Divine Capital Collective
Privacy Policy

Privacy Policy

Your privacy matters. Learn how we protect your information.

Last Updated: January 2025

Overview

Divine Capital Collective (operating as Julia Anatolvina Consulting LLC, a Wyoming LLC) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our services.

We operate as a commercial mortgage broker serving real estate investors only (not consumers) in Texas and Florida. Our services include arranging financing for bridge loans, DSCR loans, hard money loans, conventional CRE investor loans, and ground-up construction financing.

Important: By using our website or services, you consent to the data practices described in this policy. If you do not agree, please do not use our services.

Information We Collect

Personal Information You Provide

  • Contact Information: Name, email address, phone number, mailing address
  • Financial Information: Credit score, income, assets, liabilities, property details, loan amount requested
  • Business Information: Business name, EIN, business structure, years in business
  • Property Information: Property address, purchase price, estimated value, property type, intended use
  • Communication Records: Emails, phone calls, text messages, meeting notes, Calendly booking details

Automatically Collected Information

  • Device & Browser Data: IP address, browser type, operating system, device identifiers
  • Usage Data: Pages visited, time spent on pages, click patterns, referral sources
  • Cookies & Tracking: Session cookies, analytics cookies, preference cookies (see Section 7)

How We Use Your Information

We use your information for the following purposes:

  • Loan Processing: Evaluate financing requests, match you with lenders, prepare loan applications
  • Communication: Respond to inquiries, provide updates, send marketing materials (with consent)
  • Service Improvement: Analyze website usage, improve user experience, develop new features
  • Compliance: Meet legal obligations under GLBA, anti-money laundering laws, and other regulations
  • Security: Detect fraud, prevent unauthorized access, protect our systems
  • Business Operations: Maintain records, process payments, manage customer relationships

Information Sharing & Disclosure

We do NOT sell your personal information.

We may share your information with:

Lenders & Financial Institutions

We share your loan application details with lenders to obtain financing quotes and process your loan request.

Service Providers

  • Calendly: Appointment scheduling
  • Google Workspace: Email and document management
  • Hosting & CDN: Website hosting and content delivery
  • Analytics Tools: Website analytics and performance monitoring

Legal Requirements

We may disclose information when required by law, court order, subpoena, or to protect our rights and safety.

Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

Data Retention

We retain your personal information for as long as necessary to:

  • Provide our services and maintain your account
  • Comply with legal obligations (e.g., GLBA requires 5+ years for financial records)
  • Resolve disputes and enforce agreements
  • Maintain business records for tax and accounting purposes

Typical Retention Periods:

  • Loan applications: 7 years after closing or denial
  • Communication records: 5 years
  • Website analytics: 26 months
  • Marketing consent records: Until consent is withdrawn + 3 years

Data Security

We implement industry-standard security measures to protect your information:

  • Encryption: SSL/TLS encryption for data in transit, AES-256 encryption for sensitive data at rest
  • Access Controls: Role-based access, multi-factor authentication, regular access reviews
  • Secure Infrastructure: Firewalls, intrusion detection, regular security audits
  • Employee Training: Regular privacy and security training for all staff
  • Vendor Management: Due diligence and contractual safeguards for third-party processors

Disclaimer: While we use reasonable security measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security.

Cookies & Tracking Technologies

We use cookies and similar technologies to enhance your experience and analyze website usage.

Types of Cookies We Use

  • Essential Cookies: Required for website functionality (e.g., session management, security)
  • Analytics Cookies: Track website usage and performance (e.g., Google Analytics)
  • Preference Cookies: Remember your settings and preferences
  • Marketing Cookies: Track conversions and ad performance (with consent)

Managing Cookies

You can control cookies through your browser settings. Note that disabling cookies may affect website functionality.

  • Chrome: Settings → Privacy and security → Cookies
  • Firefox: Settings → Privacy & Security → Cookies
  • Safari: Preferences → Privacy → Cookies

SMS & Text Messaging

This section applies if you opt in to receive text messages from Divine Capital Collective.

Consent & Opt-In

By providing your mobile phone number and opting in (via checkbox, keyword, or verbal consent), you consent to receive text messages from us, including:

  • Loan application updates and status notifications
  • Appointment reminders and confirmations
  • Marketing messages about our services (if you opt in)
  • Account alerts and important notices

Message Frequency & Charges

  • Frequency: Message frequency varies. You may receive up to 10 messages per month for transactional updates, and up to 4 messages per month for marketing (if opted in).
  • Charges: Message and data rates may apply. Check with your mobile carrier for details.
  • Carriers: We support all major U.S. carriers. Carrier charges may vary.

Opt-Out & Help

Platform & Compliance

We use GoHighLevel (or similar platforms) to send text messages. We comply with TCPA (Telephone Consumer Protection Act) and CTIA guidelines. Consent is not a condition of purchase.

Important A2P Compliance Notice:

This SMS program is registered for Application-to-Person (A2P) messaging. By opting in, you acknowledge that you are a real estate investor (not a consumer) and consent to receive business-related text messages. We do not send unsolicited marketing messages without explicit consent.

California Privacy Rights (CPRA)

If you are a California resident, you have specific rights under the California Privacy Rights Act (CPRA):

Your CPRA Rights

  • Right to Know: Request disclosure of personal information we collect, use, and share
  • Right to Delete: Request deletion of your personal information (subject to exceptions)
  • Right to Correct: Request correction of inaccurate personal information
  • Right to Opt-Out: Opt out of the sale or sharing of personal information (we do not sell data)
  • Right to Limit: Limit use of sensitive personal information
  • Right to Non-Discrimination: We will not discriminate against you for exercising your rights

How to Exercise Your Rights

To submit a CPRA request, email us at privacy@divinecapitalcollective.com or use the Privacy Request Form below. We will respond within 45 days.

Categories of Personal Information Collected

  • Identifiers (name, email, phone, address)
  • Financial information (credit score, income, assets)
  • Commercial information (loan applications, property details)
  • Internet activity (website usage, IP address)
  • Professional information (business name, EIN)

GDPR Rights (EU/UK Residents)

If you are located in the European Union or United Kingdom, you have rights under the General Data Protection Regulation (GDPR):

Your GDPR Rights

  • Right of Access: Request a copy of your personal data
  • Right to Rectification: Correct inaccurate or incomplete data
  • Right to Erasure: Request deletion of your data ("right to be forgotten")
  • Right to Restrict Processing: Limit how we use your data
  • Right to Data Portability: Receive your data in a structured, machine-readable format
  • Right to Object: Object to processing based on legitimate interests or direct marketing
  • Right to Withdraw Consent: Withdraw consent at any time (where processing is based on consent)

Legal Basis for Processing

We process your data based on:

  • Consent: You have given explicit consent (e.g., marketing emails)
  • Contract: Processing is necessary to perform our services
  • Legal Obligation: We must comply with laws (e.g., GLBA, AML)
  • Legitimate Interests: We have a legitimate business interest (e.g., fraud prevention)

International Data Transfers

Your data may be transferred to and processed in the United States. We use Standard Contractual Clauses (SCCs) and other safeguards to protect your data.

Supervisory Authority

You have the right to lodge a complaint with your local data protection authority if you believe we have violated your rights.

GLBA Compliance

As a financial services provider, we comply with the Gramm-Leach-Bliley Act (GLBA), which requires us to:

  • Provide clear notice of our privacy practices
  • Implement safeguards to protect customer information
  • Limit sharing of nonpublic personal information

Important: We serve real estate investors only, not consumers. GLBA's consumer protections may not apply to commercial/business transactions. However, we voluntarily apply GLBA standards to all clients.

We do not share your information with non-affiliated third parties for marketing purposes without your consent.

Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately at privacy@divinecapitalcollective.com.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated policy on this page with a revised "Last Updated" date.

For material changes, we will provide additional notice (e.g., email notification or prominent website notice) as required by law.

We encourage you to review this policy periodically to stay informed about how we protect your information.

Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Business Name

Julia Anatolvina Consulting LLC (DBA Divine Capital Collective)

Wyoming LLC

Privacy Request Form

Use this form to submit a privacy request (e.g., access, deletion, correction, opt-out). We will respond within 45 days.

By submitting this form, you confirm that the information provided is accurate and that you are authorized to make this request.