Privacy Policy

Version 2026-11 draft

DRAFT, needs owner and counsel review. Written against the Australian Privacy Principles; highlighted items are placeholders only the operator can fill. Not legal advice and not yet published as the operator's policy.

1. What we collect, and why

DataPurposeBasis
Work email address, organisation name, role in the workspaceCreate and secure your account and workspace; invite teammates; contact you about the ServicePerformance of the agreement
A trial request from a personal email address: that address and the organisation name you enteredDeciding whether to open a trial for an address that is not a work addressLegitimate interests (preventing misuse of free trials); kept until decided and for [90] days after
Sign-in events, IP address, browser detailsSecurity, rate limiting, abuse prevention, the workspace audit trailLegitimate interests (security)
Your workspace model (capabilities, systems, processes, business cases, uploaded workbooks)Providing the Service — this is your Customer Data; it is designed to hold organisational, not personal, informationPerformance of the agreement; you are the controller
Billing details (name, email, plan; card data is held by Stripe only)Subscriptions, invoices, taxPerformance of the agreement; legal obligation
Support correspondenceAnswering you and improving the ServiceLegitimate interests

We do not use analytics trackers or advertising cookies. The only cookie is a signed session cookie required to keep you signed in.

2. Where data is stored and who processes it

The Service runs on Cloudflare (Pages Functions and D1 database). The database is placed in Cloudflare's Oceania region; requests are handled at Cloudflare edge locations worldwide, so processing may take place outside Australia (APP 8). We do not guarantee Australian-only hosting. Our subprocessors are listed in the DPA: Cloudflare (hosting, storage), Stripe (payments), [Clerk (identity), once enabled]. If you need your data kept in your own country or network, use the offline edition, which holds none of your data on our side. Choosing a region per workspace, and a deployment in your own cloud account, are not built. Our data residency statement sets this out.

3. Optional AI features

AI assistance is off by default. When you enable it, text is sent to an endpoint you configure (your own provider or an in-network model); we show you the exact text first and redact identifying names by default. We do not train models on your data and we do not operate a shared default AI endpoint.

4. Retention

5. Your rights

You can access and export your workspace data at any time from the workspace page or the app. You can ask us for access to, correction of, or deletion of personal information we hold about you, or complain about our handling of it, at [privacy contact email]. We will respond within 30 days. If you are not satisfied you may complain to the Office of the Australian Information Commissioner (OAIC) or your local supervisory authority.

6. Security

Encryption in transit (TLS 1.2 or later, HSTS) and at rest (platform-managed, plus optional per-workspace encryption of models when the operator switches it on); workspace isolation enforced server-side; signed HttpOnly session cookies; optional single sign-on, provisioning and a second sign-in factor; least-privilege secrets management; an append-only audit trail and a security log per workspace; rate limiting and bot protection on sign-up. We hold no security certification and have had no independent penetration test; controls are documented in our security whitepaper. If a breach may affect your data we tell the workspace's named contact within [24] hours of becoming aware, and we notify the Office of the Australian Information Commissioner and affected individuals as the Notifiable Data Breaches scheme requires. Our incident response and breach policy sets out the steps.

7. Children

The Service is for organisations and is not directed at children under 16.

8. Changes and contact

We will notify workspace administrators of material changes at least 30 days in advance. Contact: [Operator legal name], [postal address], [privacy contact email].