Data Privacy & AI Security Standards

At Capistrol, we prioritize the confidentiality of your financial inquiries. Because our Service utilizes advanced Artificial Intelligence and Retrieval-Augmented Generation (RAG), we implement a multi-layered "Privacy-by-Design" architecture to ensure your data remains protected and, where possible, de-identified.

1. Access Controls & Data Handling

Capistrol prepares defensible audit workpapers, so it works with your trust deeds, financial statements, member data, and other source documents in full — not in de-identified or generalized form. Producing an accurate compliance workpaper or audit query response requires exact figures, not approximations. Instead of stripping or generalizing your data, we protect it through access control and encryption:

Workspace-scoped access: Each trust's data lives in its own workspace. Access is governed by role-based memberships (firm staff, trustee/client, or time-limited external submitter access for the current audit engagement only), so only people you've explicitly granted access to a given trust can see its data.
Tax File Numbers and other identifiers: If a document you upload contains a TFN or similar identifier, it is stored under the same access controls and encryption as the rest of your workspace data — it is not scrubbed, since auditors may need it for verification. Where a workflow does not require the identifier, avoid including it.

2. Encryption and Transmission

All data entered into Capistrol is encrypted both in transit (using TLS 1.2+ protocols) and at rest (using AES-256 encryption). This ensures that even in the unlikely event of unauthorized access, your data remains unreadable.

3. Purpose Limitation (No Data Selling)

Your data is used solely to:

Provide accurate, context-aware responses to your queries.
Improve the technical performance and accuracy of our RAG system.

Note: Capistrol does not sell your personal or financial data to third-party brokers or advertisers.

4. Data Retention

Documents you upload (such as trust deeds and financial statements) are parsed and indexed into your trust's private knowledge base so Capistrol can answer questions, cite sources, and generate workpapers with reference to them. This indexed content is retained for as long as your workspace remains active, and is not shared, pooled, or used across other firms' or trusts' workspaces. We do not use your data to train third-party AI models (see Section 5). If you'd like your workspace's data deleted, contact us using the details below and we will action the request in line with our retention and archival procedures.

5. Third-Party Sub-Processors

Capistrol relies on the following categories of sub-processor to operate:

AI providers: Anthropic (Claude), used to generate drafted responses, workpapers, and audit query text; and OpenAI, used solely to generate vector embeddings for document search. Both are used under API terms that prohibit use of your data to train their general-purpose models.
Document processing and search: LlamaParse for parsing uploaded documents, and a self-hosted Qdrant vector database for retrieval — the latter runs on our own infrastructure, not a third party.
Infrastructure and payments: Binary Lane for application hosting, and Stripe for payment processing. Stripe receives billing details only; it does not receive your trust or audit data.

6. Cross-Border Data Storage

Our application infrastructure is hosted with Binary Lane, on servers located in Melbourne, Victoria, Australia. Your data is not stored or processed outside Australia by us, so the cross-border disclosure obligations under Australian Privacy Principle 8 do not apply to our own hosting. Some of our third-party sub-processors (see Section 5) may process data outside Australia as part of providing their services to us; we select providers with contractual safeguards appropriate to that processing.

7. Your Rights Under the Privacy Act 1988 (Cth)

Capistrol is committed to handling personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth). You may request access to, or correction of, personal information we hold about you by contacting us using the details below. If we become aware of a data breach likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches (NDB) scheme.

8. Contact Us

For privacy questions, access/correction requests, or to lodge a complaint, contact Capistrol FinTech / ABN 27 353 663 124 / perumaal.k@gmail.com. If you are not satisfied with our response, you may lodge a complaint with the OAIC at oaic.gov.au.