Last updated: [LAST UPDATED DATE]
1. Who we are
1.1 Valufield is online software for Australian property valuation firms. It is provided by [LEGAL ENTITY NAME] (ABN [ABN]) of [REGISTERED ADDRESS] ("Valufield", "we", "us").
1.2 This policy explains how we handle personal information under the Privacy Act 1988 (Cth) and the Australian Privacy Principles.
1.3 Contact our privacy officer at [PRIVACY EMAIL] or by post at the address above.
2. Our role and the firm's role
2.1 When we decide. We are responsible for information about people who visit our website, sign up, use Valufield as a firm's staff member, pay us or contact us.
2.2 When a firm decides. Each subscribing firm puts its own information into Valufield, such as its clients, emails, SMS, call recordings, portal, documents and valuation work. The firm decides what goes in, why and for how long. We handle it only to provide the service to the firm, under our agreement and the firm's settings.
2.3 If you are a firm's client or contact, including a client portal user, the firm's privacy policy applies to you. Please send requests and complaints to the firm first. We will help the firm respond.
2.4 Each firm is responsible for its own notices and consents, such as telling people that calls are recorded, having marketing consent, and explaining its use of AI.
3. What we collect
3.1 Account details. Name, work email, organisation name and web address, role and settings. Our sign-in provider stores passwords only in scrambled (hashed) form. If you sign in with Google or Microsoft, they give us your name, email and profile picture.
3.2 Billing details. Billing contact, address, ABN, plan, seats, invoices and payment history. Card details go directly to Stripe. We never see full card numbers.
3.3 Security records. IP address, browser type, sign-in times, active sessions, an audit log of important actions (such as role changes, exports and support sessions), and error reports that include the page address.
3.4 Phone number registration. If a firm turns on Australian phone numbers, Twilio requires business details, an identity document and proof of address for an authorised person. We pass these to Twilio for that purpose only.
3.5 Support. What you tell us when you contact us.
3.6 Information firms store in Valufield. Depending on the features a firm uses, this can include:
- (a) clients' and contacts' names, emails, phone numbers and addresses, and property and valuation details [VALUATION MODULE DATA];
- (b) notes, files, bookings, form submissions, quotes, invoices and payments;
- (c) emails from Gmail or Outlook mailboxes that staff connect (the previous 30 days when first connected, then new mail);
- (d) SMS, call details, recordings, voicemails, transcripts, AI summaries and call scores;
- (e) marketing lists, consent records (including the IP address and page where consent was given) and email open and click events;
- (f) client portal sign-ins and activity, including IP address; and
- (g) recordings of staff training sessions.
3.7 We do not ask for sensitive information, such as health information, but emails, notes and recordings may contain it. Firms should not store sensitive information they do not need.
3.8 You can browse our website anonymously, but not use the service, because we must know who can see a firm's data.
4. How we use it
4.1 We use personal information to provide, secure and support the service; verify sign-ins; bill subscriptions; send service messages such as receipts, trial reminders and security alerts; investigate misuse and faults; improve the service using usage statistics; and meet legal and tax duties.
4.2 We do not sell personal information. We do not use firm data, or anything sent to our AI features, to train AI models.
4.3 Our staff look at a firm's data only to answer a support request, keep the service secure or meet a legal duty. Support access uses a session that ends within 60 minutes and is recorded in the firm's audit log.
5. Where it is stored and who helps us
5.1 Our database, file storage and backups are hosted by Supabase in Amazon Web Services' Sydney region. Our application servers run on Vercel in Sydney.
5.2 Some providers handle personal information outside Australia, mainly in the United States. Our Sub-processor List at [SUBPROCESSOR LIST URL] names each one, what it does, where it operates and its terms. In summary:
- (a) Vercel (hosting): logs and cached pages in the United States and other countries;
- (b) Stripe (payments): Australia and the United States;
- (c) Resend (email): United States;
- (d) Anthropic (AI features): the United States and other countries where it runs its models;
- (e) Twilio (phone and SMS, if turned on): United States;
- (f) ElevenLabs (transcription and voice agents, if turned on): United States;
- (g) Cloudflare (bot protection on public forms): global; and
- (h) Google and Microsoft: only when a user connects a mailbox or calendar, or signs in with them.
5.3 Our contracts with these providers limit how they use the information.
5.4 Valufield's use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
6. AI features
6.1 AI features are optional and firms can turn most of them off.
- (a) Transcription. Call recordings go to ElevenLabs to produce a transcript.
- (b) Summaries, call notes and call scoring. The transcript and the firm's scoring criteria go to Anthropic's AI models.
- (c) Knowledge base answers. Your question and the most relevant passages from the firm's knowledge base go to Anthropic. If nothing relevant is found, nothing is sent.
- (d) Drafting and automations. Text a firm chooses to summarise, reply to or extract details from goes to Anthropic.
- (e) AI receptionist. An ElevenLabs voice agent answers calls when the firm is unavailable. It tells callers it is an AI assistant and that the call is recorded, takes their name, number and reason for calling, and creates a callback task.
- (f) Training simulator. Staff practise calls with an ElevenLabs voice agent. Sessions are recorded and scored.
6.2 What is not sent. Passwords, card details and connection tokens are never sent. Each request carries only the text that task needs, and AI providers cannot browse a firm's data. Our usage records keep counts and cost, not content.
6.3 Retention. Anthropic's commercial terms say it does not train on this content and deletes it within 30 days, with limited exceptions. We set ElevenLabs to keep receptionist and training conversations for 30 days.
6.4 Decisions. Valufield does not make decisions about people by automated means. AI outputs such as call scores help the firm's staff, who decide what to do. AI can be wrong, so outputs should be checked. A firm that uses call scores in decisions about its staff is responsible for that use.
7. Cookies and similar technology
7.1 The Valufield app uses only what it needs to work: sign-in cookies (names beginning "sb-", with a separate one for the client portal), a short-lived security cookie while a firm connects accounting software, and browser storage for your theme and whether you dismissed the "install app" prompt.
7.2 The app sets no analytics, advertising or tracking cookies and runs no third-party analytics.
7.3 Stripe runs on payment pages and may set fraud-prevention cookies. Cloudflare Turnstile checks public forms for bots and, Cloudflare says, uses no cookies.
7.4 Firms are responsible for open and click tracking in their marketing emails (on unless turned off) and for any analytics they add to their own landing pages.
7.5 Our marketing website: [MARKETING SITE COOKIES].
8. Marketing messages
8.1 We send you marketing email only with your consent, express or inferred as the Spam Act 2003 allows. Each one identifies us and has a working unsubscribe link. We act on unsubscribes within five working days.
8.2 Service messages, such as security alerts, trial reminders, invoices and failed payment notices, continue while you have an account.
8.3 Firms are responsible for consent to their own messages. Valufield adds the firm's details and an unsubscribe option to marketing emails and SMS, and applies opt-outs across that firm's campaigns.
9. Security
9.1 Our measures include database rules that keep each firm's data separate (tested for every table), encryption in transit and at rest with a second layer for connection tokens, optional two-step sign-in, file links that expire within five minutes, rate limits, audit logs, and limited, logged staff access.
9.2 No system is completely secure. If a data breach is likely to cause serious harm, we will notify the people affected and the Office of the Australian Information Commissioner (OAIC) under the Notifiable Data Breaches scheme. If a breach affects a firm's data, we will tell the firm promptly.
10. Retention and deletion
10.1 We keep a firm's data while its account is open, except that activity history is kept for the period the firm's plan allows, integration logs for 30 days, automation history for 180 days (the firm can change this), and files follow the firm's retention rules. Call recordings stay until the firm deletes them, and copies may remain in the firm's Twilio account until deleted there.
10.2 Deleting an organisation. The firm's owner can ask to delete the organisation in settings. The subscription then stops renewing, and the request can be cancelled for 30 days. After that we permanently remove the firm's data from our live database and file storage. We keep only a de-identified organisation record, a list of past members, and billing records we must keep for tax purposes (generally five years). Deleted data leaves our backups within [BACKUP RETENTION DAYS] days.
10.3 Cancelling. Cancelling a subscription does not delete data. The firm can export or delete it at any time.
10.4 Your login. One login can belong to several firms, so it is not removed when a firm is deleted. Email [PRIVACY EMAIL] to close it.
11. Access and correction
11.1 You can ask for the personal information we hold about you and ask us to correct it. You can update most details in your profile.
11.2 Email [PRIVACY EMAIL]. We will check your identity, respond within 30 days and not charge you. If we refuse, we will explain why and how to complain. If a firm put your information into Valufield, contact the firm (clause 2.3).
12. Complaints
12.1 Please contact our privacy officer first at [PRIVACY EMAIL]. We will acknowledge your complaint within [COMPLAINT ACK DAYS] business days and aim to resolve it within 30 days.
12.2 If you are not satisfied, you can complain to the OAIC at https://www.oaic.gov.au/privacy/privacy-complaints.
13. Changes
13.1 We will post any new version with its date, and email account owners about material changes at least [POLICY NOTICE DAYS] days before they apply.
14. Contact
[LEGAL ENTITY NAME], [REGISTERED ADDRESS]. Privacy officer: [PRIVACY EMAIL].