Privacy Policy

This Privacy Policy explains how Divvum, Inc. ("Divvum," "we," "us," or "our") collects, uses, shares, and protects information about you when you use the Divvum mobile application, website, and related services (the "App").

This Policy is incorporated into our Terms of Use. Capitalized terms not defined here have the meaning given in the Terms.

Three things to understand before you read further:

1. Information We Collect

1.1 Information you give us

1.2 Information collected automatically

1.3 Contacts, and finding friends nearby

Divvum does not access your contacts. The App does not ask for permission to read your address book, does not upload it, and does not store anything about the people in it. You find friends on Divvum by username, by phone number you enter yourself, or by an invite link you share.

Finding friends nearby (Bluetooth). Divvum includes a feature that uses your device's Bluetooth radio to discover other Divvum users physically near you, so you can add them without typing a username.

How the nearby feature works:

• It runs only if you turn it on, from inside the nearby screen. It is off by default.
• Your device broadcasts a short Bluetooth signal and listens for signals from other Divvum users. Discovery happens over the radio only — being on the same network, or being in the same city, is not enough. Signal range is limited to a few metres.
• We learn that two users' devices were close enough to hear each other, and we show each of you the other's name and profile photo. We do not collect your GPS position or track your movements, and we do not build a history of where you have been or who you have been near.
• Android requires apps to hold the location permission in order to use Bluetooth scanning at all. Divvum requests it for that reason only — the App does not read your location, and does not use it to determine where you are.
• You can turn the feature off at any time, and revoke the Bluetooth or location permission in your device settings.

1.4 Identity verification information (KYC)

To send, fund, or withdraw money, you must complete identity verification. This may involve providing your legal name, date of birth, residential address, Social Security number or other government identification number, and images of a government-issued ID.

This information is collected directly by our verification partners — Bridge and/or Stripe — not by Divvum. It is submitted through their interfaces and is processed by them under their own privacy policies and their own legal obligations as regulated financial institutions.

Divvum receives only the result of verification (for example: approved, declined, or pending) and limited associated metadata, so we know which features to enable for your account.

1.5 Bank account information

When you link a bank account to withdraw funds, you do so through Plaid. You enter your bank credentials directly with Plaid; Divvum never sees, receives, or stores your online banking username or password. Plaid provides us (and Bridge) with a secure token and limited account information, such as the account holder name, account type, institution name, and the last four digits of the account number.

Plaid's handling of your information is governed by Plaid's privacy policy, which you should review.

1.6 Your Repayment Record

Divvum keeps a record of the obligations you take on in the App and how quickly you settle them. Each time someone requests money from you, adds you to a split, or includes you in a group expense, and each time you settle it, we record the obligation, the amount, when it was created, and when it was settled. Together these events are your "Repayment Record."

From your Repayment Record we calculate your average payback time, which determines your rank and your position on leaderboards visible to your connections (see Section 4.2).

Your Repayment Record is not a credit report and Divvum is not a credit bureau. We do not send it to credit bureaus, we do not sell it, and we do not give it to lenders, landlords, employers, or anyone else.

2. How We Use Information

We use information to:

• Create and maintain your account and your Divvum Wallet;
• Confirm that you are 18 or older;
• Process the sends, requests, splits, and withdrawals you initiate, and display your balance and history;
• Determine which features you are eligible for, based on the result of identity verification;
• Calculate and display your Repayment Record, average payback time, rank, and leaderboard position;
• Calculate and display your Points;
• Provide customer support and respond to your requests;
• Detect, investigate, and prevent fraud, abuse, security incidents, manipulation of Points, ranks, or the Repayment Record, and activity that violates our Terms or the law;
• Comply with legal obligations, and to enable our Third-Party Providers to comply with theirs (including anti-money-laundering and sanctions requirements);
• Send you transactional, security, and service communications, and — with your consent where required — marketing communications;
• Analyze and improve the App, understand how features are used, and develop new ones; and
• Enforce our Terms and protect the rights, safety, and property of Divvum, our users, and others.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We do not operate an advertising network and we do not make your information available for anyone else's marketing.

3. Legal Bases and Consent

Where required, we rely on your consent (for example, to send push notifications or marketing messages), on the necessity of processing to perform our contract with you, on our legitimate interests in operating and securing the App, and on compliance with legal obligations. You may withdraw consent at any time through your device settings or in the App, though some features may not work without it.

4. How We Share Information

4.1 With our Third-Party Providers

We share information with the providers that make the App work:

Bridge, Stripe, and Plaid — and Apple and Google when providing sign-in and app store services — are independent companies that act as controllers of your data in their own right for the services they provide directly to you, meaning they use it under their own privacy policies, not ours. You should review their policies. When Google provides our Firebase infrastructure, it acts as our processor, using data only on our instructions.

4.2 With other users

Other users can see information you choose to share: your name, username, profile photo, and any transactions, memos, GIFs, requests, groups, or splits you share with them.

Your rank and your average payback time are visible to your connections in the App, including on leaderboards. This is a core feature of Divvum — the point of the product is that settling up promptly is recognised among your friends. There is no setting that hides it, so if you do not want your payback behaviour visible to the people you are connected with, Divvum is not the right app for you.

There is no public feed and no global leaderboard. Leaderboards in the App are built from the people you are connected with.

4.3 Rewards

Divvum does not currently operate a rewards program. Points accumulate in your account but cannot be redeemed, and the Rewards area of the App displays Coming soon. We do not share your information with any rewards provider, affiliate network, or merchant, because there is none.

If we launch a rewards program in the future, we will update this Policy before it starts and tell you what changes.

4.4 For legal and safety reasons

We may disclose information if we believe it is reasonably necessary to comply with a law, regulation, subpoena, court order, or governmental request; to enforce our Terms; to detect or prevent fraud, security, or technical issues; or to protect the rights, property, or safety of Divvum, our users, or the public.

4.5 Business transfers

If Divvum is involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such transfer and any resulting changes to this Policy.

5. Blockchain Data — Please Read This

Your Divvum Wallet exists on Solana, a public blockchain. When you send or receive money in the App, a record of that transfer is written to the Solana blockchain. That record is:

• Public. Anyone in the world, without an account and without permission, can view it using a public block explorer.
• Permanent. It cannot be edited, hidden, or removed — by Divvum, by our Third-Party Providers, by any government, or by you.
• Not deletable. If you delete your Divvum account, the blockchain record of your transactions remains public forever. No right to deletion — under any law, in any jurisdiction — can remove data from a public blockchain. This is a property of the technology, not a choice we are making.

The blockchain record includes your Wallet address, the recipient's Wallet address, the amount, and the time. It does not include your name, email, or phone number.

However, blockchain records are pseudonymous, not anonymous. If your Wallet address ever becomes associated with your real identity — for example, because you share it, because someone you paid knows who you are, because of an analytics firm's clustering, or because of a data breach at any company that knows both your identity and your address — then your entire history of payments through Divvum, past and future, may be linkable to you, publicly and permanently. That history includes who you paid, when, and how much.

We cannot prevent this, and we cannot reverse it.

6. Security

We use administrative, technical, and physical safeguards designed to protect your information, including encryption in transit and at rest. Sensitive identity and payment credentials are collected directly by our regulated Third-Party Providers rather than by Divvum (see Sections 1.4 and 1.5).

No system is perfectly secure. We cannot guarantee the security of your information. And because your Wallet is self-custodial, anyone who gains access to your Authentication Method can move your funds, and Divvum cannot reverse those transfers. Protect your device, your sign-in credentials, and your phone number.

7. Data Retention

We keep information for as long as we need it for the purpose we collected it, and then delete it. In practice:

We may keep information longer where we are legally required to, where it is needed to resolve a dispute or investigate fraud, or where deletion is not technically possible — in which case we isolate it and stop using it.

Your Repayment Record after you leave. When you close your account, your record is immediately removed from your rank and from every leaderboard. The underlying entries are then kept for five years, matching the financial recordkeeping period our providers already work to, and deleted at the end of it. During that time the record is not used for anything.

Deleting your account. You can delete your account in the App under Settings, which deletes your sign-in account, your profile, and your username. You can also ask us to delete your account by emailing contact@divvum.app, and we complete emailed requests within 30 days.

8. Your Privacy Rights

Depending on where you live, you may have the right to:

• Access the personal information we hold about you;
• Correct inaccurate information;
• Delete your information;
• Port your information to another service;
• Opt out of the sale or sharing of your personal information, and of targeted advertising;
• Limit the use of sensitive personal information; and
• Not be discriminated against for exercising these rights.

To exercise any of these rights, contact us at contact@divvum.app or use the controls in the App. We will verify your identity before acting on your request. You may authorize an agent to act on your behalf.

Important limits on deletion. If you ask us to delete your information, we will delete what Divvum holds, subject to the retention obligations described in Section 7. We cannot delete:

• Records written to the Solana blockchain (Section 5) — no one can;
• Information held by Bridge, Stripe, or Plaid under their own legal recordkeeping obligations — you must contact them directly; or
• Information we are legally required to keep.

Your Repayment Record is removed from your rank and from every leaderboard when you close your account, and the underlying records are deleted five years later, as described in Section 7.

California residents. The table below sets out the categories of personal information we have collected in the preceding twelve months, where it comes from, why we collect it, and who we disclose it to. We have not sold personal information, and have not shared it for cross-context behavioral advertising, in the preceding twelve months.

We do not use or disclose sensitive personal information for any purpose other than those permitted without a right to limit under California law — providing the service you asked for, security, and legal compliance.

To exercise any right in this Section, contact us at contact@divvum.app. We honor Global Privacy Control signals as a valid opt-out request where applicable. We will not discriminate against you for exercising any of these rights.

9. Children

The App is not directed to anyone under 18, and we do not knowingly collect personal information from anyone under 18. If we learn we have, we will delete it. If you believe a minor has provided us information, contact us at contact@divvum.app.

10. International Users

The App is intended for use in the United States. If you access the App from outside the United States, you understand that your information will be transferred to and processed in the U.S., where privacy laws may differ from those in your country.

11. Changes to This Policy

We may update this Policy from time to time. We will post the updated Policy in the App and update the "Last updated" date. If we make material changes, we will provide additional notice, such as an in-app notification or email.

12. Contact Us

Questions, requests, or complaints about this Policy:

Divvum, Inc.
contact@divvum.com
131 Continental Dr, Suite 305, Newark, DE 19713