Privacy Policy
Divergente SRL Società Benefit
Last updated: May 2026
This Privacy Policy explains how Divergente SRL Società Benefit collects, uses, and protects the personal data of users who visit this site and enroll in our online courses.
This policy is provided in accordance with Article 13 of EU Regulation 2016/679 (GDPR) and the Italian Privacy Code (Legislative Decree 196/2003 as amended by Legislative Decree 101/2018).
1. Data Controller
The Data Controller, as defined by Article 4(7) GDPR, is:
Divergente SRL Società Benefit
Registered in Italy
Email: [email protected]
For any privacy-related request, please write to: [email protected]
2. Categories of Personal Data Collected
We collect the following categories of personal data:
2.1 Data provided directly by the user
- Full name
- Email address
- Billing information (name, address, and payment data processed by Stripe)
2.2 Data collected automatically
- Technical navigation data (browser type, device, session data collected by Thinkific)
- Behavioural analytics data (pages visited, time on site, aggregated usage patterns collected by Google Analytics 4)
ℹ️ A note on sensitive data
We do not ask users for any information about their health, diagnoses, or neurodivergent conditions. The subject matter of our courses does not constitute the collection of special categories of data under Article 9 GDPR. No health-related data is collected, stored, or processed.
3. Purposes and Legal Basis for Processing
The table below summarises each processing activity, the data involved, and the applicable legal basis under Article 6 GDPR.
| Purpose | Legal Basis |
|---|---|
| Enrollment and course delivery (creating your account, providing access to course content) | Contract – Art. 6(1)(b) GDPR |
| Payment processing (handling your purchase via Stripe) | Contract – Art. 6(1)(b) GDPR |
| Issuing invoices and fulfilling Italian fiscal obligations (10-year retention) | Legal obligation – Art. 6(1)(c) GDPR |
| Site analytics (understanding aggregate traffic patterns via Google Analytics 4) | Legitimate interest – Art. 6(1)(f) GDPR, subject to GA4 privacy settings described in Section 6 |
| Responding to support and privacy requests sent by email | Legitimate interest – Art. 6(1)(f) GDPR |
4. Data Retention
Personal data is retained only for as long as necessary for the purposes for which it was collected, and in compliance with applicable law.
| Data Type | Retention Period |
|---|---|
| Account and enrollment data | Duration of account + reasonable post-closure period |
| Billing and invoice data | 10 years (Italian fiscal law obligation) |
| Google Analytics 4 data | 2 months (minimum setting, configured in GA4 property) |
| Support correspondence | Duration of the request + 12 months |
5. Data Recipients and Third-Party Processors
Your personal data may be shared with the following categories of recipients, each acting as Data Processor under a written agreement with Divergente SRL Società Benefit:
5.1 Thinkific Labs Inc. (Canada)
Thinkific is our course platform provider and hosts all course content and student account data. Data transfers outside the EEA are conducted in compliance with GDPR, including through Standard Contractual Clauses (SCCs). Thinkific's legal documents, including its Data Processing Addendum, are available at: thinkific.com/legal
5.2 Stripe Inc. (USA)
Stripe processes payment transactions. Stripe does not share payment data with us beyond what is necessary for order confirmation. Data transfers to the USA are governed by Standard Contractual Clauses. Stripe's privacy policy is available at: stripe.com/privacy
5.3 Google LLC — Google Analytics 4 (USA)
We use Google Analytics 4 (GA4) to understand aggregate site usage. GA4 is integrated natively via the Thinkific platform. As described in Section 6, our GA4 configuration is set to minimise data collection. Data transfers to the USA take place under the EU–US Data Privacy Framework and Standard Contractual Clauses. Google's privacy policy is available at: policies.google.com/privacy
We do not sell personal data to third parties. We do not use personal data for advertising or retargeting purposes. No data is shared with Google Ads, Google Signals, or any ad platform.
6. Google Analytics 4 — Privacy Configuration
We have configured Google Analytics 4 to minimise data collection and personal data exposure:
- IP anonymisation is enabled by default in GA4 and cannot be modified. IP addresses are never stored.
- Data retention is set to the minimum: 2 months.
- Google Signals is disabled. We do not cross-reference analytics data with Google account profiles.
- Data sharing with Google advertising products (Google Ads, Display & Video 360, etc.) is disabled.
In this configuration, GA4 collects aggregated, anonymised traffic statistics and does not collect data that directly identifies individual users.
7. Cookies
This site uses the following types of cookies:
| Cookie Type | Description |
|---|---|
| Strictly necessary | Session and authentication cookies set by Thinkific to allow you to log in and navigate the course platform. These are essential and cannot be disabled. |
| Analytics | Anonymised, aggregated cookies set by Google Analytics 4 to measure site traffic. No personal data is stored in these cookies in our current configuration. |
For detailed information on the cookies used by Thinkific, please consult the Thinkific Cookie Policy at: thinkific.com/cookies-policy
8. Your Rights Under the GDPR
As a data subject, you have the following rights under Articles 15–22 GDPR:
- Right of access (Art. 15): You may request confirmation of whether we process your personal data and obtain a copy.
- Right to rectification (Art. 16): You may request correction of inaccurate or incomplete data.
- Right to erasure (Art. 17): You may request deletion of your personal data, subject to legal retention obligations.
- Right to restriction (Art. 18): You may request that we limit processing in certain circumstances.
- Right to data portability (Art. 20): You may request your data in a structured, machine-readable format.
- Right to object (Art. 21): You may object to processing based on legitimate interest at any time.
How to exercise your rights
To exercise any of the above rights, please contact us at: [email protected]
We will respond within 30 days of receiving your request, in accordance with Article 12 GDPR.
If you believe your rights have not been upheld, you have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali): www.garanteprivacy.it
9. Data Protection Officer (DPO)
Divergente SRL Società Benefit is not required to appoint a Data Protection Officer under Article 37 GDPR. Our core business activity does not involve large-scale, systematic monitoring of individuals, nor large-scale processing of special categories of data.
For any data protection queries, please contact us directly at [email protected].
10. International Data Transfers
Some of our data processors are based outside the European Economic Area (EEA), specifically in Canada (Thinkific) and the United States (Stripe, Google). All transfers are conducted in accordance with Chapter V GDPR through one or more of the following mechanisms:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- EU–US Data Privacy Framework, where applicable
Links to each processor's data transfer documentation are provided in Section 5.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The date of the latest revision is indicated at the top of this document. We encourage you to review this policy periodically.
Continued use of our services after any changes constitutes acceptance of the updated policy.
Divergente SRL Società Benefit · [email protected] · Privacy Policy – May 2026