Privacy Policy
- Purpose of Our Policy
inGenious AI Pty Ltd ABN 63 617 284 492 (we, us or our) has adopted this Privacy Policy to ensure that we have standards in place to protect the Personal Information that we collect about individuals that is necessary and incidental to:
(i) providing the system and services that we offer; and
(ii) the normal day-to-day operations of our business.
This Privacy Policy follows the standards of the Australian Privacy Principles set by the Australian Government for the handling of Personal Information under the Privacy Act 1988 (Cth) (Privacy Act).
By publishing this Privacy Policy we aim to make it easy for our customers and the public to understand what Personal Information we collect and store, why we do so, how we receive and/or obtain that information, and the rights an individual has with respect to their Personal Information in our possession.
This privacy policy may be updated from time to time by us as our business changes and if laws or regulations change. - Who and What This Policy Applies To
Our Privacy Policy deals with how we handle “personal information” as it is defined in the Privacy Act (Personal Information).
We handle Personal Information in our own right and also for and on behalf of our customers and users.
The Privacy Policy applies to all forms of information, physical and digital, whether collected or stored electronically or in hardcopy.
If, at any time, an individual provides Personal Information or other information about someone other than himself or herself, the individual warrants that they have that person’s consent to provide such information for the purpose specified.
Our website and services are unavailable to children (persons under the age of 18 years) without their parent or legal guardian’s consent. - The Information We Collect
In the course of business it is necessary for us to collect Personal Information. This information allows us to identify who an individual is for the purposes of our business, share Personal Information when asked of us, contact the individual in the ordinary course of business and transact with the individual. Without limitation, the kind of personal information we may collect includes: your full name, address, company name, email address, phone number, information made available to us by you via our social media account services, information about your credit or trading history, your transaction and repayment history with us, banking or credit card details, statistical information, and personal correspondence sent by you or sent by others relating to you.
We do not generally collect sensitive information about you. Sensitive information includes things like information or opinions about your racial or ethnic origin, political opinion, religious beliefs and sexual orientation. We will only collect sensitive information with your consent, and where that information is reasonably necessary for us to provide the services to you.
We may collect other Personal Information about an individual, which we will maintain in accordance with this Privacy Policy.
We may also collect non-Personal Information about an individual such as information regarding their computer, network and browser. This may include their IP address. Where non-Personal Information is collected the Australian Privacy Principles do not apply. - How Information is Collected
Most information will be collected in association with an individual’s use of inGenious AI, an enquiry about inGenious AI or generally dealing with us. However, we may also receive Personal Information from sources such as advertising, an individual’s own promotions, public records, mailing lists, contractors, staff, recruitment agencies and our business partners. In particular, information is likely to be collected as follows:
(i) when an individual provides Personal Information when using our service;
(ii) when an individual registers or subscribes for a service, account, or connection;
(iii) when an individual provides Personal Information to other users of the service;
(iv) when an individual supplies us with goods or services;
(v) when an individual contacts us in any way;
(vi) when an individual accesses us physically or through the internet; and
(vii) through pixel tags.
We also collect the content you create, upload, or receive from others when using our services, which may include Personal Information.
As there are many circumstances in which we may collect information both electronically and physically, we will endeavour to ensure that an individual is always aware of when their Personal Information is being collected.
Where we obtain Personal Information without an individual’s knowledge (such as by accidental acquisition from a client) we will either delete/destroy the information, or inform the individual that we hold such information, in accordance with the Australian Privacy Principles.
We may also receive personal information about you from third parties, where reasonably necessary to provide you with services. If we do, we will handle and protect it as set out in this Privacy Policy. - How We Hold Personal Information
We will take reasonable steps to protect your personal information while it is in our control, but please be aware that despite our best efforts, no data security or other measures can guarantee 100% security.
We keep the personal information you provide to us:
(i) if it is in hardcopy form, in secure buildings with secure systems and processes; and
(ii) if it is in electronic form, in secure systems protected by passwords, virus protection software and firewalls.
Certain personal information about you may be linked with other information about you. Only our authorised officers can access your personal information and our databases are protected by passwords. - Retention of Personal Information
How long we keep information we collect about you depends on the type of information and what it is used for. We retain personal information that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
We will take reasonable steps to de-identify or destroy your personal information if we no longer require it. Customers may also configure data retention periods within the platform and may request deletion of their data at any time through the platform dashboard or by written request. This includes requesting that any backup copies of information held by third parties are returned to us, de-identified or destroyed, and taking steps to ensure that this has occurred. We note that residual copies of information may persist for up to 180 days due to the backup systems that we use.
If you provide us with Personal Information when using our services, you have a right to request that we destroy the Personal Information if the Personal Information is not reasonably necessary to us to provide you with our services. - Personal Information Processed on Behalf of Our Customers
7.1 Our Role as Data Processor
In addition to the Personal Information we collect directly (as described in sections 3 and 4), our platform processes Personal Information on behalf of our customers. When our customers use our platform to deploy AI agents, chatbots, and workflow automation, their end users may provide Personal Information during conversations or interactions with those services.
In these circumstances, our customer is the controller of that Personal Information and determines the purposes and means of processing. We act as a data processor, processing the information solely on behalf of and in accordance with the instructions of our customer.
7.2 What We Process
The types of Personal Information processed through our platform on behalf of our customers depend on the customer’s use and configuration of the platform and may include: end user names, contact details, and account information; content of conversations between end users and the customer’s chatbots or AI agents; taskflow inputs and outputs; workflow execution data; data submitted via API, webhook, or other integration; and any other Personal Information that end users voluntarily provide in the course of interacting with the customer’s services.
7.3 Data Controls
Personal Information provided by end users or entered into the platform may be stored as part of customer data, including conversation transcripts and workflow data. The platform provides configurable guardrails and data controls that customers may use to manage the handling of sensitive or regulated data. Our customers are responsible for configuring these controls as appropriate for their use case.
7.4 AI Processing
Our platform integrates with third-party AI model providers to deliver AI features. When our customers configure AI features, data (which may include Personal Information) may be transmitted to the selected AI model provider for processing. This processing occurs within the data processing region selected by the customer. We maintain contractual arrangements with our AI model providers that prohibit the use of customer data for model training or improvement of the provider’s general models.
We do not use customer data to train, fine-tune, or improve any AI models for general purposes. The platform provides optional fine-tuning capabilities that customers may elect to use at their sole discretion. We will not initiate fine-tuning on behalf of a customer. Where a customer elects to use fine-tuning features, processing is performed exclusively on that customer’s own data and the resulting model or configuration is available only to that customer.
7.5 Data Processing Agreement
The detailed terms of our data processing activities on behalf of customers are set out in our Data Processing Agreement, which forms part of our SaaS Terms of Service and Master Services Agreement. The Data Processing Agreement covers the roles and responsibilities of each party, data security measures, subprocessors, data retention and deletion, breach notification, and other matters relating to the processing of Personal Information through our platform.
7.6 Customer Responsibility
Our customers are responsible for: ensuring they have a lawful basis to collect and process Personal Information through our platform; implementing their own privacy policy and informing their end users about how their data is collected, used, and processed; and configuring the platform appropriately for their regulatory and compliance requirements. Our Privacy Policy does not apply to how our customers handle Personal Information. If necessary under the Privacy Act, it is the customer’s responsibility to meet the obligations of the Privacy Act by implementing a privacy policy in accordance with law. - When Personal Information is Used and Disclosed
In general, the primary principle is that we will not use any Personal Information other than for the purpose for which it was collected other than with the individual’s permission. The purpose of collection is determined by the circumstances in which the information was collected and/or submitted.
If it is necessary for us to disclose an individual’s Personal Information to third parties in a manner compliant with the Australian Privacy Principles in the course of our business, we will inform you that we intend to do so and obtain your consent before doing so, except in circumstances where we are required by law to disclose to a third party.
We will not disclose or sell an individual’s Personal Information to unrelated third parties under any circumstances.
Information is used to enable us to operate our business, especially as it relates to an individual. This may include:
(i) the provision of goods and services between an individual and us;
(ii) verifying an individual’s identity;
(iii) communicating with an individual about their relationship with us, our goods and services, our own marketing and promotions, offers from our partners, and competitions, surveys and questionnaires;
(iv) investigating any complaints about or made by an individual; and
(v) as required or permitted by any law (including the Privacy Act).
There are some circumstances in which we must disclose an individual’s information:
(i) as required by any law (including the Privacy Act); and
(ii) in order to sell our business.
Personal Information collected by us will be stored in Australia by default. Customers may select alternative data processing regions where available through the platform. - Opting In or Out
An individual may opt to not have us collect their Personal Information. This may prevent us from offering them some or all of our services and may terminate their access to some or all of the services they access with or through us. They will be aware of this when:
(i) Opt In: the individual will have the right to choose to have information collected and/or receive information from us; and
(ii) Opt Out: the individual will have the right to choose to exclude himself or herself from some or all collection of information and/or receiving information from us.
If an individual believes that they have received information from us that they did not opt in or out to receive, they should contact us on the details below. - The Safety and Security of Personal Information
We may appoint a Privacy Officer to oversee the management of this Privacy Policy and compliance with the Australian Privacy Principles and the Privacy Act. This officer may have other duties within our business and also be assisted by internal and external professionals and advisors.
We will take all reasonable precautions to protect an individual’s Personal Information from unauthorised access. This includes appropriately securing our physical facilities and electronic networks.
inGenious AI uses encryption to store and transfer Personal Information. All data is encrypted at rest using AES-256 and in transit using TLS 1.2 or higher. Despite this, the security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. Each individual that provides information to us via the internet, over the phone or by post does so at their own risk. We cannot accept responsibility for misuse or loss of, or unauthorised access to, Personal Information where the security of information is not within our control.
We are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individual’s Personal Information to in accordance with this policy or any applicable laws, and including Third-Party AI Model Providers). The collection and use of an individual’s information by such third parties may be subject to separate privacy and security policies.
If an individual suspects any misuse or loss of, or unauthorised access to, their Personal Information, they should let us know immediately.
We are not liable for any loss, damage or claim arising out of another person’s use of the Personal Information where we were authorised to provide that person with the Personal Information. - Anonymity
You may deal with us by using a pseudonym, or by remaining anonymous.
However, if you use a pseudonym or remain anonymous, we may not be able to provide you with our services or handle your enquiries or complaints to the fullest extent.
We may also be required by law to identify you when we supply you with services. - Your Rights Relating to Personal Information
You have certain rights under law regarding your personal information, including:
(i) a right to request access, correction, update or deletion of your personal information;
(ii) a right to object to processing of your personal information or withdraw your consent to our processing of your personal information at any time;
(iii) a right to restrict our processing of your personal information or request that we provide you with a copy of your personal information; and
(iv) the right to lodge a complaint with a supervisory authority if you think our processing of your personal information infringes applicable laws.
If you wish to exercise any of those rights, you can contact notices@ingenious.ai. - How to Access and/or Update Information
Users of inGenious AI can update their Personal Information from within their inGenious AI account or profile.
Subject to the Australian Privacy Principles, an individual has the right to request from us access to the Personal Information that we have about them, and we have an obligation to provide them with such access within a reasonable period after the request is made.
If an individual cannot update its own information, we will correct any errors in the Personal Information we hold about an individual within 14 days of receiving written notice from them about those errors.
It is an individual’s responsibility to provide us with accurate and truthful Personal Information. We cannot be liable for any information that is provided to us that is incorrect.
We may charge an individual a reasonable fee for our costs incurred in giving them access to the Personal Information we hold about them. However, we will not apply any charge to the making of the request for access. - Complaints and Disputes
If you have any queries or complaints about our Privacy Policy, or a suspected or actual breach of the Privacy Act by us, please address your complaint in writing to the details below.
Your complaint will be considered and we will endeavour to provide you with a written response within 30 days of receipt of the complaint. If we have a dispute with you regarding your Personal Information, we will first attempt to resolve the issue directly with you.
If you are not satisfied with the outcome of your complaint, please notify us in writing. You may also refer your complaint to the Office of the Australian Information Commissioner at https://www.oaic.gov.au/contact-us.
If we become aware of any unauthorised access to your Personal Information we will inform you at the earliest practical opportunity once we have established what was accessed and how it was accessed. - Contacting Individuals
From time to time, we may send an individual important notices, such as changes to our terms, conditions and policies. Because this information is important to the individual’s interaction with us, they may not opt out of receiving these communications. - Contacting Us
All correspondence with regards to privacy should be addressed to:
The Privacy Officer
inGenious AI Pty Ltd
Level 4, 152 Elizabeth Street
Melbourne, Victoria, 3000
notices@ingenious.ai
You may contact the Privacy Officer by email in the first instance. - Additions to This Policy
If we decide to change this Privacy Policy, we will post the changes on our webpage at http://ingenious.ai/privacy. Please refer back to this Privacy Policy to review any amendments.
Where we propose to make a material change to this Privacy Policy, we will provide customers with no less than 30 days’ written notice of the proposed change, in accordance with the terms of the applicable SaaS Terms of Service or Master Services Agreement.
We may do things in addition to what is stated in this Privacy Policy to comply with the Australian Privacy Principles, and nothing in this Privacy Policy shall deem us to have not complied with the Australian Privacy Principles.
Version 4.0 (14/04/2026)