Last Updated: 19 July 2025
Welcome to www.diwalco.com (the "Platform"), operated by Diwalco ("we," "us," or "our"). We are committed to protecting your privacy and handling your personal information with care and respect, in accordance with applicable privacy laws, including the New Zealand Privacy Act 2020 (and its Information Privacy Principles - IPPs) and the Australian Privacy Act 1988 (and the Australian Privacy Principles - APPs).
This Privacy Policy explains how we collect, hold, use, disclose, and safeguard your personal information when you use our Platform. It also outlines your rights regarding your personal information.
Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Platform. By providing your personal information to us, you consent to our collection, holding, use, and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us.
1. Information We Collect ("Personal Information")
Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable. We collect personal information that is reasonably necessary for our functions and activities. The types of personal information we may collect include:
Personal Identifiers: Your name, username.
Contact Information: Email address, phone number (if provided), postal address (if provided).
Location Data: General location (e.g., city, country) you provide, and potentially IP address-derived location.
Technical Information: IP address, browser type, operating system, access times, pages viewed, and information about the device or network you use to access the Platform.
Interaction Data: Records of your interactions with us (e.g., customer service inquiries, feedback), and interactions within the Platform (e.g., connections made, content posted, messages, subject to user privacy settings).
Family and Relationship Information: Information you provide about yourself and other individuals (living or deceased) to build your family tree, including names, dates of birth and death, places of birth and death, relationships, photos, stories, and other biographical details. You are responsible for ensuring you have any necessary permissions or have made reasonable efforts to notify (if applicable) living individuals before sharing their personal information, especially if they are in New Zealand or Australia.
Photos and Media: While you may upload photos or other media, we do not perform facial recognition analysis or extract biometric data from these uploads unless a specific feature requiring this is offered and you provide explicit consent for that feature.
Billing or Purchase Information: If you make any purchases through the Platform in the future, we will collect information necessary to process your payment, such as your credit card details and billing address.
Inferred or Derived Data: We may also collect inferred or derived data based on your use of the Platform (e.g., inferred relationships or likely relatives based on information inputted or user interactions).
2. How We Use Your Information
We collect, hold, use, and disclose your personal information for the following purposes (Primary Purposes):
To Provide and Operate the Platform:
- To create and manage your account.
- To enable you to build, populate, and manage your family tree.
- To help you discover and connect with relatives and other users who share common ancestry or interests.
- To facilitate social interaction and communication between users, as permitted by your settings.
- To provide customer support and respond to your inquiries.
3. How We May Share Your Information
We may disclose your personal information in the following circumstances:
With Other Users: Certain information you provide, particularly for your family tree and social profile, may be visible to other users of the Platform according to your privacy settings and the nature of the Platform's features.
With Service Providers: We may disclose your information to third-party vendors, consultants, and other service providers who perform services on our behalf.
For Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
4. Your Choices and Control
Providing Information: Providing most personal information is optional. However, if you choose not to enter certain types of information, we may be unable to provide you with the family tree building capabilities and other associated services.
Account Information: You may review, update, or modify your account information at any time by logging into your account settings.
Communication Preferences: You can opt-out of promotional communications as described in Section 2.
5. Data Security
We take reasonable steps to protect your personal information from misuse, interference, loss, and from unauthorized access, modification, or disclosure. These measures include data encryption at rest and in transit where applicable and appropriate, access controls, and other administrative, technical, and physical safeguards.
6. Data Retention
We will retain your personal information only for as long as necessary for the purposes for which it was collected, or as required by law, or for other legitimate business purposes.
7. Your Rights
You have the right to:
- Request access to the personal information we hold about you.
- Request correction of your personal information if you believe it is inaccurate, out of date, incomplete, irrelevant, or misleading.
- Request deletion of your account and associated personal data.
- Request a copy of your personal data in a common format where legally required.
8. Children's Privacy
Our Platform is generally not intended for individuals under the age of 16. We do not knowingly collect personal information directly from children below this age without verifiable parental or guardian consent where required.
9. International Data Transfers
Your personal information may be transferred to, stored, and processed in countries other than your own. These countries may have data protection laws that are different from those in your jurisdiction.
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.
11. Contact Us and Complaints
If you have any questions, concerns, or complaints about this Privacy Policy, please contact us at:
Diwalco
Email: hello@diwalco.com
Mailing Address: Diwalco Limited, 540 Cashel Street, Linwood, Christchurch, 8011, New Zealand.
12. Automated Decision-Making and Profiling
We may use algorithms to analyze information for automated suggestions. Where automated decisions produce legal or similarly significant effects on you, you may have the right to obtain human intervention, express your point of view, and contest the decision.