Privacy Policy.
Divergent Wealth Pty Ltd (ABN 20 659 485 337) (Divergent Wealth, we, us or our) is a Corporate Authorised Representative (CAR No. 1297163) of Lifespan Financial Planning Pty Ltd (ABN 23 065 921 735, AFSL 229892) (Lifespan).
Angelo Baronessa is an Authorised Representative (AR No. 1270561) of Lifespan.
We take privacy seriously. This policy explains how we collect, hold, use and disclose personal information through our practice, our website and the technology we use to deliver and support our services. It is designed to be read with Lifespan’s Privacy Policy and its Overseas Recipient Location Register, which apply to the licensed financial services and compliance activities performed through Lifespan.
Lifespan Privacy Policy (website)
Lifespan Overseas Recipient Location Register (PDF)
Important: If there is an inconsistency between this policy and Lifespan’s policy for licensed financial services, advice records, compliance, monitoring or supervision, Lifespan’s policy applies to that extent.
1. The information we collect.
The information we collect depends on how you interact with us and the services we provide. It can include:
identity and contact details, including your name, address, phone number, email address, date of birth and identification documents;
financial, taxation, employment, business, superannuation, insurance, investment, estate-planning and cash-flow information;
information about your goals, objectives, family circumstances, risk profile and preferences;
government identifiers where reasonably required or authorised, including tax file number, Medicare, Centrelink and superannuation details;
sensitive information, such as health information needed for insurance, or other information you choose to provide where relevant to our services;
correspondence, documents, call or consultation notes, records of instructions, identity-verification material and information received from professional advisers or product providers with authority;
website, booking and digital-interaction information, such as IP address, browser, device, pages viewed, session information, cookie identifiers, referral source and form submissions; and
information about a person connected with you, such as a spouse, partner, beneficiary, director, trustee or attorney. If you provide another person’s information, please tell them about this policy.
2. How we collect information.
We collect information directly from you and, where appropriate, from people or organisations you authorise. This may occur through our website, contact forms, newsletter sign-up, Microsoft Bookings, Marloo, consultations, emails, phone calls, video calls, client portal, secure document-sharing areas, fact-finds, digital forms and paper documents.
With your authority or where permitted or required by law, we may also collect information from Lifespan, accountants, lawyers, brokers, employers, insurers, superannuation funds, investment platforms, product issuers, government agencies, referees and publicly available sources. If you do not provide information we reasonably need, we may be unable to provide, or may be limited in providing, our services or advice.
We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
3. Why we collect, hold, use and disclose information.
We use personal information only for purposes reasonably connected with our services or where otherwise permitted or required by law. This includes to:
respond to enquiries, arrange consultations and provide requested services;
understand your circumstances, prepare, implement and review advice or other agreed services;
verify identity, meet legal and regulatory obligations, prevent fraud and manage security risks;
communicate with you and, where you authorise it, your professional advisers, family members, product providers and other service providers;
maintain records, meet audit, supervision, complaints, dispute-resolution and reporting obligations;
operate, improve, secure and troubleshoot our website, client systems, communications and internal processes;
send service communications and, if permitted, relevant news, events or marketing. You can unsubscribe from marketing at any time; and
consider or complete a business restructure, sale or transfer, subject to appropriate confidentiality and legal requirements.
4. Who we may disclose information to.
Depending on the service, we may disclose personal information to Lifespan and its staff, contractors, compliance, audit and supervision personnel; financial product issuers and administrators; investment platforms and custodians; insurers and underwriting service providers; accountants, lawyers, brokers and other professional advisers you authorise; government, regulatory, dispute-resolution or law-enforcement bodies where required or permitted by law; and technology, document-management, communications, booking, analytics, security and professional service providers who support our business.
We do not sell personal information. We do not disclose it to unrelated third parties for their own direct-marketing purposes without your consent.
5. Technology platforms and service providers.
We use service providers to run our practice and website. The category of information processed depends on the service and your interaction with us. Our current technology environment may include the following providers and services:
Microsoft 365, including Outlook, Teams, SharePoint, OneDrive, Forms, Bookings, Lists and Power Automate
Email, consultations, client collaboration, document storage, forms, bookings, workflows and task administration. Contact details, correspondence, forms, documents, booking details, collaboration records and service information.
Microsoft Copilot
Assisting authorised staff to search, summarise, draft or organise work within our Microsoft 365 environment. prompts, outputs and Microsoft 365 content that the authorised user is permitted to access.
ChatGPT Business or other approved AI tools
Limited business support, drafting, analysis or workflow assistance, subject to our internal controls. Only the information staff enter or attach. We do not intentionally use personal ChatGPT workspaces for client information.
Intelliflo and client portal services
Advice-practice management, client records, document sharing, portal access, workflows and reporting. Client identity, contact, financial, advice, document, instruction and portal data.
Squarespace and website hosting tools
Website hosting, website forms and site administration. Contact form submissions, website content and technical visitor information.
Microsoft Clarity
Website usage analysis and experience improvement, including interaction analytics where enabled. Technical and interaction data such as device, browser, pages viewed, clicks, scrolls and session information. Do not enter personal, financial or sensitive information into publicly visible website fields.
Google services, including Analytics, Tag Manager, Search Console and advertising tools where enabled
Website measurement, technical performance, search visibility and, if enabled, advertising measurement. Cookie and similar-technology identifiers, device/browser data, IP-derived information, referral source and website usage data.
Other financial-services and business providers
Platform administration, portfolio reporting, payments, compliance, cyber security, accounting, file transfer and specialist services. Only information reasonably required to provide the relevant service.
Our AI rule: We require staff to use approved business accounts and to follow internal procedures. They must not enter client information into an unapproved AI service, and they must not rely on AI output without appropriate human review. AI may assist administrative work; it does not replace professional judgment, verification, or our obligations to you.
6. Website analytics, cookies and similar technologies
Our website may use cookies, pixels, tags, local storage and similar technologies. They help the website function, remember preferences, measure traffic, understand how visitors use pages and improve the site. Some are set by our service providers, including Microsoft and Google, where their services are enabled.
You can control many cookies through your browser settings. Disabling cookies may affect parts of the website. Where consent controls are required or appropriate, we will provide a cookie banner or preference centre. Our website analytics are not intended to identify you personally, although technical information may be personal information under privacy law.
Do not send sensitive information through an ordinary website contact form. We will provide a more appropriate channel where we need detailed financial, identity or health information.
7. Overseas disclosure and cloud processing.
Some of our service providers may store, access or process information outside Australia. This can include cloud, technology, support, security and compliance services. Where we disclose personal information overseas, we take reasonable steps to use providers and contractual arrangements appropriate to the information and service involved.
Divergent Wealth has staff operating in the Philippines. For Lifespan-regulated activities, Lifespan’s Overseas Recipient Location Register identifies the countries in which Lifespan may disclose personal information. It currently lists Argentina, Brazil, Chile, Colombia, Ecuador, France, India, Paraguay, Poland, Sri Lanka, the Philippines and Uruguay. Technology providers may also process information in other locations depending on their service terms, configuration and support arrangements.
8. Security, retention and destruction.
We take reasonable steps to protect information from misuse, interference, loss, unauthorised access, modification and disclosure. Measures may include access controls, multi-factor authentication, encryption offered by our providers, device and account security, staff training, monitoring, secure collaboration tools and incident-response procedures.
No method of transmission or storage is completely secure. You should use care when sending information electronically and contact us if you need a secure method for sending sensitive documents.
We retain information for as long as needed for the purposes described in this policy, to meet legal, regulatory, insurance, dispute-resolution and record-keeping obligations, and to resolve issues. When information is no longer required, we take reasonable steps to destroy it or de-identify it, unless we must retain it by law.
9. Access and correction.
You may request access to, or correction of, the personal information we hold about you. Please contact us using the details below. We will respond within a reasonable period and may need to verify your identity. In some circumstances, the law permits or requires us to refuse access or limit the form of access. If that occurs, we will explain why, where we can.
10. Marketing and communications.
We may send you service messages that are necessary to manage your relationship with us. With your consent where required, or otherwise as permitted by law, we may also send you information about our services, events, research and resources. You can unsubscribe from marketing using the link in a message or by contacting us. Unsubscribing will not stop important service, regulatory or account communications.
11. Privacy concerns and complaints.
If you have a question, concern or complaint about how we handle personal information, please contact us first. We will acknowledge your complaint and aim to resolve it within 30 calendar days. If we need longer, we will tell you why and keep you updated.
If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC): oaic.gov.au | 1300 363 992.
12. Contact us and changes to this policy.
Privacy contact: Angelo Baronessa | hello@divergentwealth.com.au | 0480 039 283 | Level 26, 360 Collins Street, Melbourne VIC 3000.
Last reviewed: 28 August 2026.
This policy should be reviewed at least annually, and sooner if contact details, reporting links, examples, or regulatory obligations change.