Privacy Policy

Effective Date: 1 June 2025

Business Titan Pty Ltd (“Brokernote”, “we”, “us”, or “our”) is committed to protecting your privacy and handling your information responsibly. This Privacy Policy outlines how we collect, use, disclose, and protect your information when you visit or use our platform (“Platform”) and its features, which include our beta testing programs and our website hosted on the same domain.  

By using the Platform, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy.

This Privacy Policy is available at all times via our Platform at brokernote.com.au. 

1. What Information Do We Collect?

The types of information we collect depend on how you use our Platform. We may collect the following categories of information:

• Account Information:
  Details you provide when registering or using the Platform, such as your name, email address, employer, and other registration details.
• Data You Provide:
  All data you provide including information, documents, materials, and feedback you upload or input into the Platform. This may include business information and client or third-party data.
• Usage Information:
  Records of your interactions with the Platform, such as feature usage, access times, and support requests.
• Technical Data:
  Information about the devices and technology you use to access our Platform, including device type, browser, IP address, cookies, and log data.
• Feedback and Communications:
  Comments, suggestions, feedback, or other communications you submit to us.
  

2. Types of Information

The Privacy Act 1988 (Cth)  defines types of information, including Personal Information and Sensitive Information.

Personal Information (“Personal Information”) means information or an opinion about an identified individual or an individual who is reasonably identifiable: 

• whether the information or opinion is true or not; 
• whether the information or opinion is recorded in a material form or not. 

If the information does not disclose your identity or enable your identity to be ascertained, it will, in most cases, not be classified as Personal Information. 

Sensitive Information (“Sensitive Information”) is defined in the Privacy Act 1988 (Cth) as including information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

You must not enter or upload any Sensitive Information to the Platform,  when engaging in any feature of our Platform, or when otherwise interacting with Brokernote. If such information is inadvertently collected, we will handle this information in accordance with the Privacy Act 1988 (Cth).  

If you are beta testing Brokernote features on the Platform, additional details about your rights and obligations are set out in our Terms and Conditions for beta testers, that will be made available to you, and to which you must agree to before proceeding to beta testing. We encourage you to review these terms carefully. 

3. How We Collect Information

We may collect personal information from you:

• When you register for or use the Platform.
• When you input, upload, or transmit data into the Platform (including information about your clients or third parties).
• When you communicate with us or provide feedback.
• Automatically, through cookies, analytics tools, and other technical means when you use the Platform.

If you provide us with information about third parties (such as your clients), you must ensure that you have obtained all necessary consents and authorisations to do so.

4. Purposes for Information Collection

We collect, use, store, and process your information for purposes necessary to operate and improve the Platform, to comply with our legal obligations, and to protect our users and business. These purposes include:

• Providing and Operating the Platform:
  To enable and deliver the core features and functionalities of the Platform.
• Maintaining and Supporting the Platform:
  To operate, provide, and maintain the Platform and its features; to identify, investigate, and resolve technical issues, security incidents, or bugs; and to protect the security and integrity of the Platform.
• Improving the Platform:
  To analyse and enhance the Platform, including by using aggregated and de-identified data for product development, analytics, and the generation of anonymised reports or benchmarking insights for internal analysis, market research, or business intelligence.
• User Engagement and Communication:
  To communicate with you about updates, support, or changes to the Platform, and to invite you to participate in user research, surveys, feedback programs, or new feature trials and beta releases.
• Third-Party Processing:
  To facilitate data processing using trusted third-party service providers, subject to appropriate privacy and data protection safeguards.
• Business Operations and Compliance:
  To ensure business continuity, including backup, archival, and recovery of data; to manage data retention and deletion in accordance with this Privacy Policy and applicable law; to monitor, audit, and ensure compliance with company policies, contractual obligations, applicable laws, and industry standards.
• Legal, Regulatory, and Security Purposes:
  To comply with legal and regulatory requirements; to enforce our rights under our Terms or other agreements; and to protect the rights, property, or safety of Brokernote, our users, or third parties.

5. Disclosure of Personal Information

We may disclose your personal information in the following circumstances:

• To our employees, contractors, and trusted service providers (including cloud and AI model providers) who assist in delivering, maintaining, and supporting the Platform. All such parties are subject to confidentiality and data protection obligations that meet or exceed the requirements of the Privacy Act 1988 (Cth).
• If required by law, regulation, or legal process.
• In connection with a merger, acquisition, or sale of assets, with notice to you where practicable.
• In de-identified or aggregated form for analytics, research, product improvement, or business intelligence. 

We do not sell or trade your personal information.

6. Consent for Third-Party Data Provided to Us 

When you upload or otherwise provide us with personal or confidential information of third parties, including your clients, you warrant that you have obtained all necessary consents and authorisations to use and disclose such data in connection with the Platform and its intended purposes. We do not verify consents for third party data provided to us, but we may audit or remove data that is flagged as it may not have the valid consents. 

You agree that you will only upload or provide data which you are lawfully permitted to disclose to Brokernote under applicable Australian privacy laws.

7. Disclosure to Third-Party Service Providers

Some Platform features may require transmitting your data to trusted third-party service providers, including external AI model providers and cloud service providers for processing, storage, hosting, and other purposes. We do not let third-party AI models train on your data. 

We take reasonable steps to ensure that all third-party service providers are subject to contractual confidentiality and data protection obligations that are substantially equivalent to, compatible with, or otherwise appropriate for the requirements of the Privacy Act 1988 (Cth). These providers must implement appropriate security safeguards to protect the security and confidentiality of your data.

By using the Platform, you acknowledge and consent to the collection, use, storage, and processing of your data by Brokernote and its third-party service providers as described in this Privacy Policy. If you provide us with information about third parties (such as your clients), you warrant that you have obtained all necessary consents and authorisations for such processing.

8. International Data Transfers

In the course of providing our services, Brokernote may process, store, or otherwise transfer your data—including personal information—to jurisdictions outside Australia. This includes locations where our trusted AI and cloud service providers operate, as well as other third-party service providers engaged to support our business.

We take reasonable steps in accordance with Australian Privacy Principles 8 to ensure that any third-party service providers handling your data outside Australia are subject to contractual obligations requiring them to protect the security and confidentiality of your information, and to implement privacy and data protection measures that are substantially equivalent to, compatible with, or otherwise appropriate for the requirements of the Privacy Act 1988 (Cth). 

By using the Platform or otherwise interacting with Brokernote, you expressly consent to the transfer, processing, and storage of your data outside Australia, subject to these safeguards.

If you provide us with information about third parties (such as your clients), you warrant that you have obtained all necessary consents and authorisations for such international transfers, as required by Australian privacy laws.

9. Security and Data Retention

We store your Personal Information in a way that reasonably protects it from unauthorised access, misuse, modification or disclosure. When we no longer require your Personal Information for the purpose for which we obtained it, we will take reasonable steps to destroy and anonymise or de-identify it. 

10. Data Breach 

If we become aware of a data breach involving personal information that is likely to result in serious harm to individuals, and remedial action cannot prevent this risk, we will promptly notify:

• All individuals whose personal information is involved in the breach and who are at risk of serious harm; and
• The Office of the Australian Information Commissioner (OAIC),

as required by the Notifiable Data Breaches (NDB) scheme under the Privacy Act 1988 (Cth).

Our notification will include:

• Our identity and contact details; and 
• A description of the data breach; and
• The kinds of information involved; and
• Recommendations about the steps individuals should take in response to the breach.

We will make this notification within 72 hours after becoming aware of the eligible data breach.

11. Access, Correction, and User Rights

 The Australian Privacy Principles: 

• Permit you to obtain access to the Personal Information we hold about you in certain circumstances (Australian Privacy Principle 12); and 
• Allow you to correct inaccurate Personal Information subject to certain exceptions (Australian Privacy Principle 13).

Where you would like to obtain such access, please contact us in writing on the contact details set out at the bottom of this privacy policy.

You may also withdraw your consent or request that we delete your account or personal data by contacting us. 

12. Cookies and Analytics

We use cookies and similar technologies to operate the Platform, analyse usage, and improve user experience. You may disable cookies in your browser, but some features may not function properly.

13. Direct Marketing

We may use your contact details to send you updates or information about Brokernote, but you may opt out at any time by following the unsubscribe instructions in our communications.

14. Complaints and Contact Details

If you have a complaint concerning the manner in which we maintain the privacy of your Personal Information, please contact us using the contact details set out at the bottom of this policy. All complaints will be considered, and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.

15. Changes to This Policy

We may update this Privacy Policy from time to time. When we do so, we will update the effective date of this Privacy Policy. 

16. How To Contact Us About Privacy

If you have any queries, or if you seek access to your Personal Information, or if you have any questions, concerns, or complaints about our privacy practices, you can contact us through: scott@brokernote.com.