Privacy Policy

Updated October 20, 2020

Divvy knows the importance of and values the privacy of all its customers. We agree that how your personal information is collected, used, and shared is important and we take this responsibility seriously. Our primary goal is to provide you with exceptional service, and we understand that you may have questions or concerns regarding your personal information and how it will be used. You can talk to us about this policy at [email protected].

This document describes how Divvy will process (collect, transmit, store, use, share, and erase) personal information. This document will help you make an informed decision about how you want to use our products and services.

This policy does not include anonymized and aggregated data.

Applicability of Privacy Policy

This privacy policy applies to all information DivvyPay, Inc. (“Divvy”, “we”, “us”) collects through our web and mobile applications from Divvy users, including you. By using or accessing our web and mobile application (“Divvy Services”), you acknowledge that you accept the practices and policies delineated in this Privacy Policy, and you hereby consent that we may collect, use, and share your information in the ways defined. This Privacy Policy, or its future variations, will continue to apply if your use of our Services is discontinued by either you or Divvy. This policy only applies to the Divvy Service(s) and does not apply to the practices of any other partner or third-party provider.

In this policy, the term “personal information” is used to describe information that can be associated with a specific individual and can be used to identify that person. We do not consider personal information to include information that has been anonymized so that it does not identify a specific user.

The information we collect

The Divvy products you use and how you use them dictates which personal information is collected.  Divvy collects personal information when you directly interact with Divvy in the following ways:

  • Browsing getdivvy.com or using app.divvy.co
  • Completing an application and creating a Divvy account
  • Using our iOS or Android mobile apps
  • Making a purchase using your physical or virtual Divvy card
  • Communicating (e.g. calling, chatting, or interacting with us, including Customer Experience or Sales interactions)
  • Interacting with us at a conference or event

Information We Collect When You Use Our Products and Services

Information needed to apply for a line of credit and create a Divvy Account

If you are opening a Divvy account, we need to process a certain amount of information about you, your business, and individuals associated with your business to comply with our legal and regulatory obligations and to address our fraud risks. We will collect the following information:

Identification Information 

  • Email address 
  • Name
  • Telephone number
  • Home street address 
  • Social security number or passport number
  • Date of birth
  • Business name
  • Business address
  • Business industry
  • Business tax ID
  • Business revenue

Banking Information

  • Bank name
  • Account holder name
  • Account number
  • Routing number
  • Bank address

Device and Connection Information

  • IP address
  • Geolocation data
  • Browser type and version 
  • Operating system and other software installed on your device 
  • Unique device identifier and other technical identifiers
  • Performance data
  • Error reports

Usage data

  • Features you used
  • Settings you selected
  • Your URL clickstream data (including date and time stamp and referring and exit pages) 
  • Pages you visited on the service

Information needed to use our products and services
Personal information is required to be processed when your business assigns a credit card to you.  To use this service, we will collect: 

  • Your name
  • Your email
  • Your phone number

Information processed when you make a transaction
When a payment is made by you on the Divvy platform, we collect information about your transaction. The transaction information is received: (i) directly from you; (ii) from the issuing bank (WEX bank); and/or (iii) from the card networks (Mastercard). We will collect:

  • Payment method information
  • Purchase amount
  • Purchase date
  • Purchase location
  • Receipt information
  • Information provided to us by the card network associated with transactions, merchants, or cardholders

Information automatically processed when you visit our websites or use our mobile app

In order to facilitate the best financial and security experience for you and us, personal information is automatically collected when you visit or use our website and/or mobile app. We will collect:

Browser and device information

Device and connection information

  • IP address 
  • Geolocation data
  • Browser type and version 
  • Operating system and other software installed on your device
  • Unique device identifier and other technical identifiers
  • Performance data
  • Error reports

Usage data

  • Features you used
  • Settings you selected
  • Your URL clickstream data (including date and time stamp and referring and exit pages)
  • Pages you visited on the Service

Cookies and trackers
To create optimal website functionality, we use cookies and other activity tracking tools to: 

  • Provide you services such as those that allow you to chat with our Customer Success team
  • Perform website analytics
  • Prevent fraud and prevent attacks against our websites and services
  • Assign you a unique identifier so we can record: (i) websites you visit; (ii) length of time the advertisement was visible; and (iii) IP address

You have the option to block cookies and other activity tracking tools used by us; however, in doing so, you may limit the functionality and use of certain features of our services.

Information processed when you interact with Divvy
Personal information may be collected about you when you interact with our customer-facing teams (e.g., Customer Success, Growth, Sales, or Marketing) through phone calls, chat services, or email. We may collect:

  • Your name
  • Your email, phone number, or other contact information
  • Content of your communications and survey responses

Information from person(s) under the age of 18 

We do not knowingly solicit or collect information from any individuals under the age of 18. If we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible.

How we protect & store personal information

We store and process your personal information using third-party servers located in secure data centers in the United States. The information is protected by physical, electronic, and procedural safeguards in compliance with applicable US federal and state regulations. We employ electronic safeguards such as firewalls and data encryption. We enforce physical access controls to our office and files. We authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

We make reasonable efforts to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered, or destroyed by breach of our administrative, managerial, and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your Divvy password with anyone.

If Divvy learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Divvy Service, you agree that Divvy may communicate with you electronically. Divvy may post a notice on the website if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach) you should notify us.

How we use the personal information we collect

Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, fun, and customized experience. We may use your personal information to:

  • Provide the services and customer support you request
  • Process transactions and send notices about your transactions or your network activity
  • Prevent potentially fraudulent, prohibited or illegal activities, and enforce our user agreement
  • Customize, personalize, measure, and improve our services and the content and layout of our website
  • Send you updates about new products and services that we are offering to customers
  • Compare information for accuracy and verify it with third parties 
  • Perform other duties as required by law

How we share personal information within the Divvy network

To process payments on Divvy, we need to share some of your personal information with the person or company that you are paying or is paying you. Your contact information, date of sign-up, the number of payments you have received and other verification metrics like social graph activity may be provided to users or companies when you transact with, on, or through Divvy.

We work with vendors to enable them to accept payments from you using Divvy. In doing so, a vendor may share information about you with us, such as your mobile phone number or Divvy username, when you attempt to pay that vendor. We use this information to confirm with that vendor that you are a Divvy customer and that the vendor should enable Divvy as a form of payment for your purchase.

We may share anonymized and aggregated data, including transactional data. We will obtain your prior written consent before ever sharing your data in an attributable format. You may revoke consent at any time here.

Regardless, we will not disclose your credit card number or bank account number to anyone you have paid or who has paid you through Divvy, except with your express permission or if we are required to do so to comply with a subpoena or other legal process.

How we share personal information with other parties

Divvy does not share your personal information with third parties for promotional or marketing purposes.

We may share your personal information with: 

  • Law enforcement, government officials, or other third parties if compelled to do so by a subpoena, court order or similar legal procedure, when it is necessary to do so to comply with law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the Divvy User Agreement, or as otherwise required by law.
  • Third-party service providers who assist us in providing services to you or who provide fraud detection or similar services on our behalf.
  • Service providers under contract who help with parts of our business operations (for example, fraud prevention, payment processing, or technology services); Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
  • Other third parties with your consent or at your direction to do so.

Except as permitted by law, Vermont is an opt-in state and we cannot share consumer information with third parties without permission from the consumer.

Bill Pay privacy

This Privacy Policy describes how MVB Bank, Inc. (“Bank”) uses and discloses information about the users of the bill payment service (“Service”) or software that permits access to the Service (“Platform”). By using the Service you agree to these terms.

Additionally, except as prohibited by law, you authorize Bank and Divvy to share information about you with each other without limitation, including information regarding your use of the Services, your activity on the Platform, transactions involving your authorized bank account, and information about you relating to or arising from other Divvy branded products. 

Bank and Divvy may use such information shared with the other for any lawful purpose. Without limiting the foregoing, such sharing and use may include:

  • Sharing your information relating to the Service, including any application or sign up process for the Service, to facilitate opening or managing another Divvy branded product
  • Sharing your information relating to another Divvy branded product, including the application or sign up process for such product, to facilitate your access to the Service under this agreement or managing the Service
  • Sharing information regarding you in connection with the Service, the Platform, and/or other Divvy branded products to detect, prevent, or investigate fraud or illegal conduct and to manage other risks
  • Sharing information to facilitate transactions and services that you request
  • Responding to governmental inquiries and legal process
  • Any other lawful business purposes of Bank or Divvy

How you can access or change your personal information

You can review and update your personal information in your account settings at any time by logging into your account.

Links to other sites

The website application and mobile application may contain links to other sites. Divvy does not control the information collection of sites that can be reached through links from our products. We encourage our users to be aware when they are leaving the applications and to read the privacy statements of any site that collects personally identifiable information.

Changes to our Privacy Policy

Divvy is always improving. As the Divvy service evolves, we may occasionally update this privacy policy. If we modify this privacy policy, we will post the revised privacy policy to the website, and we will also revise the “last updated date” stated above. If we make material changes in the way we use personal information, we will notify you by posting an announcement on our service or by sending you an email. It is your responsibility to periodically review this privacy policy; users are bound by any changes to the privacy policy by using the service after such changes have been first posted.