to the
Services
-
Where required, we will appoint an EU/EEA representative and/or UK representative, whose
contact details will be made available in this policy and on our Website
-
You have the rights described in the section “Your Rights” above, including the right to
lodge a complaint with your local supervisory authority
17.2 United Arab Emirates (UAE)
For users in the UAE, we process your personal data in accordance with the UAE Federal
Decree-Law No. 45 of 2021 on the
Protection of Personal Data (PDPL), as applicable, and any other relevant implementing
regulations.
If we operate or engage entities within UAE free zones that have their own data protection
regimes (such as the Dubai
International Financial Centre (DIFC) or Abu Dhabi Global Market (ADGM)), we will also
comply with the relevant local
data protection laws and regulations for processing activities carried out there.
You may have additional rights under these laws, and you may be able to lodge a complaint
with the competent authority
(for example, the UAE Data Office or a free-zone Commissioner of Data Protection, where
applicable).
18. Changes to This Privacy Policy
17.1 European Union (EU), European Economic Area (EEA), and UK
We may update this Privacy Policy from time to time. When changes are significant, we will
notify you via email, in-app
messages, or other appropriate means. The latest version will always be available at
www.sharedivi.com/privacy.
Where required by law, we will obtain your consent to material changes that affect how we
process your personal data.
19. Contact Us
If you have questions, concerns, or would like to exercise your data protection rights,
please contact us:
We may update this Privacy Policy from time to time. When changes are significant, we will
notify you via email, in-app
messages, or other appropriate means. The latest version will always be available at
www.sharedivi.com/privacy.
Where required by law, we will obtain your consent to material changes that affect how we
process your personal data.
Contact Us
Data Protection Officer (DPO)
Email: [email protected]
Registered Address: Ajman Free Zone – B.C. 1307087
Sharedivi F.Z.E.
AJMAN, United Arab Emirates
For general questions, contact: [email protected]