Privacy Policy

Effective date: 1 January 2026

Last updated: February 2026

Newframe Group Pty Ltd (ACN 674 XXX XXX) ("we", "us", "our", "ApprovalPath") operates the ApprovalPath platform. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information and health information when you use our Service.

We are committed to complying with:

1. Information We Collect

1.1 Information You Provide Directly

Account and Registration Data

Payment Information

Guide Data

Communication Data

Optional Information

1.2 Information Collected Automatically

Usage and Behavioural Data

Technical Data

Location Data

Cookie and Tracking Technologies

2. How We Use Your Information

We use your information for the following purposes:

2.1 Primary Service Delivery

2.2 Communication and Support

2.3 Product Improvement and Analytics

2.4 Compliance and Legal Obligations

2.5 Business Operations

2.6 Marketing (with your consent)

3. Legitimate Basis for Processing

Under the Australian Privacy Principles, we process your information on the basis of:

4. AI and Data Processing

4.1 How AI Guide Generation Works

When you run a guide in ApprovalPath:

  1. Your inputs (property address, project details, answers to questions) are processed by our AI models
  2. The AI analyses publicly available planning data relevant to the property's jurisdiction
  3. The AI generates a structured guide report with the likely approval pathway
  4. Your inputs and the generated report are stored in your account for future reference

4.2 Training and Model Improvement

We may use anonymised and aggregated data to:

We do not sell your personal data or individual guide inputs to third parties.

4.3 Data Processing Agreements

All AI model providers used by ApprovalPath are subject to strict Data Processing Agreements (DPAs) that ensure:

5. Sharing Your Information

We only share your information with trusted partners, and only to the extent necessary:

5.1 Service Providers and Processors

All service providers are bound by confidentiality obligations and data processing agreements.

5.2 Legal and Regulatory Authorities

We may disclose your information without consent if required by:

5.3 Business Transfers

If Newframe Group Pty Ltd is acquired, merged, or substantially restructured, your information may be transferred to the acquiring organisation. We will provide notice of any such change and your right to opt-out.

5.4 Protecting Our Rights

We may disclose information to enforce our Terms of Service, investigate breaches, prevent fraud, or protect the legal rights, property, or safety of Newframe Group Pty Ltd, our users, or the public.

5.5 What We Do NOT Do

6. Data Retention

6.1 Account Data

We retain your personal information (account details, payment records, contact information) for as long as your subscription is active, and for a minimum of 7 years after account closure for:

6.2 Guide Data

Your guide inputs and generated reports are retained for the duration of your active subscription. You can export or download this data at any time.

6.3 After Cancellation

Upon cancellation of your subscription:

6.4 Communication Records

7. Data Security

We implement industry-leading security measures to protect your personal information:

7.1 Technical Safeguards

7.2 Administrative Safeguards

7.3 Subprocessor Security

7.4 Limitations

While we strive to protect your information, no system is 100% secure. We cannot guarantee absolute protection against all security breaches. If a breach occurs, we will notify affected individuals in accordance with the Notifiable Data Breaches scheme (see Section 8).

8. Notifiable Data Breaches

Under the Privacy Act 1988 (Cth), we are required to notify you if:

Notification will include:

Notifications will be sent to your registered email address as soon as practicable, and without unreasonable delay (generally within 30 days).

9. Your Privacy Rights and Choices

Under the Australian Privacy Principles, you have the following rights:

9.1 Right of Access

You have the right to access the personal information we hold about you. To request access:

9.2 Right to Correction

If you believe personal information we hold is inaccurate, incomplete, or out-of-date, you can request correction:

9.3 Right to Deletion

You have the right to request deletion of your personal information:

9.4 Right to Opt-Out of Marketing

You can opt-out of marketing communications at any time by:

9.5 Right to Withdraw Consent

For any processing based on your consent (e.g., optional analytics, marketing), you can withdraw consent at any time:

9.6 Right to Complain

If you believe we have breached your privacy rights, you can lodge a complaint:

10. Cookies and Tracking Technologies

10.1 Essential Cookies

These cookies are necessary for the Service to function. They cannot be disabled:

10.2 Optional Cookies

These cookies are optional and require your consent:

10.3 Managing Cookies

You can manage cookie preferences:

Note: Disabling essential cookies may prevent the Service from functioning properly.

11. Children and Privacy

ApprovalPath is not intended for children under 18 years of age. We do not knowingly collect personal information from children. If we become aware that a child has provided information to us, we will delete it promptly and notify the parent or guardian.

If you are a parent or guardian concerned about a child's privacy, please contact us at privacy@approvalpath.com.au.

12. International Data Transfers

Your information may be transferred to and stored on servers located outside Australia, including in the United States (Vercel, Stripe), Canada, or the European Union, as required for Service delivery.

By using ApprovalPath, you consent to the transfer and processing of your information in these jurisdictions. We ensure that all international transfers comply with:

13. Third-Party Links

ApprovalPath may contain links to third-party websites or services (e.g., council websites, government planning portals). We are not responsible for the privacy practices of third-party sites. Please review their privacy policies before providing personal information.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

We will notify you of material changes via:

Continued use of the Service after changes take effect constitutes your acceptance of the revised Privacy Policy. If you do not agree with changes, your sole remedy is to cancel your subscription.

15. Our Privacy Officer

For privacy-related inquiries, concerns, or requests, please contact our Privacy Officer:

Email: privacy@approvalpath.com.au

Mailing Address: Newframe Group Pty Ltd [Street Address] New South Wales, Australia

Response timeframe: We will acknowledge your inquiry within 2 business days and provide a substantive response within 30 days (or as required by law).

16. Verification and Authentication

To protect your privacy, we may ask you to verify your identity before providing access to your personal information. This may include:

This verification process ensures that only you can access your personal data.

17. Governing Law

This Privacy Policy is governed by the laws of New South Wales, Australia, and the Privacy Act 1988 (Cth). Any disputes will be resolved in accordance with Australian privacy law and the jurisdiction of the courts of New South Wales.