Privacy Policy

Billroo Operations PTY LTD · ABN 34 676 806 429

The personal information we collect and hold about you may include:

• Billroo account information, such as your email address, name, country, currency and information used to authenticate your Billroo account;

• your subscription status and records relating to subscription and AI Credit purchases, such as the billing provider, transaction reference, purchase date, purchase status and the plan or product purchased;

• financial account information, such as account names, account types and account balances;

• transaction data, such as transaction amounts, dates, descriptions, merchants and categories;

• budgeting information used within the Billroo platform; and

• net worth information, including assets, liabilities or debts, their categories, balances or estimated values, and changes in value over time.

We do not receive or store the login credentials you use to access your bank or financial institution.

5.1. Security Framework Compliance

• Our security practices align with industry-standard frameworks including SOC2 principles
• We maintain regular security assessments and audits
• Our infrastructure is hosted on Google Cloud, leveraging their extensive security features
• We partner with Fiskil, a verified Open Banking provider, ensuring compliance with government standards

5.2. Data Access Controls

• Access to personal information is strictly limited to authorised personnel
• Employee access is granted on a need-to-know basis and requires management approval
• All-access to customer data is logged and monitored
• Regular access reviews are conducted to ensure appropriate permissions
• We maintain read-only access to banking data through Open Banking, ensuring we cannot modify any financial information

5.3. Development and Testing practices

• Development and testing environments are strictly separated from production
• We use synthetic data for testing and development purposes
• Production data is never copied to development environments
• All code changes undergo a security review before deployment

5.4. Data Storage and Protection

• We use state-of-the-art encryption to protect your data both in transit and at rest
• Regular backups are performed and stored securely
• Your banking credentials are never stored – we use secure Open Banking APIs instead

5.5. Open Banking Security

• We utilise Open Banking, a secure government-backed initiative, for accessing banking data
• No bank passwords or credentials are ever shared with Billroo
• Users maintain complete control and can disconnect access at any time through their settings
• Our Open Banking partner Fiskil maintains their own Consumer Data Rights policy, available at https://www.fiskil.com/legal/privacy-policy
• For United States bank connections, our provider Plaid Inc. maintains its own End User Privacy Policy, available at https://plaid.com/legal/#end-user-privacy-policy

5.5A Bank Account Connections via Plaid (United States users)

For users connecting financial accounts held with United States institutions, Billroo uses Plaid Inc. (“Plaid”) to securely connect to your bank or financial institution and retrieve account information on your behalf. When you connect an account through Plaid, you enter your account credentials directly into Plaid’s interface — Billroo never receives or stores your banking login credentials. Plaid accesses and transmits to us the financial data you authorise, which may include:

• Account information, such as account name, type, and balance; and
• Transaction information, such as transaction amounts, dates, descriptions, and categories.

Plaid accesses this data on a read-only basis. Neither Plaid nor Billroo can move funds, make payments, or otherwise transact on your connected accounts. You can disconnect a linked account at any time through your Billroo settings.

Plaid’s collection, use, and handling of your information is governed by Plaid’s End User Privacy Policy, available at https://plaid.com/legal/#end-user-privacy-policy. By connecting a financial account through Plaid, you acknowledge and agree that your information will be collected, used, and shared by Plaid in accordance with Plaid’s End User Privacy Policy.

5.6. Data Usage and Sharing

• We only collect and use data necessary for providing our services
• Your data is never shared with third parties without your explicit permission
• All data sharing is conducted through secure, encrypted channels

5.7 Partner Access — Sharing of Financial Data Between Users

Where you enable the Partner Access feature, you consent to your personal and financial information stored within your Billroo account — including your transaction history, bank connections, budgeting data, and account activity — being accessible to the Additional User you have nominated.

Before your nominated Additional User can access your account, they are required to accept this Privacy Policy and Billroo’s Terms and Conditions. By enabling Partner Access, you acknowledge that:

Billroo Operations PTY LTD handles the personal information of both Account Holders and Additional Users in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. The Additional User’s own personal information (including their email address and login credentials) is collected and handled separately in accordance with this Privacy Policy.

Australian Privacy Principle 12 permits you to obtain access to the personal information we hold about you in certain circumstances, and Australian Privacy Principle 13 allows you to correct inaccurate personal information subject to certain exceptions. If you would like to obtain such access, please contact us as set out below.

If you have a complaint concerning the manner in which we maintain the privacy of your personal information, please contact us as set out below. All complaints will be considered by Pablo Bizzini and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.

After your account is deleted, we may retain your email address to confirm the deletion of associated data. Notwithstanding the above, we may retain information as long as necessary to comply with our legal and regulatory obligations or in connection with any legal proceedings. Note that you can request the deletion of your information at any time by contacting us via [email protected] or filling out our contact form.

Where you are an Account Holder who has enabled Partner Access, deleting your account will immediately terminate the Additional User’s access to your account. The Additional User’s own separate Billroo account (if any) will not be affected by your account deletion. Where you are an Additional User, deleting your own Billroo account will remove you from the Account Holder’s account. Any data you added to the Account Holder’s account during the period of access will be retained on the Account Holder’s account.

We partner with Fiskil (for Australian Open Banking) and Plaid (for United States financial account connections) to provide bank connectivity. Your banking data access is governed by the applicable Open Banking regulations, Fiskil’s Consumer Data Right policy, and Plaid’s End User Privacy Policy.

Your personal information may be transferred to recipients located in United States of America as we use third-party applications to process and store your data.

We use third-party applications and service providers to deliver our services, including but not limited to Segment, AWS, Google Cloud, Stripe, Anthropic, Fiskil, Plaid (for United States financial account connections), and Apple (for iOS in-app purchases, where applicable). You agree and acknowledge that you may be subject to the terms and privacy policies of those third-party providers.

United States of America has data protection laws which protect personal information in a way which is at least substantially similar to the Australian Privacy Principles, and there will be mechanisms available to you to enforce protection of your personal information under that overseas law. In the circumstances, we do not require the overseas recipients to comply with the Australian Privacy Principles and we will not be liable for a breach of the Australian Privacy Principles if your personal information is mishandled.

10A. European Union General Data Protection Regulation (GDPR)

In some circumstances, the European Union General Data Protection Regulation (GDPR) provides additional protection to individuals located in Europe. The fact that you may be located in Europe does not, however, on its own entitle you to protection under the GDPR. Our website does not specifically target customers located in the European Union and we do not monitor the behaviour of individuals in the European Union, and accordingly the GDPR does not apply.

10B. Mobile App Privacy Notice (iOS & Android)

This Mobile App Privacy Notice supplements our Privacy Policy and explains how Billroo Operations Pty Ltd (“Billroo”, “we”, “us”, “our”) collects, uses and protects information when you use our iOS or Android mobile applications (“Apps”).

a) Information we collect through the Apps

When you use the Apps, we may collect the following additional types of data in addition to what is described elsewhere in this Privacy Policy:

• Device information such as model, operating-system version, language, time zone, and app version.
• Diagnostics and usage data such as crash logs, performance analytics, and feature usage metrics to improve stability and user experience.
• App permissions data such as push-notification tokens, camera or photo-library access (for receipt capture), and biometric unlock status, only when you grant permission on your device.
• In-app purchase, subscription and AI Credit purchase data (iOS only), handled by Apple for billing and fraud prevention. Billroo does not receive or store your Apple payment details.
• Login data and secure session tokens needed to authenticate your account.

We do not collect your precise GPS location, microphone input, or contacts list. We also never store your bank login credentials — all financial data sharing occurs securely via our accredited providers, Fiskil for Australian institutions and Plaid for United States institutions.

b) Payments and subscriptions

iOS: Subscription purchases, trials, and AI Credit purchases may be managed by Apple under their App Store Terms of Service. Apple provides us with limited transactional information, such as anonymised or tokenised references, purchase status, and subscription status, but not your full payment details.

Android / Web: Subscriptions and AI Credit purchases may be processed through Stripe, the same system used on our web app. Stripe processes your payment information on our behalf; Billroo does not store your full card details.

c) Account deletion

To delete your Billroo account, log in to the web app at www.billroo.com → Account → Delete Account. Deletion permanently deactivates your account and schedules removal of personal data from live systems within 30 days (and from backups within 90 days). Deleting your account does not cancel any active subscription; you must cancel via your Apple ID (iOS) or Stripe billing portal (Android).

d) How we use mobile data

We use data collected through the Apps to:

• Provide and improve mobile functionality and user experience;
• Diagnose technical issues and enhance app performance;
• Secure the app and protect against fraud and misuse;
• Deliver notifications you opt into (e.g., budgeting reminders, subscription updates);
• Comply with legal obligations and store-platform requirements.

e) Data sharing for mobile features

We may share limited, non-identifying data with service providers who help us operate our Apps:

• Apple Inc. – App distribution, in-app billing, crash diagnostics (iOS only).
• Stripe Inc. – Payment processing (Android only).
• Fiskil Pty Ltd – Open Banking data connections under the CDR framework (Australia).
• Plaid Inc. – Secure financial account connections for United States institutions, governed by Plaid’s End User Privacy Policy.
• Anthropic PBC – AI services (Claude AI) for chatbot and tax-report functionality.

Each third party has its own privacy policy governing their processing of your data.

f) Push notifications and analytics

With your consent, we may send push notifications. You can disable them at any time in your device settings. Aggregated, anonymised analytics may be used to assess app usage and feature engagement.

g) Data retention

Mobile diagnostic and analytics data are retained only as long as necessary for troubleshooting, security and improvement purposes, typically no longer than 12 months, after which they are aggregated or deleted.

h) Legal basis

Processing of mobile app data is based on your consent (for permissions and notifications) and on our legitimate interests in providing and improving the Billroo App and ensuring security and stability.

11.1 Use of Data

When you enter or upload your data into our services, we don’t own that data. However, by using our services, you grant us a licence to use, copy, transmit, store, analyse, and back up all data you submit to us, including personal data, for the following purposes: Enabling you to use our services; Improving, developing, and protecting our services; Creating new services; Communicating with you about your subscription; Sending you information based on your marketing preferences; We may disclose data to third-party service providers and partners to support these purposes.

11.2 Use of Your Personal Data

We respect your privacy and take data protection seriously. Our privacy notice details how we process the personal data that you enter into Billroo, such as your name and email address.

11.3 Use of Personal Data You Enter About Others

If you enter personal data about others (e.g., your merchants) into Billroo, our data processing terms may apply depending on where your contacts are based.

11.3A Partner Access — Personal Data Shared Between Users

Where you are an Account Holder who has enabled Partner Access, you are sharing your personal and financial data with your nominated Additional User. You are responsible for ensuring that any personal data you share via Partner Access is shared with the consent of any individuals whose data may be included (for example, joint account holders or other parties whose transactions appear in your account). Billroo Operations PTY LTD is not responsible for any privacy obligations that arise between you and your Additional User as a result of this data sharing.

11.4 Data Breach Notifications

In the event of unauthorised access to personal data entered into Billroo, we will inform you and provide relevant details about the breach. Depending on the nature of the breach and the location of your affected contacts, you may need to assess whether the breach should be reported to the affected individuals and/or a relevant authority. You are best placed to make this decision due to your knowledge of the personal data entered into your Billroo subscription.

11.5 Children’s Privacy

Our website is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe we might have any information from or about a child under 13, please contact us at [email protected].

12.1 Use of AI Technologies

We utilise artificial intelligence technologies, including Anthropic, to enhance our services and user experience. When you interact with our AI-powered features, we collect and process additional information including:

• Chat conversations and interactions with our AI systems
• Queries submitted to AI features
• Response data and interaction patterns
• Usage analytics related to AI features

12.2 Data Processing for AI Services

The data collected through our AI features, including the tax report, may be:

• Processed by third-party AI service providers, including Anthropic (Claude AI)
• Used to train and improve our AI systems
• Stored in servers located in the United States of America
• Subject to the same security measures and privacy protections outlined in our Third-parties and overseas transfers section

The data shared with our AI service providers, including Anthropic, may include transaction descriptions, transaction categories, transaction amounts, budget information, your Billroo tier, account balances and net worth information, including assets, liabilities or debts and their recorded values. We only share information relevant to the AI feature you are using. We do not share your name, email address, bank login credentials or payment details with AI service providers.

Additionally, Billroo AI may link to your Billroo account to fetch your existing personal information to individualise the chat experience or for future direct marketing purposes. Furthermore, Billroo may use any content you type into the chat to train Billroo AI and improve our products and services. This processing helps enhance user interactions and ensures that our offerings are tailored to meet your needs and preferences.

Where an Additional User uses AI features within the Account Holder’s account, their interactions (including queries and responses) are processed in the same manner as described in this section. The Account Holder’s data (including transaction history and account information) may be used to generate AI responses during the Additional User’s session.

12.3 AI Data Retention and Security

All data processed through our AI features is:

• Retained in accordance with our general data retention policies
• Protected by appropriate technical and organisational security measures
• Subject to the same data breach notification procedures outlined in section 11.4
• Handled in compliance with applicable Australian Privacy Principles

12.4 Third-Party AI Services

When using our AI features, you acknowledge that:

• Your interactions may be processed by third-party AI providers
• You’ll be subject to the T&Cs and Privacy Policy of our 3rd party AI provider including but not limited to Anthropic – https://www.anthropic.com/legal/consumer-terms
• These providers have their own privacy policies and terms of service
• We have agreements in place with these providers to protect your personal information
• The same overseas data transfer provisions outlined in our Third-parties section apply to AI-related data transfers

If you have any queries, or if you seek access to your personal information, or if you have a complaint about our privacy practices, you can contact us through: [email protected].

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.