Effective Date: September 2, 2026
Last Updated: September 2, 2026
At Divergent POS ("Divergent POS," "we," "us," or "our"), we respect your privacy and are committed to protecting the personal information entrusted to us.
This Privacy Policy explains how we collect, use, store, disclose, and protect personal information when you visit our website, use our POS software and services, communicate with us, request a demo, purchase our products or services, or otherwise interact with Divergent POS.
This Privacy Policy is intended to comply with applicable Philippine privacy laws, including Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), and its implementing rules and regulations.
We process personal information in accordance with the principles of transparency, legitimate purpose, and proportionality.
Divergent POS is a provider of point-of-sale and business management solutions for businesses in the Philippines.
For purposes of applicable data privacy laws, Divergent POS may act as a Personal Information Controller (PIC) when we determine the purposes and means of processing personal information.
In certain circumstances, Divergent POS may act as a Personal Information Processor (PIP) when processing personal information on behalf of our business customers.
Company Legal Name: Divergent POS
Business Address: Unit 701-A, Pacifica One Center, 2178 Chino Roces Ave, Makati City, 1230 Metro Manila
Privacy Email: misha.ballesteros@divergentechphil.com
Data Protection Officer: [Insert DPO Name/Title]
DPO Email: [Insert DPO Email]
Depending on how you interact with Divergent POS, we may collect different categories of personal information.
When you contact us, request a quotation, request a demo, register for an account, purchase a service, or communicate with our team, we may collect information such as:
We only seek to collect information that is reasonably necessary for the relevant purpose.
When you use Divergent POS, the information processed may depend on how the POS is configured and how your business uses the system.
This may include:
The exact information processed will depend on the features enabled by the customer and the nature of the business.
When you visit our website or use our online services, we may automatically collect certain technical information, such as:
We use this information primarily to operate, maintain, secure, and improve our website and services.
We may collect personal information through:
Where required by law, we will provide appropriate privacy notices and obtain consent or rely on another lawful basis for processing.
The National Privacy Commission recognizes that consent is not the only possible lawful basis for processing; the Data Privacy Act also recognizes circumstances such as contractual necessity, legal obligations, protection of vital interests, and legitimate interests, subject to applicable requirements.
We may process personal information for legitimate and specified purposes, including:
We use information to:
We may use information to:
We may process information for:
We may process information to:
We may process and retain information where necessary to:
Where permitted by applicable law, we may use contact information to send:
Where consent is required, we will obtain appropriate consent. You may opt out of marketing communications at any time.
We process personal information only when permitted under applicable law.
Depending on the circumstances, our processing may be based on:
These are among the lawful processing criteria recognized under the Philippine Data Privacy Act.
When processing is based on consent, you may withdraw your consent subject to applicable legal and contractual limitations.
Divergent POS may process information on behalf of business customers who use our POS platform.
For example, a restaurant, retail store, grocery store, pharmacy, salon, or other business may enter customer information into its POS system.
In these circumstances, the business using Divergent POS may determine:
Where Divergent POS processes information on behalf of a business customer, we will process such information according to the customer's instructions and applicable data privacy requirements.
The business customer may therefore have its own privacy policy governing its collection and use of customer information.
We do not sell personal information as a business practice.
We may disclose personal information when reasonably necessary for legitimate purposes, including to:
We may engage third-party providers that help us operate our business, such as:
These providers may only process information as necessary to provide their services and subject to appropriate contractual or other safeguards.
We may disclose information when required or permitted by applicable law, regulation, court order, subpoena, or lawful government request.
Personal information may be processed or disclosed as part of a merger, acquisition, restructuring, financing, sale of assets, or similar corporate transaction, subject to applicable privacy requirements.
We may disclose information when you specifically request or authorize us to do so.
Where data sharing is subject to consent, we will provide the applicable information required by law, including the purpose and relevant recipients or categories of recipients. The Philippine privacy rules recognize specific requirements for private-sector data sharing.
Our website may use cookies and similar technologies to improve your browsing experience and understand how our website is used.
Cookies may be used for purposes such as:
You can configure your browser to reject or delete cookies. However, disabling certain cookies may affect some website functionality.
If we use cookies that require consent under applicable law, we will provide an appropriate consent mechanism.
We take reasonable organizational, physical, and technical measures designed to protect personal information against:
Depending on the nature of the information and services involved, safeguards may include:
The Data Privacy Act's implementing rules require appropriate organizational, physical, and technical security measures based on the nature, scope, context, purpose, and risks associated with processing.
However, no internet-connected system can be guaranteed to be completely secure.
We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, or as required by applicable laws, regulations, contracts, or legitimate business requirements.
Retention periods may depend on:
When personal information is no longer required, we will take reasonable steps to securely delete, anonymize, or dispose of it, subject to applicable retention requirements.
Divergent POS should insert its actual retention schedule here if one has been formally established.
Under applicable Philippine data privacy laws, data subjects have rights concerning their personal information.
These may include the right to:
You have the right to know whether your personal information is being processed and to receive information about how it is processed.
You may request access to personal information that we hold about you, subject to applicable limitations.
You may request correction of inaccurate or incomplete personal information.
You may object to certain processing of your personal information where permitted by law.
Where processing is based on consent, you may withdraw your consent, subject to applicable legal or contractual limitations.
In circumstances provided by law, you may request the deletion, blocking, or removal of personal information.
Where applicable, you may have the right to obtain your personal information in a structured and commonly used format or have it transmitted to another controller, subject to legal requirements.
You may lodge a complaint with the National Privacy Commission (NPC) if you believe that your personal information has been processed unlawfully or your privacy rights have been violated.
The Data Privacy Act and its implementing rules recognize these data subject rights, including the rights to be informed, access, correction, objection, and complaint.
To exercise your rights or raise a privacy concern, contact our Data Protection Officer or privacy team:
Data Protection Officer: [DPO Name/Title]
Email: [privacy@yourdomain.com]
Phone: [Phone Number]
Address: [Business Address]
When submitting a request, we may need to verify your identity to protect your information from unauthorized disclosure.
We will handle requests in accordance with applicable laws and regulations.
Our services are intended primarily for businesses and their authorized users.
We do not knowingly collect personal information directly from children for purposes unrelated to the services.
If you believe that a child has provided personal information to us without appropriate authorization, please contact us so that we can evaluate and take appropriate action.
Some of our service providers or technology infrastructure may be located outside the Philippines.
Where personal information is transferred, stored, or processed outside the Philippines, we will take reasonable steps to ensure that applicable privacy and security requirements are observed.
This may include contractual safeguards, security measures, and other appropriate protections.
Our website or services may contain links to third-party websites, applications, payment providers, or other services.
Divergent POS is not responsible for the privacy practices of third parties that operate independently from us.
We encourage you to review the privacy policies of third-party services before providing personal information to them.
Divergent POS maintains procedures for identifying, investigating, and responding to security incidents involving personal information.
If a personal data breach occurs, we will assess the incident and take appropriate measures in accordance with applicable law and regulatory requirements.
Where notification is legally required, affected data subjects and/or the National Privacy Commission will be notified within the applicable timeframe and in the manner required by law.
We may update this Privacy Policy from time to time to reflect:
When we make material changes, we may provide additional notice where appropriate.
The latest version will be posted on our website with the updated effective date.
We encourage you to review this Privacy Policy periodically.
If you have questions about this Privacy Policy, our privacy practices, or the handling of your personal information, please contact us.
Divergent POS
Legal Company Name: Divergent POS
Address: Unit 701-A, Pacifica One Center, 2178 Chino Roces Ave, Makati City, 1230 Metro Manila
Privacy Email: misha.ballesteros@divergentechphil.com
We are committed to handling privacy concerns responsibly and providing appropriate information about how personal data is processed.
This Privacy Policy is intended to be aligned with applicable Philippine data protection requirements, including:
For the official Philippine privacy framework, refer to the National Privacy Commission and the Data Privacy Act of 2012.
This Privacy Policy should be reviewed by Divergent POS's Data Protection Officer and/or qualified Philippine legal counsel before publication and implementation.
