Privacy Policy
Your privacy matters to us
We collect only what's needed to run your assessment, pseudonymise data before AI processing, never sell your information, and let you delete everything at any time.
About This Policy
Separately is operated by Patuwi Pty Ltd ("we", "us", "our"). We operate the website at separately.ai and provide 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.
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
- Voice recordings (optional): if you use the "talk to fill your forms" voice feature, we capture short audio of what you say so it can be transcribed into your assessment. Transcription happens in Australia and the audio is discarded after transcription. See Section 10 for details
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
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)
- 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, anonymised analytics
- Comply with legal obligations
We will not use your personal information for purposes other than those described above without your consent.
How We Store and Protect Your Information
MongoDB Atlas with encryption at rest and in transit
Hashed using Argon2id, an industry-leading algorithm
httpOnly and secure cookies
Handled by Stripe, PCI-DSS compliant
While we take reasonable steps to protect your information, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security.
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, names are replaced with pseudonyms (e.g. "Party A", "Party B"), dates of birth are converted to ages, email addresses are removed, and free-text fields are scrubbed for any occurrences of known names. Financial figures, asset descriptions, and other assessment details are retained for analysis. See Section 10 for full details.
- OpenAI (GPT): AI analysis provider based in the United States. The same pseudonymisation measures apply as described above. See Section 10 for details.
- Deepgram: voice transcription and standard voice playback for the optional voice feature, processed in Australia (Sydney region). Your voice recordings are not sent overseas and are discarded after transcription.
- ElevenLabs: optional premium voice playback, based in the United States. Used only if you turn on the premium voice. We send only the de-identified text of the assistant's spoken reply. Your voice recordings, name, and other identifiers are never sent to ElevenLabs.
- 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.
Your Rights Under the Australian Privacy Act
You have the right to:
Access
View the personal information we hold about you
Correct
Fix inaccurate or out-of-date information
Delete
Request deletion of your account and data
Withdraw Consent
AI processing is integral to producing your report. To withdraw consent, delete your account at any time from your account settings, which stops all processing and removes your data.
Export
Request a copy of your data by contacting us
Complain
Lodge a complaint with the OAIC
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.
Data Retention
We retain your personal information according to the following schedule:
| Data Type | Retention |
|---|---|
| AI analysis results | Auto-deleted after 1 year |
| Inactive assessments | Archived/deleted after 2 years of inactivity |
| Account data | Until you delete your account |
| Transaction records | 7 years (Australian tax law) |
We may retain anonymised, aggregated data for analytics purposes.
Cross-Border Data Transfers
Your data may be processed in countries outside Australia by the following service providers:
| Provider | Purpose | Location |
|---|---|---|
| Anthropic (Claude) | AI analysis | United States |
| OpenAI (GPT) | AI analysis | United States |
| Vercel | Application hosting | United States |
| MongoDB Atlas | Database hosting | AU / US |
| Stripe | Payments | United States |
| OAuth, analytics | United States | |
| ElevenLabs | Premium voice (opt-in only) | United States |
Voice data stays in Australia
Voice transcription and our standard voice playback are handled by Deepgram in the Sydney (Australia) region, so your voice recordings are not transferred overseas. The only overseas part of the voice feature is the optional ElevenLabs premium voice, and even then we send only the de-identified text of the reply, never your audio.
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 pseudonymise your data before transmission -- replacing names with pseudonyms and scrubbing free-text fields -- though financial and assessment details are retained for analysis (see Section 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 Pseudonymisation Before AI Processing
Before any data is sent to an AI provider, we apply the following pseudonymisation 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
Free-text fields are scrubbed for any occurrences of known names
What is retained
The following information is sent to the AI provider because it is required for analysis:
- Financial amounts (incomes, asset values, debt balances)
- Asset and debt descriptions (e.g. property type, fund names)
- Work and career descriptions
- Relationship dates (start, separation)
- State or territory
- Health and care details
- Any other text you entered in free-form fields (after name scrubbing)
Limitations
This process is pseudonymisation, not full de-identification as defined under the Privacy Act 1988. While direct identifiers (names, DOBs, emails) are removed, the combination of financial details, location, relationship dates, and asset descriptions could theoretically allow re-identification, particularly in smaller communities. The AI provider does not attempt to re-identify users, and we use providers whose terms prohibit using input data for training or re-identification purposes.
10.3 Voice Intake (optional)
If you use the "talk to fill your forms" voice feature, the following applies in addition to the measures above:
- Transcription stays in Australia. Your speech is transcribed by Deepgram in the Sydney (Australia) region. The audio recording is used only to produce the transcript and is discarded afterwards; it is not stored long term and is not sent overseas.
- Standard voice playback is also in Australia. By default the assistant's spoken replies are generated by Deepgram in Australia.
- Premium voice is overseas and opt-in. If you turn on the optional premium voice, the de-identified text of the assistant's reply (not your audio, and after the name-scrubbing described above) is sent to ElevenLabs in the United States to generate the spoken audio. This is off unless you choose it.
10.4 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.
10.5 Your Rights Regarding AI Processing
- Consent: AI processing of your data requires your explicit consent, which you grant when you create an account and accept these terms
- Opt out: If you no longer wish for your data to be processed by AI, you can delete your account and all associated data at any time from your account settings. Once deleted, all assessment data, AI analysis results, and personal information are permanently removed
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.
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.
Contact Us
If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us at:
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.