Ask Charlie Technologies Pty Ltd is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and disclose personal information and business data in connection with the Ask Charlie application. This Privacy Policy is governed by and should be read in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

1. Information We Collect

We collect the following categories of information when you use the App:

• Account Information: Your name, email address, and business details provided during registration.
• Xero Business Data: Financial records, transaction data, invoices, and other business information retrieved via the Xero Connector as required to generate advisory outputs.
• Usage Data: Information about how you interact with the App, including pages accessed, features used, and time spent.
• Technical Data: Device identifiers, IP addresses, browser type, and operating system information for the purpose of maintaining and improving the App.

2. How We Collect Information

We collect information in the following ways:

• Directly from you, when you create an account or interact with the App.
• From Xero, via the Xero Connector, with your authorisation.
• Automatically, through standard web and application tracking technologies.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To service your requests within the App, including generating business advisory insights and recommendations.
• To improve and enhance our services, including the development of new features and the refinement of existing functionality.
• To compare anonymised and aggregated data against industry benchmarks and trends, and to surface industry-level insights within the App where critical mass thresholds are reached. Best endeavours will be made to ensure all such data is fully anonymised.
• To communicate with you regarding your account, the App, or matters related to our services.
• To comply with our legal obligations.

Your Data will not be used to train any AI model.

4. Security of Your Information

1. We take the security of Your Data seriously. All data in transit between your device and our systems, between our systems and Xero, and between our systems and the AI engine is transmitted using encrypted connections (TLS 1.2 or higher).
2. We implement appropriate technical and organisational measures to protect Your Data against unauthorised access, alteration, disclosure, or destruction.
3. No method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security, but we will use commercially reasonable efforts to maintain the security of Your Data.

5. Disclosure of Your Information

We may disclose your information in the following circumstances:

• To Google LLC, for the purpose of processing your data through the Google Gemini AI engine, in accordance with Google’s applicable terms and privacy policies.
• To Anthropic LLC, for the purpose of processing your data through the Anthropic Claude engine, in accordance with Anthropic’s applicable terms and privacy policies.
• To Xero Limited, as required to facilitate the Xero Connector integration.
• To service providers, where necessary to assist in the operation of the App (e.g. hosting, payment processing), subject to confidentiality obligations.
• As required by law, including to comply with legal process, court orders, or government requests.
• In anonymised and aggregated form, for the purpose of industry benchmarking and trend analysis, where best endeavours have been made to ensure no individual business is identifiable.

6. Data Retention

1. We retain Your Data for as long as your account is active and your Subscription is in force, and for such period thereafter as is necessary to service any outstanding requests or obligations.
2. Upon cancellation, termination of your Subscription, or disconnection of your Xero account, Your Data will be deleted within 180 days.
3. Anonymised and aggregated data, which is no longer linked to any identifiable individual or business, may be retained for longer periods for the purpose of improving our services and industry benchmarking.

7. Your Privacy Rights

Under the Australian Privacy Principles, you have the following rights in relation to your personal information held by us:

• Access: You may request access to the personal information we hold about you.
• Correction: You may request that we correct any personal information we hold that is inaccurate or outdated.
• Deletion: You may request the deletion of Your Data by cancelling your account. Deletion will occur within 180 days as described above.
• Disconnection: You may disconnect your Xero account at any time, which will cease the retrieval of new data.

To exercise any of these rights, please contact us at: support@askcharlie.app

8. Third-Party Services and Privacy Policies

The App integrates with third-party services whose own privacy policies govern how they handle your data. We encourage you to review the following:

• Google Privacy Policy: https://privacy.google.com/policy
• Xero Privacy Policy: https://www.xero.com/company/legal/privacy/
• Anthropic Privacy Policy: https://www.anthropic.com/legal/privacy

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by updating the “Last Updated” date on this document and, where practicable, by notifying you through the App or via email. Your continued use of the App after any changes constitutes your acceptance of the revised Privacy Policy.

10. Contact Us

If you have any questions or concerns about this Privacy Policy or how we handle your data, please contact us:

Ask Charlie Technologies Pty Ltd

Email: privacy@askcharlie.app

You may also lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at https://www.oaic.gov.au if you believe your privacy rights have been breached.