DRAFT - Requires Legal Review

This document is a structural placeholder. It has not been reviewed by legal counsel and must not be relied upon as legal advice until reviewed and approved. Australian Privacy Principles framework is referenced; full compliance requires legal review.

Privacy Policy

Last updated: 23 April 2026

Version: 0.1-draft

Governing framework: Australian Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs)

1. About this policy

Ledgable Pty Ltd (“Ledgable”, “we”, “our”) is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and protect your personal information in accordance with the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

2. Australian Privacy Principles

Ledgable complies with the 13 Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth). These principles govern how we collect, hold, use, and disclose personal information.

Key APPs applicable to Ledgable:

  • APP 1: Open and transparent management of personal information
  • APP 3: Collection of solicited personal information
  • APP 5: Notification of the collection of personal information
  • APP 6: Use or disclosure of personal information
  • APP 8: Cross-border disclosure of personal information
  • APP 11: Security of personal information
  • APP 12: Access to personal information
  • APP 13: Correction of personal information

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3. Information we collect

We may collect the following types of information:

  • Account information: name, email address, business name, ABN
  • Financial data: bank transaction data imported via bank feed connections
  • Usage data: how you interact with the Ledgable platform
  • Communication data: emails, support tickets, and feedback you send us
  • Payment information: billing details (processed via our payment provider - not stored on our servers)

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4. How we use your information

We use your information to:

  • Provide and improve the Ledgable service
  • Process your transactions and subscriptions
  • Send you service notifications and account communications
  • Comply with Australian legal and regulatory obligations
  • Train and improve our AI models (with your consent - opt-in only)

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5. Data storage and security

Your data is stored in Australia. We use industry-standard encryption for data in transit and at rest. We maintain security controls appropriate to the sensitivity of financial data. We do not sell your data to third parties for any purpose.

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6. Disclosure to third parties

We do not sell, trade, or rent your personal information. We may share your information with third parties only in the following circumstances:

  • Service providers who assist in operating the Ledgable platform (e.g., cloud hosting, payment processing)
  • When required by Australian law or a valid court order
  • With your explicit consent (e.g., sharing with your accountant)

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7. Your rights

Under the Australian Privacy Act, you have the right to:

  • Access the personal information we hold about you
  • Request correction of inaccurate information
  • Make a complaint if you believe we have breached the APPs
  • Export your data at any time
  • Delete your account and associated data (subject to legal retention requirements)

8. Cookies and tracking

We use cookies and similar tracking technologies to operate the Service. See our Cookie Policy at ledgable.co/legal/cookie for full details.

9. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email with reasonable advance notice. The most current version is always available at this URL.

10. Contact and complaints

For privacy queries or to exercise your rights under the Privacy Act, contact our Privacy Officer at privacy@ledgable.co. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.