Pheace: Not sure if this was about Dragon Commander or Divinity anymore but pretty sure of one of them they said both versions were DRM-free, even the Steam one. (I guess it was Dragon Commander). That with the Steam version, if you ran the game with Steam you'd have all the features like Steam play and achievements etc, but if you ran it completely without Steam, you'd basically have the GOG version. So they were both DRM-free.
I guess it's possible they did Divinity the same way.
It's not /quite/ DRM-free.
Basically, as they had to make the discs before the game was completed, you need to patch it once on steam if you bought the retail version.
Once it's patched, you can uninstall steam/whatever and still play the game with steam not installed, and the game is DRM-free (you can totally save it on a disc/hard-drive and use it for future install, for examples).
So it's "gated" by a patch.