PRIVACY

Effective date: 5 November 2026
Last updated: 5 November 2026

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This Privacy Policy explains how the Divinota mobile application handles information, the choices available to users, and how to contact the provider about privacy. It applies to the Divinota iPhone application. Data that may be collected independently by the delicvent.si website, such as website analytics, contact-form submissions or cookies, is outside the scope of this App Privacy Policy and should be described separately if used.

 

App provider and data controller
ADAL podjetje za gradbeništvo in trgovino d.o.o. Ljubljana
Ulica bratov Učakar 18, 1000 Ljubljana, Slovenia, EU
Email: info@adal.si

Website: delicvent.si

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1 Privacy overview

Divinota works without advertising, advertising profiling, cross-app tracking or third-party analytics. Most information is stored locally on the user's iPhone. When the optional Family feature is used, information required for shared shopping is stored and synchronized through Apple iCloud and CloudKit and is available to invited family members. ADAL does not operate a separate server for shopping information and does not sell personal information.

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2 Information handled by Divinota

Depending on the features used, Divinota may handle the following information:

• An optional display name or nickname entered in the App. A real name is not required.

• Selected products, custom products, baskets, preferred stores and shopping status.

• Basket history, dates and information about who created, accepted or completed a shared basket.

• Family membership and invitation information needed for iCloud sharing.

• An Apple CloudKit account identifier used to associate family data with the correct iCloud participant.

• App settings, recipe selections, reminder settings, notification times and other preferences stored on the device.

• Completed basket history used locally for optional personalized product suggestions and approximate freshness reminders.

• Technical synchronization information, including record identifiers, change tokens and pending changes.

Divinota does not request precise location, contacts, photos, camera, microphone, health data or an advertising identifier.

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3 Local storage

Solo shopping information, drafts, settings and some cached Family information are stored locally on the iPhone. Local information normally remains on the device until the user removes it through available App controls or deletes the App. Deleting the App removes its locally stored information, subject to iOS backup and restore behaviour controlled by Apple and the user.

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4 Backup export and import

A user can export a Divinota backup through Apple's Files interface and choose where to save it, including a compatible cloud-storage location available in Files. A backup can contain the local draft, local active baskets, local History, store names and selected App settings. Shared Family records and the CloudKit Family connection are not included.

Backup creation and import are processed locally on the device. ADAL does not receive or control exported backup files. Anyone who can access a backup file may be able to read its shopping information, so users should keep backup files private. After confirmation, importing a backup replaces the local Divinota information and included settings on that iPhone while preserving the current Family connection.

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5 Family sharing and Apple iCloud

Family sharing is optional and requires an iCloud account. When a user creates or joins a Divinota family, shared information is transmitted to and stored in Apple CloudKit. This may include display names, Family membership, shared products, baskets, shopping status, custom products, history and related timestamps.

Shared information is visible to invited members of that Divinota family. The Family owner controls invitations and can remove participants or stop sharing. Draft baskets remain private on the device until they are confirmed for sharing. Apple processes iCloud and CloudKit information under Apple's terms and privacy policy.

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6 Purposes and legal bases

Where the GDPR applies, information is processed for the following purposes and legal bases:

• To provide Divinota and the Family synchronization requested by the user, based on performance of a contract or steps requested by the user under Article 6(1)(b) GDPR.

• To maintain security and reliability, prevent data loss, diagnose failures and protect the integrity of the App and synchronization, based on ADAL's legitimate interest in providing a secure and reliable service under Article 6(1)(f) GDPR.

• To comply with applicable legal obligations under Article 6(1)(c) GDPR.

Family sharing is optional. Divinota can still be used for solo shopping with locally stored information.

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7 Personalized suggestions

When enabled, Divinota uses completed shopping history already available in the App to suggest products that the household may need again. Only products recorded as purchased are considered. This analysis takes place on the device. The resulting suggestion profile is not uploaded to ADAL, is not shared with third parties and is not used for advertising. Personalized suggestions can be disabled or their learning period reset in Settings without deleting baskets or History.

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8 Reminders and notifications

When enabled, Divinota uses completed basket history already available on the device to show approximate Use Soon reminders for recently purchased fresh products. These reminders are calculated and dismissed locally, are not uploaded to ADAL and do not determine whether food is safe to eat. Users should always follow packaging, storage instructions and the actual condition of the food.

Users can separately enable local Use Soon notifications and Active Basket notifications and select one or more available notification times for each feature. Active Basket reminders use the active baskets stored or synchronized on the device and stop after the relevant baskets are claimed, completed or deleted. Notification preferences are stored locally and can be changed in Divinota or in iPhone Settings. These notifications are not used for advertising or tracking.

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9 Sharing of information

Information is shared only where necessary:

• Invited members of a Divinota family receive shared Family information.

• Apple processes information as the provider of iOS, iCloud and CloudKit infrastructure.

• Information may be disclosed to competent authorities where disclosure is required by law.

ADAL does not sell personal information and does not share it for behavioural advertising or cross-app tracking.

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10 Retention and deletion

Local information is retained until the user deletes it through available App controls or deletes the App. Shared CloudKit information is retained while the relevant family or shared records remain active. The Family owner can remove a participant or stop sharing. Available App controls can remove completed or deleted baskets.

Divinota does not create a separate account on ADAL servers. Some information stored through iCloud may need to be managed through the Family owner's sharing controls, the user's Apple Account or the relevant device settings. Deleting the App from one device does not by itself guarantee deletion of shared records that remain active in CloudKit or available to other Family members.

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11 Security

Divinota uses Apple platform protections, CloudKit sharing permissions and iOS data protection for local Family files. No method of storage or transmission is completely secure. The App is designed to limit shared access to invited participants and to preserve pending changes when synchronization is temporarily unavailable.

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12 International data transfers

Apple may process information in countries outside the user's country of residence. Such processing is subject to Apple's contractual and legal safeguards. Information about Apple's privacy practices and international data-transfer safeguards is available through Apple's privacy documentation. Users may contact ADAL for further information relevant to Divinota.

Apple Privacy Policy apple.com/legal/privacy

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13 Children

Divinota is intended for household shopping and is not designed to collect information directly from children for advertising or profiling. A parent or guardian should manage Family invitations and supervise a child's use where required by applicable law. A child should use a nickname rather than a real name where appropriate.

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14 User rights

Depending on applicable law, users may have rights of access, correction, deletion, restriction, portability and objection. Users may also lodge a complaint with the Information Commissioner of the Republic of Slovenia or another competent supervisory authority.

To exercise these rights, contact ADAL at info@adal.si. ADAL may require sufficient information to verify and process a request. ADAL may not be able to access information held only in a user's private iCloud environment. In that case, ADAL will explain the available device, sharing or Apple Account controls.

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15 Changes to this Privacy Policy

ADAL may update this Privacy Policy when Divinota, legal requirements or service providers change. The latest version will be published at the same web address with an updated Last updated date.

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16 Contact

ADAL d.o.o. Ljubljana
Gospodinjska ulica 8
1000 Ljubljana, Slovenia
Email info@adal.si
Website: delicvent.si