1. About This Policy

Separately ("we", "us", "our") operates the website at separately.ai and provides a divorce asset division estimation tool for Australian users. This Privacy Policy explains how we collect, use, disclose, and protect your personal information in accordance with the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

By using our service, you consent to the collection and use of your information as described in this policy. If you do not agree, please do not use our service.

2. Information We Collect

2.1 Information You Provide

• Account details: username, email address, and password (hashed)
• Assessment data: financial information about assets, debts, superannuation, income, and property you enter into the form wizard
• Relationship details: names, dates of birth, relationship dates, and children's information as entered for your assessment
• Health information: any health or disability details you provide as part of your assessment (e.g. capacity to earn, future needs)
• Sensitive information: information about your family circumstances, domestic contributions, and other matters relevant to property settlement under the Family Law Act 1975
• Payment information: processed securely by Stripe. We do not store card numbers

2.2 Information Collected Automatically

• Device and browser information (user agent, screen resolution)
• IP address
• Usage data via Google Analytics (pages visited, session duration)
• Cookies for session management and authentication

2.3 Information from Third Parties

• Google OAuth: if you sign in with Google, we receive your name, email address, and profile picture from Google

3. How We Use Your Information

We use your personal information to:

• Provide, operate, and maintain the Separately service
• Generate your asset division estimation reports
• Analyse your assessment data using AI to cross-validate algorithmic calculations and provide additional insights (see Section 10 below)
• Process payments via Stripe
• Authenticate your identity and manage your account
• Communicate with you about your account or service updates
• Improve our service through aggregated, de-identified analytics
• Comply with legal obligations

We will not use your personal information for purposes other than those described above without your consent.

4. How We Store and Protect Your Information

• Your data is stored in MongoDB databases hosted by MongoDB Atlas with encryption at rest and in transit
• Passwords are hashed using Argon2id, an industry-leading algorithm
• Session cookies are httpOnly and secure
• Payment data is handled by Stripe and is PCI-DSS compliant
• Access to production systems is restricted to authorised personnel

While we take reasonable steps to protect your information, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security.

5. Disclosure of Your Information

We may share your personal information with:

• Stripe: for payment processing (United States)
• Google: if you use Google OAuth sign-in (United States)
• Anthropic (Claude): AI analysis provider based in the United States. Before your data is sent, all names are replaced with pseudonyms (e.g. "Party A", "Party B") and dates of birth are replaced with ages. No email addresses are transmitted. See Section 10 for details.
• OpenAI (GPT): AI analysis provider based in the United States. The same de-identification measures apply as described above. See Section 10 for details.
• Vercel: application hosting (United States)
• MongoDB Atlas: database hosting (Australia / United States)
• Law enforcement: if required by law or to protect our legal rights

We do not sell your personal information to third parties.

6. Cookies

We use the following types of cookies:

• Essential cookies: session authentication (required for the service to function)
• Analytics cookies: Google Analytics to understand how users interact with our service

You can control cookies through your browser settings, but disabling essential cookies will prevent you from using the service.

7. Your Rights Under the Australian Privacy Act

You have the right to:

• Access the personal information we hold about you
• Correct inaccurate or out-of-date information
• Request deletion of your account and associated data
• Withdraw consent for data processing at any time, including AI processing consent
• Export your data from your account settings page
• Complain to the Office of the Australian Information Commissioner (OAIC) if you believe your privacy has been breached

To exercise any of these rights, please contact us at the details below. You can also delete your account directly from your account settings page.

8. Data Retention

We retain your personal information according to the following schedule:

• AI analysis results: automatically deleted 1 year after creation
• Inactive assessments: assessments with no activity for 2 years may be archived or deleted
• Account data: retained until you delete your account. When you delete your account, we delete your user record and all associated assessments, assets, debts, calculations, and AI analysis results.
• Transaction records: retained for 7 years as required by Australian tax law

We may retain de-identified, aggregated data for analytics purposes.

9. Cross-Border Data Transfers

Your data may be processed in countries outside Australia by the following service providers:

• Anthropic (Claude AI): United States
• OpenAI (GPT): United States
• Vercel: United States (application hosting)
• MongoDB Atlas: Australia and United States (database hosting)
• Stripe: United States (payment processing)
• Google: United States (OAuth authentication, analytics)

In accordance with APP 8, before disclosing personal information to overseas recipients, we take reasonable steps to ensure these providers comply with the APPs or are subject to substantially similar privacy protections. For AI providers specifically, we de-identify your data before transmission (see Section 10).

10. Automated Decision-Making and AI Analysis

Separately uses artificial intelligence to supplement its algorithmic scoring of property division assessments. This section explains how AI is used and your rights in relation to it.

10.1 How AI Is Used

When you generate a report, your assessment data may be analysed by an AI system (currently Anthropic Claude or OpenAI GPT, depending on configuration) to:

• Cross-validate the algorithmic contribution scores
• Identify potential inconsistencies in the data
• Provide a qualitative narrative explanation of the assessment

10.2 De-identification Before AI Processing

Before any data is sent to an AI provider, we apply the following de-identification measures:

• Your name and your partner's name are replaced with "Party A" and "Party B"
• Children's names are replaced with "Child 1", "Child 2", etc.
• Dates of birth are replaced with ages calculated at the date of separation
• Email addresses are removed entirely

Financial amounts, relationship dates, health descriptions, and contribution details are retained because the AI requires this information to perform its analysis. However, without names or other direct identifiers, this data cannot readily be linked back to you by the AI provider.

10.3 AI Does Not Make Final Decisions

The AI analysis is advisory only. It supplements, but does not replace, the algorithmic scoring system. The final report combines both algorithmic and AI outputs, and all results should be reviewed by a qualified family lawyer before being relied upon.

10.4 Your Rights Regarding AI Processing

• Consent: AI processing of your data requires your explicit consent, which you can grant or withdraw at any time from your account settings
• Withdraw consent: If you withdraw AI processing consent, your reports will be generated using algorithmic scoring only
• Human review: You may request a human review of any AI-generated analysis by contacting privacy@separately.ai

11. Children's Privacy

Our service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new policy on this page, updating the version number and "Last updated" date, and prompting you to review and accept the updated policy when you next use the service.

13. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us at:

Separately
Email: privacy@separately.ai

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.