> How the Divido retail finance widget sets cookies and processes credit application data and checks, plus GDPR duties on automated decisions. > > Canonical: https://www.flowconsent.com/en/services/ecommerce/divido E-commerce # Divido Preferences · [Official website](https://www.divido.com/) Divido is a white label retail finance platform that lets retailers offer point of sale instalment credit and pay monthly options at checkout. When its finance calculator or checkout widget is embedded, it sets cookies for session handling and attribution and processes credit application data, often including a credit check. Under the GDPR and the ePrivacy Directive, its non essential cookies require prior consent and the lending decision triggers automated decision making safeguards. [Block Divido until consent](https://app.flowconsent.com/auth/sign-up?utm_source=flowconsent.com\&utm_medium=referral\&utm_campaign=ecommerce) · [Scan my site](https://www.flowconsent.com/en/scan) At a glance - Category [E-commerce](https://www.flowconsent.com/en/services/ecommerce) - Consent Preferences - Prior consent Required - Documented cookies 3 - Third-party domains 3 - Servers United Kingdom and European Union Overview ## What does Divido do? ## **What is Divido?** Divido is a white label retail finance and lending platform that lets retailers add point of sale instalment credit, pay monthly and pay later options at checkout. It connects merchants with a network of lenders and presents a finance calculator and application flow under the retailer own branding. It is headquartered in the United Kingdom and operates across Europe. ## **What data and cookies does it collect?** When the Divido calculator or application loads it sets cookies for session handling and conversion attribution and reads device data. To assess an application, Divido and its lending partners process identity, contact, employment and financial information, and usually perform a credit check with a credit reference agency. Some cookies are persistent identifiers used to attribute the sale. ## **GDPR and ePrivacy implications** The attribution cookies are not strictly necessary and require consent under Article 5(3) of the ePrivacy Directive. The credit decision often constitutes automated decision making with legal or similarly significant effect, which under Article 22 of the GDPR requires specific safeguards, including meaningful information about the logic and a right to obtain human intervention. ## **Consent requirements** Block Divido non essential cookies until the shopper accepts them through a Consent Management Platform, while cookies strictly necessary to run a finance application the shopper has started may load. Inform applicants clearly about the credit check and automated decision, log consent, and let shoppers refuse non essential tracking as easily as they accept. ## **Data transfers** Divido processes data in the United Kingdom and the European Union. The UK benefits from a European Commission adequacy decision, so transfers from the EU are permitted without additional safeguards, although you should record them. Confirm where any lending partners process data and apply Chapter V safeguards if any are outside an adequate country. ## **Practical compliance steps** List the Divido cookies and domains in your cookie policy and gate non essential ones behind consent. Define the controller and processor roles between your business, Divido and the lenders, sign the appropriate agreements, and give applicants clear information about the credit check, the automated decision and their right to human review. Carry out a DPIA before launch. Compliance ## Divido and the GDPR Divido is classified as “Preferences”. On a site that targets European visitors, it must only load after the visitor consents, and it must be listed in your cookie policy. - Legal basis Consent (Art. 6(1)(a) GDPR) - Risk level high - Applicable regulations GDPR, ePrivacy Directive (Cookie Law) ### Impact assessment (DPIA) Divido processes identity, contact, financial and order data and typically runs a credit check to approve point of sale finance. Key DPIA considerations: (1) the lending decision can be an automated decision with legal or similarly significant effect under Article 22 GDPR, requiring safeguards and a right to human review; (2) credit reference data is sensitive in nature and tightly regulated; (3) attribution cookies are persistent identifiers needing consent; (4) controller roles between retailer, Divido and the lender must be defined. A DPIA is strongly recommended for this high risk financial processing. ### Sample text for your banner > We offer Divido so you can pay for your purchase in monthly instalments. The Divido finance application sets cookies and processes your identity, financial and order data, and may run a credit check to decide your application. You can withdraw your consent to non essential cookies at any time through our cookie settings. Cookies and trackers ## What Divido sets and contacts - Tracking method JavaScript finance calculator and checkout widget with cookies - Server location United Kingdom and European Union - Data transferred outside the EU Divido processes data in the United Kingdom and the European Union. The UK benefits from a European Commission adequacy decision, so transfers from the EU are permitted without additional safeguards, which you should still document. Confirm where any lending partners process data and apply Chapter V safeguards if any operate outside an adequate country. ### Cookies set (3) | Name | Type | Duration | Purpose | | --------------- | ----------------------- | -------- | ------------------------------------------------------------------------------------------------- | | divido\_session | Functional | Session | Maintains the applicant session through the Divido finance application. | | \_dv\_attr | Attribution / Analytics | 1 year | Persistent identifier used to attribute completed finance orders and recognise returning devices. | | dv\_state | Functional | 30 days | Stores the progress of a finance application so it can be resumed. | ### Third-party domains contacted (3) - `divido.com` - `api.divido.com` - `cdn.divido.com` Questions ## Frequently asked questions about Divido Can't find your question? Write to us, we answer fast. [Write to us](https://www.flowconsent.com/en/demo) ### What cookies does Divido set? Divido sets cookies for session handling and conversion attribution when its finance calculator or application loads. The attribution cookies are persistent identifiers that are not strictly necessary, so they require consent, while cookies needed to run a finance application the shopper has started may be treated as essential. ### Does Divido require cookie consent? Yes for the non essential cookies. The attribution and tracking cookies Divido sets need prior consent under the GDPR and the ePrivacy Directive, so they should not load until the shopper accepts. Cookies strictly necessary to run a requested finance application can rely on a different basis. ### What is the legal basis for Divido? Consent under Article 6(1)(a) GDPR covers the attribution cookies. The finance application itself relies on contract and the lender legal obligations, but where the approval is an automated decision with significant effect, Article 22 GDPR safeguards and explicit consent or contractual necessity must be in place. ### Does Divido transfer data outside the EU? Divido processes data in the United Kingdom and the EU. The UK has an EU adequacy decision, so transfers are permitted without extra safeguards, but you should document them and verify that any lending partners do not process data in a non adequate country without Chapter V safeguards. ### Do I need a DPIA for Divido? A DPIA is strongly recommended. The processing involves credit reference data and an automated lending decision that can have legal or similarly significant effects, which Article 35 GDPR treats as high risk, so documenting purposes, logic, risks and safeguards is essential. ### How do I implement Divido compliantly? Add Divido through a CMP that blocks non essential cookies until consent, keep application essential cookies separate, and define the controller and processor roles with Divido and the lenders. Provide clear information about the credit check, the automated decision and the right to human review, and complete a DPIA before launch. ### Are there alternatives to Divido? Other point of sale finance and BNPL providers include Klarna, Clearpay, Scalapay, Alma and Younited, several of which are European. All process credit related data and set tracking cookies, so the compliance work is similar; the focus is on consent, transparency about credit decisions and clear controller roles. ### How do I update my cookie policy for Divido? Describe the Divido cookies, their purpose and duration, list the Divido domains, and note that data is processed in the UK and EU. 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