PRIVACY DISCLOSURE POLICY

Introduction

Divvied LLC ("we," "us," or "our") is committed to protecting the privacy of our users ("you," "your"). This Privacy Policy describes how we collect, use, share, and protect your personal information when you use our mobile application ("App"), website ("Site"), and related services (collectively, the "Services").


By using Divvied, you agree to the terms outlined in this Privacy Policy. If you do not agree with our practices, please discontinue using our Services.


Information We Collect

We collect information to provide, improve, and secure our Services. This includes:


Information You Provide to Us

      • Personal Identifiable Information (PII): Name, email address, phone number, address, date of birth, and government-issued identification (for KYC verification).
      • Account Information: Login credentials, security questions, and two-factor authentication information.
      • Payment Information: Linked payment methods (debit/credit card, CashApp, PayPal, Venmo, Apple Pay, Google Pay) and associated account details.


Information We Collect Automatically

      • Device Information: Device type, operating system, browser type, IP address, and device identifiers.
      • Usage Information: Time, frequency, and duration of use, as well as in-app activity and navigation.
      • Location Information: Geolocation data (with your consent) to support regulatory compliance and secure payments.


Information from Third Parties (Including Social Media Accounts)

We may collect information from third-party partners including social media login providers (LinkedIn, Google, and Facebook), as well as  payment processors, KYC verification providers to verify identities, process transactions, and enhance security.

      • Social Media Login & Profile Information: When you sign up or log in using LinkedIn, Google, or Facebook, we may receive your name, email address, profile picture, and other publicly available information based on your social media settings.
      • Authentication Tokens: To facilitate secure login, we receive an authentication token from the social media provider instead of storing passwords.
      • Consent-Based Collection: We collect this information only if you choose to sign up or log in via social media. You will have the ability to review and manage your linked accounts in the app settings.


How We Use Your Information

We use your information for the following purposes:

        • To Provide and Improve Our Services: Enable payments, process withdrawals, and load funds via payment providers.
        • To Verify Your Identity: Comply with Anti-Money Laundering (AML) and Know Your Customer (KYC) requirements.
        • To Facilitate Social Media Login: Allow users to sign up, log in, and authenticate their identity using LinkedIn, Google, or Facebook.
        • To Populate User Profiles: Auto-fill your Divvied profile with information from your social media account (e.g., name, profile photo).
        • To Communicate With You: Send notifications, account updates, and policy changes.
        • To Ensure Security and Fraud Detection: Monitor activity for suspicious transactions and secure user accounts.
        • To Comply with Legal Obligations: Meet requirements under applicable U.S. laws and financial regulations.



User Control Over Linked Social Media Accounts

Users who sign up with LinkedIn, Google, or Facebook can manage their linked accounts within the Divvied App:

        • Unlinking a Social Media Account: Users can disconnect their social media login method from the app settings. If unlinked, users will need to create a password for future logins.
        • Data Retention: If a user unlinks their account, Divvied will retain any user information collected during sign-up (e.g., name, email) unless a formal account deletion request is made.
        • Limited Access: We do not post content on users’ social media accounts or access private information beyond what is explicitly provided for authentication.


How We Share Your Information

We do not sell your personal information. However, we may share it with:

        • Service Providers: Payment processors (CashApp, PayPal, Venmo, etc.), KYC verification providers, and analytics providers.
        • Social Media Login Providers: Authentication services via LinkedIn, Google, and Facebook to facilitate login.
        • Law Enforcement or Regulatory Authorities: To comply with legal obligations or respond to lawful requests.
        • Business Transfers: If Divvied undergoes a merger, sale, or transfer of assets, user data may be included in the transaction.


How We Protect Your Information

We implement strong security measures to protect your information, including:

        • Encryption: All sensitive data is encrypted during transmission and at rest.
        • Two-Factor Authentication (2FA): 2FA is required for logins and sensitive actions.
        • Access Controls: Only authorized personnel can access personal data.
        • Periodic Audits: We conduct regular audits to ensure compliance with our data protection policies.


Your Rights and Choices

You have the right to:

        • Access Your Information: Request access to your personal information.
        • Correct Your Information: Update or correct inaccuracies.
        • Delete Your Information: Request deletion of your account or personal data (subject to regulatory retention requirements).
        • Opt-Out of Marketing: Unsubscribe from marketing communications.


Data Retention

We retain your data for as long as necessary to fulfill the purposes outlined in this Privacy Policy or comply with legal obligations. Upon account closure, some information may be retained to comply with financial regulations.


Children’s Privacy

Divvied does not knowingly collect information from children under the age of 13. If we become aware of such data, we will delete it immediately.


Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, Services, or legal obligations. We will notify users of significant changes via email or an in-app notification.


Contact Us

If you have any questions or concerns about this Privacy & Disclosure Policy, please contact us at: support@divvied.app



Divvied LLC 

Address: 8 The Green STE A, Dover, DE 19901, United States 

Email: [support@divvied.app]


Effective Date: January 2025 

Last Updated: January 2025