Lumiere Property Intelligence Pty Ltd ("we", "us", "our") is committed to protecting your privacy. This Policy explains how we handle personal information in connection with the Lumière AUSTRAC platform ("the Platform"), consistent with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
1. The two kinds of information we handle
It is important to distinguish two roles:
(a) Information about you, our customer
When you register and subscribe, we collect information about you and your business — such as your name, email, business name, contact details and billing information.
(b) Information you input about your own customers
To use the Platform's compliance tools, you input personal information about your customers and staff — including identity and customer due diligence (CDD) information. For this information, you are the entity that decides how it is used; we host and process it on your behalf so you can meet your obligations. You are responsible for collecting it lawfully and for your own privacy obligations to those individuals.
2. What we collect
- Account & contact data: name, email, business name, phone, role.
- Billing data: processed by Stripe; we do not store full card numbers.
- Compliance data you input: customer names, identity document details, screening results, risk assessments, transaction and reporting records, training records.
- Usage data: log and technical data needed to operate and secure the Service.
3. Why we use it
- To provide, maintain and secure the Platform.
- To process your subscription and payments.
- To support you and respond to enquiries.
- To meet our own legal obligations.
We do not sell personal information, and we do not use your compliance data for our own purposes beyond providing the Service.
4. How it is stored and protected
Data is stored using reputable infrastructure providers. Compliance data is held in a database with access controls that isolate each customer's data to their own account. Access to your sensitive data on the server is restricted. We take reasonable steps to protect personal information from misuse, loss and unauthorised access, though no system is perfectly secure.
We use the following key service providers ("processors") to operate the Platform:
- Supabase — database and authentication.
- Netlify — application hosting.
- Stripe — payment processing.
- Anthropic — AI features (where you enable them).
Some of these providers may store or process data outside Australia. By using the Platform you acknowledge this. We take reasonable steps to ensure they protect information consistently with the APPs.
5. Retention
The AML/CTF laws require certain records to be kept for at least seven years. We retain compliance data for as long as your account is active and as needed to provide the Service. You control your records and can export them. If you close your account, we will retain or delete data in line with our legal obligations and your instructions; note that you may have your own independent obligation to retain records for seven years.
6. Your rights
Under the Privacy Act you may request access to, and correction of, the personal information we hold about you. To make a request, contact us at the details below. We will respond within a reasonable time. Where the information is your customers' data that you input, you can access and correct it directly within the Platform.
7. Complaints
If you have a privacy concern, contact us first and we will work to resolve it. If you are not satisfied, you may contact the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.
8. Data breaches
We have procedures to respond to data breaches. Where a breach is likely to result in serious harm, we will notify affected individuals and the OAIC as required by the Notifiable Data Breaches scheme.
9. Changes to this Policy
We may update this Policy from time to time. The current version is always available on our website, with the "last updated" date shown above.
10. Contact us
For privacy questions, access requests or complaints:
Lumiere Property Intelligence Pty Ltd
Privacy contact: admin@lumiereaustrac.com.au