Important notice
Belira Pty Ltd (ABN 52 696 900 553) ("Belira", "we", "us", "our") is committed to protecting your privacy. We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).
This policy outlines how we handle the personal information of our direct customers (Brokers/Subscribers) and how we process the data of their clients (Borrowers) on their behalf.
1. About this policy
1.1
This Privacy Policy applies to our website, our software-as-a-service platform (the Service), and our related business operations.
1.2
By using our Service, visiting our website, or otherwise providing us with personal information, you consent to the handling of your information as described in this policy.
2. What personal information we collect
2.1
From our Customers (Brokers): We collect contact details (name, email, phone), business details (ABN, address, ACL number), billing information, and technical usage data (IP address, device info, access logs).
2.2
From Borrowers (End Users): We process identity documents (e.g., passports, driver's licences), financial documents (e.g., payslips, bank statements), and contact details uploaded via the Service. This may include Sensitive Information (such as government identifiers or biometric data).
3. How we collect personal information
3.1
We collect information directly from you when you register for an account, interact with our support team, or browse our website.
3.2
We process Borrower information when it is submitted into our platform by a Broker, or when a Borrower uploads it directly via a Belira-hosted magic link or portal.
4. Why we collect, hold, use and disclose personal information
4.1
We handle your information to: (a) provide, operate and secure the Service; (b) process billing and payments; (c) communicate with you regarding updates, support, and marketing; and (d) comply with our legal and regulatory obligations.
5. Our role as a Service Provider (Borrower Data)
5.1
When a Broker uses Belira to collect Borrower Data, the Broker is the APP entity responsible for that data. Belira acts merely as a data processor and software provider.
5.2
We will only process Borrower Data in accordance with the Broker's instructions, our Terms and Conditions, and this Privacy Policy. We do not use Borrower Data for our own independent marketing or commercial purposes.
6. Disclosing personal information
6.1
We may disclose personal information to our trusted third-party service providers (e.g., AWS for hosting, Stripe for payments, Annature for e-signing). These providers are contractually bound to protect your data.
6.2
We will not sell your personal information to third parties. We may disclose information if required by law, subpoena, or a regulatory authority.
7. AI Features and automated processing
7.1
Belira uses advanced AI features to extract data from uploaded documents. We do not use Customer Data or Borrower Data to train third-party foundation models. Data processed through AWS Bedrock is isolated and secure.
9. Direct marketing
9.1
We may send you direct marketing communications about our products. You may opt-out at any time using the unsubscribe link in our emails. We never send direct marketing to Borrowers.
10. Cross-border disclosure
10.1
Our primary data hosting infrastructure is located in Sydney, Australia (AWS ap-southeast-2). However, some limited sub-processors may operate overseas. We take reasonable steps to ensure any overseas recipients comply with the APPs.
11. Quality, security and retention
11.1
Security: We implement bank-grade security measures including AES-256 encryption at rest, TLS encryption in transit, strict access controls, and multi-tenant database isolation.
11.2
Retention: We retain Customer Data while your account is active. Upon termination, we will delete or de-identify data in accordance with our Terms and Conditions, typically within 90 days.
12. Access and correction
12.1
You have the right to request access to or correction of your personal information. Brokers can update their details directly in the platform. Borrowers seeking access to their data must contact their Broker directly.
13. Complaints
13.1
If you believe we have breached the Privacy Act, please contact us at privacy@belira.com.au. We will investigate and respond within 30 days. If unsatisfied, you may complain to the Office of the Australian Information Commissioner (OAIC).
14. Changes to this policy
14.1
We may update this Privacy Policy periodically. We will notify customers of significant changes via email or an in-app alert.
— End of document —