Disclaimer, privacy and company details

Not investment advice

All information on this website is general and informative in nature. It is expressly not investment advice, not a personal recommendation and not an invitation to buy, sell or hold any financial instrument whatsoever. No account is taken of your personal situation, financial position, knowledge, experience or objectives.

No AFM licence

Divergent Solutions does not hold a licence from the Dutch Authority for the Financial Markets (AFM) and is not supervised by the AFM or by De Nederlandsche Bank. No investment services within the meaning of the Dutch Financial Supervision Act are provided: no asset management, no order execution for third parties and no personalised investment advice.

Own risk

Investing and trading in equities, commodities and crypto carries risk. The value of an investment can fall, and loss of the entire amount invested is possible. Anyone taking a decision based on information from this site does so entirely at their own responsibility and for their own account and risk.

No promise of returns

No returns are named, promised or suggested on this site. Past results are no guarantee for the future.

That distinction is worth making explicit, because this site does show the allocation of a portfolio. A percentage in that allocation says which share of the whole sits in a sector. It says nothing about profit or loss, and no return can be derived from it. See the next section.

About the portfolio allocation shown

The homepage and Sectors show the allocation of a portfolio across sectors and subsectors. The following applies to it.

• It is the personal portfolio of Pim van den Boomen, held for his own account and at his own risk. No trading is done on anyone else’s behalf.
• These are weights and counts, not amounts. No euros are shown, no account value, no amount invested and no purchase or sale prices.
• No individual instruments are named: no tickers, no ISINs, no company names. The taxonomy is the information, not the contents.
• It is a snapshot with a stated reference date. The allocation changes as soon as trading happens, and the picture on this site lags behind it by definition.
• The classification into sectors and subsectors is an own classification, made manually and open to revision. It follows no external standard and cannot be compared with anyone else’s.
• It is not a recommendation to replicate this allocation, and no indication that it would be suitable for anyone.

Accuracy of the information

The information is compiled with care, but no guarantee is given that it is complete, current or free of errors. Divergent Solutions accepts no liability for damage arising from the use of this site or of the information on it.

Methods described

The analytical frames and systems described on this site are a rendering of the author’s own way of working. They are meant descriptively and do not constitute a model that is suitable or validated for use by others.

No cookies of our own

This website places no cookies of its own and uses no tracking scripts that follow you across websites. So there is no cookie banner either: on the site itself there is nothing to allow or refuse.

Signing up for the newsletter

The sign-up block on the homepage is our own form, not someone else’s window. Press Sign up and your address goes to this site’s server and nowhere else: it is checked here (is there a mail server on the domain behind the @?) and then stored in our own subscriber list, in a database I manage myself.

Divergent Journal asks only for your email address. Until 4 October 2026 the homepage also carried a request form for Divergent Intel, which additionally asked two things in your own words: what you invest in, and what you hope to get out of it. Divergent Intel has since been a closed workspace for two fixed people and cannot be requested; the site no longer accepts requests. What happens with requests sent in earlier is set out below under What is processed.

Your browser makes no connection with another party in the process. That has been different since 28 August 2026: before then a sign-up ran through Substack, and at the moment of sending your browser did contact substack.com. That step is gone.

If you would rather be on Substack’s list directly (because you want to read the newsletter there, for instance), that is still possible: the blog page has a button to their sign-up page. That is a plain link, nothing is loaded as long as you do not click it, and from that moment on Substack’s privacy policy applies. The blog posts themselves are fetched when the site is built and then sit in the page as plain text. No request from your browser to Substack is involved there either. This site loads nothing from a third party on any page, and sends nothing to one.

Visitor statistics

Cloudflare Web Analytics is used for visitor counts. That measurement is cookieless and builds no profile of individual visitors; no data that identifies you as a person is collected.

What is processed

• Email. If you send a message, your email address and the content of your message are processed in order to answer your question.
• Previously booked conversations. Until October 2026 you could book a conversation through the contact page. For such an appointment, your name, email address and chosen time were recorded in Google’s calendar environment. No new appointments are added: the site no longer takes bookings. If you want an earlier appointment removed, send a message to pim@divergentsolutions.nl.
• Signing up for Divergent Journal. If you sign up, your email address is stored in the Divergent Solutions subscriber list, together with the moment of signing up. Nothing more is recorded: no name, no IP address, no behaviour on the site. The address is used only to send you the newsletter, is not sold on and is not shared with third parties. You can unsubscribe via any newsletter or with a message to pim@divergentsolutions.nl; your address is then deleted.
• Earlier requests for Divergent Intel. From 28 August to 4 October 2026 you could request access via the homepage. For such a request your email address and your two answers (what you invest in and what you hope to get out of it) are kept in the same list as the newsletter, with a note that it was a request. No new requests are added: Divergent Intel is a closed workspace and cannot be requested. The answers are not sold on and not shared with third parties. For every request I received a message in my own Telegram at the time with those two answers in it; your email address was not in that message. If you unsubscribe, the two answers are erased at the same time. If you want your request or your answers deleted, send a message to pim@divergentsolutions.nl.
• Technical logs. The hosting provider processes technical data such as IP address and time of the request in order to deliver and secure the site.

Legal basis and retention

Data you provide yourself is processed in order to be able to be in contact with you (legally: on the basis of your consent, or in order to take steps at your request prior to a possible agreement). It is kept no longer than necessary for that purpose, and is not sold or shared with third parties for commercial purposes.

For the newsletter that means: your address stays on the list as long as you want it there. If you unsubscribe, it is deleted and not kept as “once unsubscribed”.

For an earlier request for Divergent Intel the same applies, with one addition: the two answers served only to assess the request. If you do not want to stay on the ordinary newsletter, the address and the answers come off together.

Your rights

You have the right to access your data, to have it corrected or deleted, and to object to the processing. Send a message to pim@divergentsolutions.nl for that. If we cannot resolve it together, you can lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).