Div9ne Ray is a trading name of Elevate Gateway Ltd, registered in England and Wales.

1. Introduction

Div9ne Ray is committed to protecting and respecting your privacy.

This Privacy Policy explains how Div9ne Ray, a trading name of Elevate Gateway Ltd (“we”, “our”, “us”), collects, uses, stores, and protects your personal information when you:

• • visit our website

• • contact us

• • book events, retreats, workshops, or sessions

• • subscribe to newsletters or mailing lists

• • purchase products or services

• • participate in wellbeing or spiritual offerings

• • interact with us online or in person

We are committed to handling personal information in accordance with:

• • UK GDPR

• • Data Protection Act 2018

• • Privacy and Electronic Communications Regulations (PECR) where applicable

2. Who We Are

Div9ne Ray is a spiritual wellbeing and educational platform operated by Elevate Gateway Ltd.

For the purposes of data protection law, Elevate Gateway Ltd acts as the data controller in relation to your personal information.

3. Information We May Collect

We may collect and process the following categories of personal information:

Identity & Contact Information

• • name

• • email address

• • telephone number

• • postal address

• • emergency contact information where relevant

Booking & Transaction Information

• • booking details

• • retreat or event participation information

• • payment confirmation details

• • communication history

• • purchase history

Please note that payment card details are processed securely through third-party payment providers and are not stored by us.

Wellness & Participation Information

Where voluntarily provided and necessary for participation, we may collect limited information relating to:

• • accessibility requirements

• • allergies

• • medical considerations relevant to participation

• • emergency contact information

We request only information reasonably necessary to support participant safety and event administration.

Technical Information

When you use our website, we may automatically collect:

• • IP address

• • browser type and version

• • device information

• • pages visited

• • referral sources

• • website usage analytics

• • cookie data

4. How We Use Your Information

We may use personal information for the following purposes:

• • processing bookings and payments

• • managing events, retreats, workshops, and services

• • communicating important event or booking information

• • responding to enquiries

• • sending newsletters or marketing communications where consent has been provided

• • improving our website, services, and user experience

• • maintaining health and safety procedures where relevant

• • complying with legal and regulatory obligations

• • protecting our business, website, and participants

5. Legal Bases for Processing

Under UK GDPR, we rely on one or more of the following lawful bases:

Contractual Necessity

Where processing is necessary to provide booked services, events, retreats, workshops, or products.

Legitimate Interests

Where processing is reasonably necessary for:

• • business administration

• • customer support

• • event management

• • improving services

• • fraud prevention

• • website security

provided such interests are not overridden by your rights and freedoms.

Consent

Where you voluntarily consent to receive newsletters, marketing communications, or provide optional information.

You may withdraw consent at any time.

Legal Obligations

Where processing is necessary to comply with applicable legal or regulatory obligations.

6. Marketing Communications

We may send newsletters, updates, event announcements, promotional materials, or wellbeing-related content where:

• • you have subscribed

• • requested information

• • purchased services where lawful marketing exemptions apply

You may unsubscribe or opt out of marketing communications at any time using the unsubscribe link or by contacting us directly.

7. Sharing Your Information

We do not sell personal information.

We may share personal data where reasonably necessary with:

• • payment providers

• • booking platforms

• • email marketing providers

• • website hosting providers

• • IT and technical support providers

• • retreat venues or facilitators where operationally necessary

• • professional advisers, insurers, or legal representatives

• • regulatory authorities where legally required

All third parties are expected to process personal data securely and lawfully.

8. International Data Transfers

Some third-party providers may process data outside the United Kingdom.

Where international transfers occur, we take reasonable steps to ensure appropriate safeguards are in place in accordance with UK data protection laws.

9. Data Retention

We retain personal information only for as long as reasonably necessary for:

• • the purposes outlined in this Privacy Policy

• • legal, accounting, insurance, or regulatory obligations

• • dispute resolution and record keeping

When information is no longer required, it will be securely deleted or anonymised where appropriate.

10. Data Security

We take reasonable technical and organisational measures to protect personal information against:

• • unauthorised access

• • misuse

• • loss

• • disclosure

• • alteration

• • destruction

However, no internet transmission or electronic storage system can be guaranteed completely secure.

11. Health & Sensitive Information

Where participants voluntarily provide health or wellbeing-related information relevant to participation in retreats, workshops, healing sessions, breathwork, movement, or wellbeing activities, such information will be treated with appropriate confidentiality and processed only where reasonably necessary.

We request that participants avoid sharing excessive or unnecessary sensitive personal information.

12. Cookies & Website Analytics

Our website may use cookies and similar technologies to:

• • improve website functionality

• • analyse traffic and website usage

• • remember user preferences

• • support security and performance

You may manage cookie preferences through your browser settings.

Where legally required, cookie consent tools or banners will be provided.

13. Your Rights

Under UK data protection laws, you may have rights including:

• • the right to access your personal information

• • the right to request correction of inaccurate information

• • the right to request deletion of personal information

• • the right to restrict or object to certain processing

• • the right to data portability where applicable

• • the right to withdraw consent

• • the right to lodge a complaint with the Information Commissioner’s Office (ICO)

Requests may be submitted using the contact details below.

14. Third-Party Websites

Our website may contain links to third-party websites, booking systems, social media platforms, facilitators, or external services.

We are not responsible for the privacy practices, content, or policies of third-party websites or providers.

Users are encouraged to review the privacy policies of external websites they visit.

15. Children’s Privacy

Our services are generally intended for individuals aged 18 years and over unless otherwise stated.

We do not knowingly collect personal information from children without appropriate consent where required.

16. Changes to This Privacy Policy

We reserve the right to amend or update this Privacy Policy at any time.

Updated versions will be published on the website and continued use of the website or services constitutes acknowledgement of any updates.

17. Contact Information

If you have any questions regarding this Privacy Policy or your personal information, please contact:

Div9ne Ray
A trading name of Elevate Gateway Ltd

Please use the contact form or official contact details provided on the website.

18. Complaints

If you are unhappy with how your personal information has been handled, you may contact the UK Information Commissioner’s Office (ICO).

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