Privacy Policy

Version 3.0 - Last updated: 26 March 2026

1. Introduction

Precision CAD Australia (ABN 61 451 007 505), trading as RTOFlow ("we", "us", "our"), is committed to protecting the privacy of individuals who use our platform. This Privacy Policy explains how we collect, use, disclose, store, and protect personal information in accordance with the Australian Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act.

This Policy also addresses our obligations in relation to the use of artificial intelligence in content generation, consistent with the Australian Government's Voluntary AI Safety Standard (2024) and emerging regulatory expectations from the Privacy Act Review reform process.

By accessing or using RTOFlow, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the platform.

2. What Personal Information We Collect

2.1 Account Information

• Full name
• Email address
• Organisation name and details
• Role within the organisation
• Password (stored in hashed form only)

2.2 Usage and Activity Data

• Login timestamps and session duration
• Features accessed and actions performed
• Content generation requests and parameters
• Document uploads and downloads
• Search queries within the platform

2.3 Technical Data

• IP address
• Browser type and version
• Operating system
• Device identifiers
• Referring URLs

2.4 Payment Information

• Billing name and address
• Payment card details (processed and stored by Stripe; we do not store full card numbers)
• Transaction history
• Invoice records

2.5 Newsletter and Lead Magnet Data

When you sign up for our newsletter or download free resources (lead magnets), we collect:

• Name
• Email address
• Source page URL (the page you signed up from)
• IP address (for rate limiting and fraud prevention)

Newsletter subscriptions use a double opt-in process: after submitting your email, you must confirm your subscription via a link sent to your email address. We will only send you marketing communications after you have confirmed your subscription. You may unsubscribe at any time using the unsubscribe link included in every email. We send a weekly VET industry digest to confirmed subscribers.

2.6 Student and Learner Data

If your Organisation uses our contextualization features, we may process the following learner data on your Organisation's behalf:

• Student names (first name, last name)
• Email addresses and phone numbers
• Date of birth
• Apprenticeship numbers
• Language, Literacy, and Numeracy (LLN) assessment levels (reading, writing, oral communication, numeracy, digital)
• LLN support notes
• Learning styles and learning goals
• Employer name, job title, primary tasks, equipment and processes, shift patterns
• Supervisor name and contact details
• Prior qualifications and experience summaries

2.7 Content Data

• Training and assessment materials created using the platform
• Documents uploaded for compliance checking or AI processing
• Notes, comments, and feedback submitted within the platform

2.8 Communication Data

• Support requests and correspondence
• Feedback and survey responses
• In-app chat and help interactions

2.9 Signature Data

• Digital signatures captured within the platform (e.g., user profile signatures)

2.10 Analytics and Tracking Data

• Page view history (path, referrer, session ID) - collected for internal analytics
• Third-party analytics data collected on public pages (when configured) via Google Analytics 4, Google Ads conversion tracking, Bing UET, and Meta/Facebook Pixel - see Section 6 for details

3. How We Collect Personal Information

We collect personal information through:

• Direct collection: When you create an account, update your profile, submit forms, upload documents, or contact us.
• Automated collection: Through cookies, server logs, internal analytics tools, and - on public pages where configured - third-party analytics and advertising services (see Section 6) when you use the platform.
• Third-party sources: From training.gov.au (publicly available training package data), payment processors (transaction confirmations), and OAuth authentication providers (Google, Microsoft, or Replit - when you choose to sign in with these services, we receive your name, email address, and profile photo as authorised by you during the login flow).

Where practicable, we collect personal information directly from you. If we receive personal information about you from a third party, we will take reasonable steps to ensure you are made aware of this Policy.

4. How We Use Personal Information

We use personal information for the following purposes:

We do not use personal information for direct marketing without your express consent. Newsletter subscribers must complete a double opt-in process before receiving marketing communications, and may unsubscribe at any time via the link in each email.

5. Third-Party Processors

We share personal information with the following categories of third-party service providers, each of which is bound by contractual obligations to protect your data:

We do not sell personal information to any third party.

6. Cookies and Tracking Technologies

6.1 Essential Cookies

6.2 Third-Party Analytics and Advertising on Public Pages

On our public-facing pages (marketing site, landing pages), we may use the following third-party analytics and advertising technologies. These services are only active when their respective environment variables are configured, and they are not present on authenticated application pages.

These services may set their own cookies and collect data in accordance with their respective privacy policies. You can opt out of personalised advertising through your browser settings, the Digital Advertising Alliance opt-out page, or the respective platform settings (Google Ad Settings, Facebook Ad Preferences, Microsoft Privacy Dashboard).

6.3 Managing Cookies

On our public pages we also display an in-app cookie banner the first time you visit. You can Accept all analytics cookies, Reject non-essential cookies, or open Manage to choose individual categories. Your choice is recorded in the rtoflow_consent cookie listed in Section 6.1, and we re-render the page with trackers either enabled or fully suppressed accordingly. You can change your mind at any time by clearing that cookie in your browser.

You can configure your browser to refuse cookies. However, disabling session cookies will prevent you from using the platform, as they are essential for authentication. Disabling third-party cookies may prevent analytics and advertising tracking on public pages but will not affect platform functionality.

7. Data Retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by law.

After the applicable retention period, personal information is securely deleted or de-identified.

8. Data Security

We implement reasonable technical and organisational measures to protect personal information from misuse, interference, loss, unauthorised access, modification, or disclosure, including:

• Encryption at rest: AES-256 encryption for stored data
• Encryption in transit: TLS 1.2 or higher for all data transmission
• Access controls: Role-based access with least-privilege principles
• Authentication: Hashed passwords with industry-standard algorithms
• Tenant isolation: Full per-organisation data separation
• Backup integrity: Automated backup verification on each cycle
• Monitoring: Automated health and security monitoring
• Incident response: Documented incident response procedures

No method of electronic storage or transmission is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

9. Your Rights

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

9.1 Access (APP 12)

You may request access to the personal information we hold about you. We will respond to your request within 30 days. Access may be refused in limited circumstances permitted by law, and we will provide reasons for any refusal.

9.2 Correction (APP 13)

You may request correction of personal information that is inaccurate, out of date, incomplete, irrelevant, or misleading. We will respond to correction requests within 30 days.

9.3 Deletion

Although not explicitly required by the APPs, we honour reasonable deletion requests. Upon receiving a verified deletion request:

1. Your account and profile data will be deleted within 30 days.
2. Content you generated will be deleted or de-identified within 30 days.
3. Data retained in backups will be purged as backups rotate (up to 12 months).
4. Records required by law (e.g., payment records) will be retained for the legally mandated period.

9.4 Data Portability

You may request an export of your data in a commonly used, machine-readable format. Exports are available for user-generated content and account data.

9.5 Complaint (APP 1)

If you believe we have breached the APPs, you may lodge a complaint with us (see Section 17). If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

10. Student and Learner Data - Controller and Processor Roles

10.1 Your Organisation as Controller

Where your Organisation uploads or enters student and learner personal information into the Platform (including for contextualization, cohort management, or RPL assessment), your Organisation is the data controller for that information. RTOFlow processes this data solely on your Organisation's behalf and in accordance with your instructions.

10.2 RTOFlow as Processor

RTOFlow acts as a data processor for student and learner personal information. We process this data only to provide the Platform services, and we do not use learner data for any independent purpose.

10.3 Your Obligations

Your Organisation is responsible for:

• Obtaining all necessary consents from students and learners before uploading their personal information to the Platform, including explicit consent for sensitive information (APP 3)
• Informing students that their data may be processed by AI providers located overseas (see Section 11) as part of the contextualization feature
• Ensuring that student data uploaded to the Platform is accurate and up to date
• Complying with all applicable privacy laws in relation to the learner data you control

10.4 AI Processing of Student Data

11. AI Data Handling and Governance

11.1 How AI-Generated Content Is Produced

RTOFlow uses multiple third-party large language model (LLM) providers to generate training and assessment content. When you initiate a content generation request:

1. The Platform constructs a prompt containing training package requirements, organisational context, and - where the contextualization feature is used - relevant learner data.
2. The prompt is sent to one or more AI providers via encrypted API connections (TLS 1.2+).
3. The AI provider processes the prompt and returns generated text.
4. RTOFlow stores the generated content in its own infrastructure; AI providers do not retain the content after processing.

11.2 AI Provider Data Handling

We use AI providers under enterprise or API agreements that include the following protections:

• No model training: Customer data sent to AI providers is not used for training, fine-tuning, or improving their models.
• No data retention: AI providers process data transiently and do not retain input prompts or output content beyond the processing window (typically seconds to minutes).
• Data minimisation: We minimise the personal information included in prompts. Where possible, we use de-identified or pseudonymised data.

12. Children's Privacy

RTOFlow is a business-to-business platform designed for professional use by organisations. We do not knowingly collect personal information from children under the age of 18. If we become aware that we have collected personal information from a child, we will take steps to delete it promptly.

13. Cross-Border Data Transfers

Some of our third-party service providers are located outside Australia (see Section 5). Before disclosing personal information overseas, we take reasonable steps in accordance with APP 8 to ensure that overseas recipients do not breach the APPs. This includes entering into contractual arrangements requiring overseas processors to handle personal information in accordance with standards substantially similar to the APPs.

Countries to which personal information may be transferred: United States (OpenAI, Anthropic, xAI, Google, Microsoft, Replit, Perplexity, Replicate, Stripe, Resend, AWS, Meta) and Singapore / China (DeepSeek).

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or in-app notification at least 30 days before they take effect. The current version of the Privacy Policy is always available at https://rtoflow.au/privacy.

15. Do Not Track Signals

RTOFlow does not track users across third-party websites and does not respond to Do Not Track (DNT) browser signals. Third-party analytics and advertising services on public pages (see Section 6) are managed by their respective providers; you can opt out through their platform settings or your browser's cookie controls.

16. Third-Party Links

The Platform may contain links to third-party websites (e.g., training.gov.au, payment processors). We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing personal information.

17. Contact and Complaints

For privacy enquiries, data access or correction requests, or to lodge a privacy complaint, please contact:

Privacy Officer
Precision CAD Australia
Trading as RTOFlow

• Email: privacy@rtoflow.au
• Support: support@rtoflow.au
• Website: https://rtoflow.au

We will acknowledge your complaint within 5 Business Days and provide a substantive response within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

• Website: www.oaic.gov.au
• Phone: 1300 363 992