Privacy Policy

Last Updated: Jan 2024


  1. We are diñeiro Pty Ltd ACN 646 413 087 (Provider, we, us and our). We are committed to respecting your privacy. This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Services and the choices you have associated with that data.



  1. The Application is the wealth management and finance application operated by us.


  1. The Website Is the website located at the domain operated by us.


  1. The Services are the Application and Website.

Personal Data

  1. Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

  1. Usage Data is data collected automatically and either generated through use of the Services or from the infrastructure underpinning the Services.


  1. Cookies are small files stored on your device (computer or mobile device). When you visit our website, we may collect information from you automatically through cookies or similar technology. For more information, visit:
  2. For more information about our cookies, please see our Cookie Policy (see heading below “CHANGES TO THIS DOCUMENT AND OUR OTHER DOCUMENTS” for link to policy).


  1. Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the way any personal information are, or are to be, processed.
  2. For this Privacy Policy, we are a Controller of your Personal Data.

Processors (or Service Providers)

  1. Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Controller.
  2. We may use the services of various Service Providers to process your data more effectively.

Data Subject (or User)

  1. Data Subject is any living individual who is using our Services and is the subject of Personal Data.

Information Collection and Use

  1. We collect several different types of information for various purposes to provide and improve our Services.

Australian Privacy Principles (APP)

  1. Reference to APP in this policy means the Australian Privacy Principles contained in Schedule 1 of the Privacy Act 1988 (Cth). These APPs govern the content of privacy policies and rights under Australian law. We take pride in our adherence to these Principles.


  1. We use your data to provide and improve the Services. By using the Services, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from:

Personal Data

  1. While using our Services, in particular when creating and registering your account, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
    • first name and last name;
    • email address;
    • telephone number;
    • address, state, province, postal code, city;
    • credit card information;
    • bank account details;
    • your device ID, device type, geo-location information, computer, and connection information;
    • Usage Data, (see below);
    • information provided you provide to us through customer surveys;
    • details of the Services we have provided to you or that you have enquired about, including any additional information necessary to deliver the Services and respond to your queries; and
    • any other information necessarily required in order to facilitate and improve your dealings with us and the Services.
  2. We may use your Personal Data to contact you with notifications, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by turning off notifications within the App or following the unsubscribe link and the instructions provided in any correspondence we send.

Anonymous Statistical Data

  1. When You use Our Services, We may create anonymous statistical data from Your data and usage of our Services, including through aggregation. For clarity, anonymous statistical data differs from personal data in that its disclosure does not permit an individual to be identified.

Usage Data

  1. We also collect information on how the Services are accessed and used ("Usage Data"). This Usage Data may include information such as the screens and interfaces within our Services that you visit, the time and date of your visit, the time spent on those interfaces, unique device identifiers and other diagnostic data.

Location Data

  1. We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide certain features within our Services, as well as to improve and customise the Services.
  2. You can enable or disable location services when you use our Services at any time by way of your device settings.
  3. You are not required to provide your location data when using the Services and can decline requests for location data. You may choose to either enter an address or postcode or simply view the locations on the map.

Tracking & Cookies Data

  1. We use cookies and similar tracking technologies to track the activity on the Services and we hold certain information.
  2. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyse our Services.
  3. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.
  4. Examples of cookies we might use are:
    • Session Cookies. We use Session Cookies to operate our Services.
    • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
    • Security Cookies. We use Security Cookies for security purposes.
  5. More information on cookies and which ones we use is set out in our cookie policy (see heading below “CHANGES TO THIS DOCUMENT AND OUR OTHER DOCUMENTS” for link to policy).

Children’s Privacy

  1. Our Services do not address anyone under the age of 18 ("Children").
  2. We do not knowingly collect personally identifiable information from anyone under the age of 18.
  3. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from our servers.
  4. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us using the contact information provided at the end of this Privacy Policy.


  1. We may collect data either directly from you, or from third parties, when you:
    • register for the Services;
    • interact with the Services;
    • communicate with us through correspondence, chats, email or otherwise share information with us;
    • engage in other related social applications, services or websites;
    • interact with our Services, content, advertisements and/or marketing material; and/or
    • invest in our business or enquire about our business.


  1. We use the collected data for various purposes:
    • To enable you to access and use our Services (on the grounds of fulfilment of our contract with you);
    • To operate, maintain, protect, improve and optimise our Services (on the grounds of fulfilment of our contract with you);
    • To notify you about changes to our Services (on the grounds of our legitimate interests in ensuring you are aware of any relevant changes);
    • To allow you to participate in interactive features of our Services when you choose to do so (on the grounds of your consent);
    • To provide or administer rewards, surveys, contests or other promotional activities or events;
    • To provide customer support (on the grounds of our legitimate interests in ensuring you receive the help you need when accessing our Services);
    • To gather analysis or valuable information so that we can improve our Services;
    • To monitor the usage of our Services;
    • To gather analysis or valuable information so that we can improve our Services (on the grounds of your consent);
    • To monitor the usage of our Services (on the grounds of your consent);
    • To detect, prevent and address technical issues (on the grounds of our legitimate interests in maintaining the functionality of the Services);
    • To provide you with notifications, financial information, and information about other services we offer unless you have opted not to receive such information (on the grounds of your consent). This correspondence may occur by Application notification, email, text message or another electronic format;
    • To comply with our legal obligations, resolve any issues our users may encounter, and enforce our agreements with third parties; and,
    • To consider your employment application.


Disclosure of Data

  1. We may disclose personal information for the purposes described in this privacy policy to:
    • Our employees and related bodies corporate;
    • Third party suppliers and service providers (including providers for the operation of the Services and/or our business;
    • Professional advisors, dealers and/or agents (where such disclosure is initiated by you);
    • Payment systems operators (for example, merchants receiving card payments);
    • Our existing or potential agents, business partners or partners;
    • Anyone to whom our assets or businesses (or any part of them) are transferred; specific third parties authorised by you to receive information held by us;
    • Other persons, including government agencies, regulatory bodies, and law enforcement agencies; and/or
    • As otherwise required or permitted by law.

Retention of Data

  1. Personal Data is retained only whilst you have an active subscription to the Application. All stored Personal Data is removed within seven (7) days upon the cancellation of your subscription.
  2. We may also retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
  3. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer periods.

Transfer of Data

  1. All data collected, including any backups, is stored solely in Australia:
    • by us; and
    • on third-party cloud-storage services.
  2. If you are located outside Australia and choose to provide information to us, please note that we transfer the data, including Personal Data, to Australia and process it there.
  3. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
  4. We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Collaboration with Third Parties

  1. We do not sell any Personal Data to third parties.
  2. If we are involved in a collaboration with a third party which involves collecting data and you subscribe to a mailing list associated with this collaboration, your Personal Data may be transferred to this third party so that they may send you marketing in accordance with the consent you provided. Your data will only be given to the core third party involved in the associated collaboration.

Business Transaction

  1. If we are involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

  1. Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

  1. We may disclose your Personal Data to third parties (including legal advisors) in the good faith belief that such action is necessary to:
    • To comply with a legal obligation;
    • To protect and defend our rights or property;
    • To prevent or investigate possible wrongdoing in connection with the Services;
    • To protect the personal safety of users of the Services or the public; or
    • To protect against legal liability.

Security of Data

  1. We may hold your personal information in either electronic or hard copy form. The security of your data is important, and we take reasonable steps to ensure your personal information is protected against misuse, interference, loss, unauthorised access, modification, or disclosure. These steps include various physical, administrative, personnel and technical measures.
  2. However, please bear in mind that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.


Service Providers

  1. We may employ third party companies and individuals to facilitate our Services ("Service Providers"), provide the Services on our behalf, perform services related to the Services or assist us in analysing how our Services are used. These third-party Service Providers include Amazon Web Services, Yodlee, CarsXE and Domain, who may have operations in or located in the United States.
  2. When you provide your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that any personal information disclosed is handled in accordance with Australian Privacy Law. However, we are committed to taking all reasonable steps to ensure that any personal information disclosed to overseas recipients is handled in a way that complies with the Australian Privacy Principles.

Analytics (General)

  1. We may use third-party Service Providers to monitor and analyse the use of our Services. We will only do so if we have your consent to use cookies in line with our cookie policy.

Analytics (Google)

  1. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
  2. You can opt-out of having made your activity on the Services available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
  3. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:


Under the APPs

  1. You have the right, under APP 1.4, to request access to the Personal Information we hold for you. You also have the right to request the correction of such information.


  1. You can submit complaints to us using the contact information provided below under the Contact Us heading.
  2. You can also lodge a complaint to the Office of the Information Commissioner if your privacy or data issue has not been resolved by us. For more information, please visit


  1. We may update this document from time to time. Any changes will be notified via posting the updated information on this page.
  2. We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update the "effective date" at the top of this document.
  3. You are advised to review this document periodically for any changes. Changes to this document are effective when they are posted on this page.
  4. Here is a list of our other policies and agreements:


  1. If you have any questions about this document, the data we hold, or you would like to exercise one of your rights regarding the data, please contact us.

Companydiñeiro Pty Ltd ACN 646 413 087
AttentionPrivacy and Data Protection Officer

Postage C/­ Macpherson Kelley Lawyers
L16, 324 Queen Street
Brisbane 4000


This Privacy Policy has been prepared with our legal team at Macpherson Kelley Lawyers.

© Diñeiro Pty Ltd ACN 646 413 087 2022