1. Who controls your data
The controller of personal data processed on 2Divide is DIGITO7 TECNOLOGIA LTDA, registered under company ID (CNPJ) 10.516.838/0001-96, with its head office in São Paulo / SP, Brazil. 2Divide is the brand under which the platform is offered.
2Divide organizes and records shared expenses. The platform does not receive, move or hold funds: payments happen directly between participants, using whatever method they choose.
2. Personal data we collect
2.1 Identification and contact data
Phone number with country and area code, the name or nickname you choose, profile picture when made available by the messaging channel, e-mail address when provided and preferred language.
2.2 Split data
Name and type of the split, participants, financially responsible people and linked dependants, recorded expenses, amounts, dates, currencies, categories, descriptions, splitting rules, balances, approvals, disputes and change history.
2.3 Payout details you provide
The details you choose to provide in order to receive money — for example an instant-payment key, account holder name, institution, branch and account number, a digital wallet identifier or another equivalent method in your country — plus uploaded proofs, dates, the declared payment method and receipt confirmations. Those details are passed only to the people who need to pay you in that split. We do not collect banking passwords, full card data or credentials for accessing financial institutions.
2.4 Content you upload
Text messages, voice notes, photos of receipts and proofs of payment, documents and notes you send to record or justify an operation. We accept images and PDFs on every tier and audio only in Premium splits. Video is not accepted: video files are rejected and are not stored.
2.5 Technical and usage data
Access logs, date and time of interactions, IP address, session identifiers for contextual links, device and browser type on the web dashboard, navigation events and aggregated usage metrics.
2.6 Purchase and billing data
The tier of each split, the period and participant capacity purchased, the history of purchases, extensions and upgrades, amount, currency, payment status and the minimum tax data required to issue an invoice. Payment method data is collected and processed directly by the contracted payment provider.
3. How we collect this data
We collect data directly from you: in the conversation with 2Divide's official number, in forms sent through the messaging channel, on web pages opened from a link in that conversation and on the optional web dashboard.
We also receive data from other participants in the same split. When someone records an expense and indicates who took part, your name or nickname and the amount assigned to you appear in that split. You are told this when you join by invitation.
4. What we use the data for
- Creating and managing your account and the splits you take part in.
- Recording expenses and calculating shares, balances and debt simplification.
- Sending operational notifications, payment reminders and confirmations.
- Making your payout details available to the participants who must pay you.
- Recording proofs, approvals, disputes and the closing of each obligation.
- Generating statements, closing reports and the exports you request.
- Providing support, investigating incidents and responding to requests.
- Preventing fraud, misuse and duplicate entries.
- Processing purchases of splits, extensions and upgrades, issuing invoices and complying with legal obligations.
- Measuring usage, fixing faults and improving the platform, preferably with aggregated data.
- Sending product news, where you have authorized it.
5. Legal bases for processing
We process personal data on the basis of: performance of a contract and preliminary procedures, where processing is necessary to operate the split you created or agreed to join; compliance with a legal or regulatory obligation, for keeping access logs and meeting tax requirements; the regular exercise of rights, in the event of a dispute; legitimate interest, for security, fraud prevention and product improvement, always with an impact assessment and balancing test; and consent, for marketing communications and optional processing, which you may withdraw at any time.
6. What the other participants see
2Divide exists to give a group transparency. Within a split, therefore, the other participants can see: the name or nickname you chose, the expenses you recorded, your share of each expense, your balance, the payments you reported and receipt confirmations.
Your payout details — such as an instant-payment key, bank details or a digital wallet identifier — are shown only to the participants who need to pay you in that split. Reminders are always sent in a private conversation: 2Divide does not expose debtors in group chats.
Your phone number is not shown to the other participants, unless you yourself provide it as a payout key.
7. Who we share data with
We share data only as far as necessary, with: cloud infrastructure and storage providers; messaging and communication platform providers; providers that process payment for platform purchases; usage analytics and support providers; providers of optical character recognition and language processing services, when you use those features; and public authorities, where there is a legal obligation, court order or request from a competent authority.
We do not sell personal data and do not license it for third-party advertising.
8. Use of a messaging platform
2Divide operates through the official WhatsApp messaging API. The messaging app is provided by a third party and has its own privacy policies, over which we have no control. Messages exchanged with 2Divide's official number are received and stored by us in order to operate the service.
2Divide does not read, access or monitor your conversations with other people. We only receive what is sent directly to our official number or to our web pages.
9. Use of artificial intelligence
In Premium splits, we may use automated processing to interpret the text, audio and images you send — for example, extracting the amount, merchant, date and line items from a receipt. That processing exists to fill in a record and cut down typing. On the Free and Standard tiers, attached files are only stored and displayed, with no automatic reading of their content.
No material expense is recorded or changed without your confirmation: extracted data is presented for review before it is saved. We do not make automated decisions producing legal effects on you without human intervention and without your confirmation.
10. International data transfers
Part of our infrastructure and some providers may be located outside Brazil. In those cases, the international transfer takes place on the grounds set out in the LGPD, with contractual clauses and security measures adequate to maintain the level of protection.
11. How long we keep data
We keep a split's data while it is active and, after it closes, for as long as necessary to consult the history, resolve disputes and comply with legal obligations. Access logs are kept for six months, as required by the Brazilian Internet Civil Framework. Tax and accounting data follows the periods set by applicable law.
Once the period ends, data is deleted or anonymized. Because a group is shared, deleting one participant's data may not erase the historical entries needed for the others' accountability — in those cases we apply anonymization where possible.
12. Information security
We adopt technical and administrative measures to protect personal data, including: encryption in transit and at rest, role-based access control and least-privilege principle, temporary contextual access links, audit logging of sensitive operations, data minimization, environment segregation and incident monitoring.
In the event of a security incident that may create relevant risk to data subjects, we will notify the Brazilian National Data Protection Authority (ANPD) and the affected data subjects within the periods and in the manner required by law.
13. Your rights as a data subject
You may request at any time: confirmation that processing exists; access to your data; correction of incomplete, inaccurate or outdated data; anonymization, blocking or deletion of unnecessary data or data processed unlawfully; portability; information about who we share data with; information about the possibility of refusing consent and its consequences; withdrawal of consent; and objection to processing based on legitimate interest.
To exercise your rights, write to privacidade@digito7.com. We will reply within the legal deadlines and may request additional information to confirm your identity before fulfilling the request.
14. Cookies and similar technologies
On the website and web dashboard we use necessary cookies, for authentication and session security, and measurement cookies, to understand navigation and improve the pages. You can manage non-essential cookies in the notice shown on first access and in your browser settings. Blocking necessary cookies may prevent the dashboard from working.
15. Children and teenagers
2Divide is intended for people aged 18 or over. A responsible adult may include minor dependants as participants in a split solely for splitting purposes, providing the minimum necessary information — as a rule, a name or nickname. We do not create accounts for or send charges to minors.
16. Changes to this policy
This policy may be updated to reflect changes in the product, in legislation or in our processes. The date of the last update is always at the top of this page. Where a change is relevant, we will give notice through the official messaging channel or by e-mail before it takes effect.
17. Contact and data protection officer
Questions, requests and complaints about privacy should be sent to the person in charge of personal data processing at DIGITO7 TECNOLOGIA LTDA:
You may also file a complaint with the Brazilian National Data Protection Authority (ANPD).