Privacy Policy

At DiviPay Pty Ltd ABN: 39 617 434 607, we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth). This Privacy Policy describes our current policies and practices in relation to the collection, handling, use and disclosure of personal information. It also deals with how you can complain about a breach of the privacy laws, how you can access the personal information we hold about you and how to have that information corrected.

What information do we collect and how do we use it?

When we provide you with our digital wallet and virtual card payment services, we ask you for the information we need:

  • to verify your identity;
  • to provide and optimise the services we provide to you;
  • to provide you with customer service and deal with any disputes or complaints;
  • for our general business and risk management purposes;
  • for business development purposes; and
  • to comply with our obligations under the law.

This can include a broad range of information including:

  • your name, address, contact details when you download the DiviPay App, register for a DiviPay card, use DiviPay online services, or enter into any promotions or competitions we may hold from time to time;
  • other personal information such as drivers licence and identification documentation details you provide to us if you are subject to our full identity verification process;
  • your photograph if you upload photos of yourself;
  • your financial information such as details about your nominated credit or debit card and nominated bank account when you register for a DiviPay;
  • information about the transactions you make and accept via DiviPay, including the value of the transactions, method of payment and reason for purchase when you make payments using your DiviPay Card;
  • information you provide us when you participate in any dialogue with us or via the DiviPay platform;
  • with your permission, your physical location using our GPS location service, when you request us to show you other DiviPay users that are near you; and
  • with your permission, your friends list and contact list in order to show you which of your friends are on DiviPay. We do not send anything to your friends without your permission first.
  • your employment and educational information when you apply for a job with us.

We may disclose your de identified personal information to third parties (such as other DiviPay users, third party social media service providers, banks, our contractors, business partners and related entities, suppliers, service providers, professional advisors and agents, card providers, debt collectors and payment gateway providers):

  • to provide and manage our services;
  • for the purpose of facilitating direct marketing
  • to assess your credit worthiness and risk;
  • with your permission, to provide commentary, share photos or other personal information you have uploaded onto our social media accounts;
  • to assess your job application (if you have applied for a job with us);
  • if our business is purchased by another party, in which case your personal information may form part of the transferred assets;
  • to comply with our legal obligations; and
  • for any other reason with your consent.

We also use your information to enable us to manage your ongoing requirements and our relationship with you. We may do so by mail or electronically unless you tell us that you do not wish to receive electronic communications.

From time to time we will use your contact details to send you offers, updates, events, articles, newsletters or other information about products and services that we believe will be of interest to you. We may also send you regular updates by email or by post. We will always give you the option of electing not to receive these communications and you can unsubscribe at any time by notifying us that you wish to do so.

We may also sell or trade your de identified Personal Information to third parties in order to facilitate direct marketing by that third party.  You may request us to stop facilitating the direct marketing of your Personal Information at any time by using the contact details set out at the end of this Privacy Policy. Subject to the exceptions set out in this Privacy Policy, we will not exchange your information with any third party for any other purpose.

We may also use your information internally to help us improve our services and help resolve any problems.

What if you don’t provide some information to us?

If you do not provide us with some or all of the information that we ask for, we may not be able to provide you access to the Divipay platform or limit your use of the DiviPay platform and features

How do we hold and protect your information?

We strive to maintain the relevance, reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements

We hold the information we collect from you in an Australian based PCI-DSS Level 1 certified data centre and protect it using the industry standard AES-256 encryption algorithm. In some cases, your file is archived and sent to an external data storage provider for a period of time. We only use storage providers in Australia who are also regulated by the Privacy Act

We ensure that your information is safe by conducting a quarterly security assessment using a Qualified Security Assessor, maintaining strong network security using firewalls and segregation, encrypting all data during transmission and storage, and restricting access to customer data. We maintain physical security over our paper and electronic data and premises, by using locks and security systems

Anonymous data – We use technology to collect anonymous information about the use of our website, for example when you browse our website our service provider logs your server address, the date and time of your visit, the pages and links accessed and the type of browser used. It does not identify you personally and we only use this information for statistical purposes and to improve the content and functionality of our website, to better understand our clients and markets and to improve our services.

Cookies Cookies – In order to collect this anonymous data we may use “cookies". Cookies are small pieces of information which are sent to your browser and stored on your computer’s hard drive. Sometimes they identify users where the website requires information to be retained from one page to the next. This is purely to increase the functionality of the site. Cookies by themselves cannot be used to discover the identity of the user. Cookies do not damage your computer and you can set your browser to notify you when you receive a cookie so that you can decide if you want to accept it. If you use only temporary cookies, insert “Once you leave the site, the cookie is destroyed and no personal or other information about you is stored." If you use permanent cookies, insert “They allow the website to recognise your computer when you return in the future".

Will we disclose the information we collect to anyone?

We may disclose your information to recipients from overseas countries for the purpose of providing you with our services in overseas countries and in local currencies. If a recipient is not regulated by laws which protect your information in a way that is similar to the Privacy Act, we will seek your consent before disclosing your information to them.

We will disclose your information to our card providers, debt collectors, payment gateway providers, third party social media service providers, banks, business partners and related entities, suppliers, service providers, professional advisors and agents, and may need to provide your information to contractors who supply services to us, e.g. to handle mailings on our behalf, external data storage providers, credit assessors and providers, or to other companies in the event of a corporate sale, merger, reorganisation, dissolution or similar event. However, we will take all reasonable steps to ensure that they protect your information in the same way that we do.

We may also sell or trade your de identified Personal Information to third parties in order to facilitate direct marketing by that third party.  You may request us to stop facilitating the direct marketing of your Personal Information at any time by using the contact details set out at the end of this Privacy Policy.

We may provide your information to others if we are required to do so by law or under some unusual other circumstances which the Privacy Act permits.

How can you check, update or change the information we are holding?

Upon receipt of your written request and enough information to allow us to identify the information, we will disclose to you the personal information we hold about you. We will also correct, amend or delete any personal information that we agree is inaccurate, irrelevant, out of date or incomplete.

If you wish to access or correct your personal information please write to Daniel Kniaz at level 2, 50 Bridge Street or email daniel@divipay.com

We do not charge for receiving a request for access to personal information or for complying with a correction request. We do not charge for providing access to personal information.

In some limited cases, we may need to refuse access to your information or refuse a request for correction. We will advise you as soon as possible after your request if this is the case and the reasons for our refusal.

What happens if you want to complain?

If you have any concerns about whether we have complied with the Privacy Act or this Privacy Policy when collecting of handling your personal information, please write to our Privacy Officer at Daniel Kniaz at level 2, 50 Bridge Street or email Daniel@divipay.com

Your complaint will be considered by us through our internal complaints resolution process and we will try to respond with a decision within 45 days of you making the complaint.

Your consent

By registering with DiviPay, you consent to the collection and use of the information you have provided to us for the purposes described above.

Further Information

For further information about our privacy policies or practices please contact us by email at daniel@divipay.com