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⚠ This document contains unfilled placeholders (e.g. [YOUR COMPANY NAME], [ABN]). It is a working template and must be completed before use with customers.

Privacy Policy

Capturio Last updated: [DATE]

This Privacy Policy explains how [YOUR COMPANY NAME] (ABN: [YOUR ABN]) ("we", "us", "our") manages personal information when you use Capturio ("Service"). It has been prepared in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

We are committed to protecting the privacy of individuals whose personal information is processed through our Service.


1. About us and this policy

Our details: [YOUR COMPANY NAME] ABN: [YOUR ABN] Address: [YOUR ADDRESS] Privacy contact: privacy@[YOUR-DOMAIN]

This policy covers:

For the purpose of the Privacy Act 1988 (Cth), we are an APP entity and this document is our APP Privacy Policy as required by Australian Privacy Principle 1.4.


2. What personal information we collect

2.1 Account information

When you register or use our Service, we collect:

We do not collect sensitive information (as defined in the Privacy Act) about our customers or their team members in the ordinary course of business.

2.2 Document data (processed, not stored)

When you upload an invoice or receipt for OCR processing, the document image may contain personal information about third parties, including:

We do not store uploaded document images. Images are transmitted to our AI processing provider (Anthropic, USA — see section 5) and deleted after extraction is complete. The extracted structured data is returned to you.

The personal information within documents is collected and processed by us on your behalf. You, as the business uploading the documents, are responsible for ensuring you have a lawful basis to upload and process that personal information.

2.3 Usage and technical data

We collect technical data including:

This data helps us operate, secure, and improve the Service.

2.4 Cookies

We use only essential session cookies required for authentication. We do not use advertising or tracking cookies, and we do not use third-party analytics services.


3. How we collect personal information

We collect personal information:

We collect personal information only by lawful and fair means. We will not collect personal information by unreasonably intrusive means.


4. How we use personal information

We use personal information only for the purposes for which it was collected or for directly related purposes:

Purpose Information used
Providing the OCR extraction service Document data (processed, not retained)
Managing your team account Account data
Billing and invoicing Billing contact details
Security monitoring and fraud prevention Usage and technical data
Responding to support requests Account data, usage data
Complying with legal obligations As required
Improving the Service (aggregated, de-identified only) Usage patterns

We do not:


5. Disclosure of personal information — including overseas disclosure

5.1 Overseas disclosure (APP 8)

We disclose personal information to overseas recipients in order to provide the Service. Under APP 8 of the Australian Privacy Principles, we are required to inform you of this.

Anthropic PBC (United States)

Document images you upload are transmitted to Anthropic PBC, located in the United States, for AI processing. Anthropic is our AI model provider. This transmission is necessary to provide the OCR extraction service.

Before making this disclosure, we have taken reasonable steps to ensure Anthropic does not breach the Australian Privacy Principles in relation to that information, including by:

You consent to this overseas disclosure by using the Service. If you do not consent, you should not upload documents containing personal information.

Fly.io, Inc. (United States)

Our servers and database are hosted by Fly.io, Inc. in [REGION]. Your account data and audit logs are stored on Fly.io infrastructure. We have entered into data processing terms with Fly.io.

[PAYMENT PROCESSOR] ([COUNTRY])

Billing information is processed by [PAYMENT PROCESSOR]. We share your billing email and plan details for payment processing purposes only.

5.2 No other overseas disclosure

We do not disclose personal information to any other overseas recipients.

5.3 Domestic disclosure

We do not sell, rent, or trade personal information with any domestic third parties. We may disclose personal information to professional advisers (lawyers, accountants) bound by confidentiality, or to law enforcement where required by law.


6. Data storage and security (APP 11)

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification, or disclosure. Our security measures include:

When personal information is no longer needed for the purpose for which it was collected, and we are not required by law to retain it, we will take reasonable steps to destroy or de-identify it.


7. Data retention

Data type Retention period
Uploaded document images Deleted immediately after extraction
Extracted JSON data 90 days, then permanently deleted
Audit logs 90 days, then permanently deleted
Account data Duration of subscription + 30 days
Billing records 7 years (tax law requirement)
Webhook delivery logs 90 days

8. Your rights under the Australian Privacy Principles

8.1 Access to your personal information (APP 12)

You have the right to request access to the personal information we hold about you. To make a request, contact privacy@[YOUR-DOMAIN]. We will respond within 30 days. We will not charge for access requests.

In limited circumstances, we may refuse access — for example, if providing access would unreasonably impact the privacy of another individual, or if the information is subject to legal professional privilege. If we refuse access, we will explain why in writing.

8.2 Correction of your personal information (APP 13)

If you believe personal information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, you may request that we correct it. We will respond within 30 days.

8.3 Anonymity and pseudonymity (APP 2)

Where practicable, you may interact with us anonymously or using a pseudonym. However, we require identifying information to create an account and use the Service.


9. Notifiable Data Breaches (NDB scheme)

We are subject to the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988 (Cth). If we have reasonable grounds to believe an eligible data breach has occurred (i.e. unauthorised access, disclosure, or loss of personal information that is likely to result in serious harm), we will:

  1. Notify you as soon as practicable
  2. Notify the Office of the Australian Information Commissioner (OAIC) as soon as practicable
  3. Include in the notification: the nature of the breach, the type of information involved, and the steps we have taken or propose to take

10. Complaints (APP 1.4)

If you have a complaint about how we have handled your personal information, please contact us first:

Privacy complaint contact: privacy@[YOUR-DOMAIN] Response timeframe: We will acknowledge your complaint within 5 business days and respond substantively within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):


11. Children

The Service is for business use only. We do not knowingly collect personal information from individuals under 18. If you believe we have inadvertently collected such information, please contact us immediately.


12. Changes to this policy

We will notify you of material changes to this Privacy Policy by email at least 14 days before they take effect. The current version is always available at [LINK]. We will also update the "Last updated" date at the top of this document.


Contact us

For privacy enquiries, access requests, or complaints:

[YOUR COMPANY NAME] ABN: [YOUR ABN] Email: privacy@[YOUR-DOMAIN] Address: [YOUR ADDRESS]

This Privacy Policy was prepared in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. Last updated: [DATE].