Draft for review. This is a starting template, not legal advice. Have it reviewed by a qualified lawyer and complete the bracketed details before relying on it or publishing.

Privacy Policy

Last updated: [date]

This Privacy Policy explains how [Legal entity name] (ABN [ABN]) ("EquityRoom", "we", "us") collects, uses, stores and discloses your personal information when you use the EquityRoom platform and website (the "Service"). We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

Who we are

EquityRoom is a virtual data room and equity-management platform for founders raising capital. Our registered entity is [Legal entity name], located in [state/country].

Information we collect

How we use your information

AI processing and data residency

When you use our AI features, the relevant documents are processed to generate the analysis you request. Document embeddings are generated on our own infrastructure hosted in Australia (Sydney) and your document text is not sent to third parties to create those embeddings. Where a generative-AI provider is used to produce written analysis, only the context required for your request is sent, and it is not used to train third-party models. [Confirm exact AI data-handling wording with your lawyer.]

Where your data is stored

Application data and documents are hosted in Australian regions (compute and database in Sydney; document storage in an Australian region). We use the following sub-processors to deliver the Service:

[Confirm this sub-processor list and each provider's data location with your lawyer.]

How we protect your information

We apply industry-standard safeguards including encryption in transit and at rest, access controls and permissions, document watermarking, audit logging and macro stripping on uploads. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Disclosure

We do not sell your personal information. We disclose it only to the sub-processors above, where required by law, or with your consent. Documents you place in a data room are disclosed only to the people you invite and according to the permissions you set.

Your rights

Under the APPs you may request access to, or correction of, the personal information we hold about you. To make a request, contact us at hello@equityroom.xyz. If you have a concern about how we handle your information, you may also contact the Office of the Australian Information Commissioner (OAIC).

Cookies

We use essential cookies to keep you signed in and to operate the Service. [Add detail if you introduce analytics or non-essential cookies.]

Changes to this policy

We may update this policy from time to time. We will post the updated version here and revise the "last updated" date above.

Contact

[Legal entity name]hello@equityroom.xyz