Privacy Policy — Commission Intelligence
1. Who we are
Commission Intelligence is a commission reconciliation tool for mortgage brokers, operated by Yoursoftware Pty Ltd. Contact: privacy@yoursoftware.com.au.
2. What the product does
Commission Intelligence reconciles the commission statements you receive from your aggregator against your own records: it imports a statement, matches each line to a loan, and shows you what is missing, late, underpaid, or clawed back.
3. What we collect, and where it is held
| Information | Where it is held | Can we read it? |
|---|---|---|
| Commission records, loan references, settlement amounts, and the client names attached to them by your aggregator's statement — your whole saved workspace | Our servers (Microsoft Azure, Australia East): Blob Storage for the saved workspace
(encrypted at rest, keys held in Azure Key Vault) with its details in a PostgreSQL database.
A working copy is also kept in your browser (ci_broker_<your broker code>) |
Technically yes — the platform holds the encryption key. Each account can read only its own workspace. The previous 5 saved versions are kept so a bad save can be undone |
| Your broker name, broker code(s), targets and settings | Saved with your workspace (above) and in your browser's local storage | Technically yes, as above |
| Account details — name, email address, a password verifier and an access-PIN verifier (never the password or PIN itself) | Our servers (Microsoft Azure, Australia East), PostgreSQL | Yes |
| Questions you type into the in-product AI assistant, and the figures needed to answer them | Sent to our AI provider to generate a response; not retained by us | In transit only |
4. Why we collect it
Account details are collected to authenticate you and keep your data separate from other users'. Everything else is processed to provide the reconciliation function you asked for. We do not use your commission data or your clients' information to train any model, and we do not sell it or disclose it for marketing.
5. Client information
Your aggregator's statements contain the names of your clients. That information is yours and your brokerage's, and your obligations to those clients under the Privacy Act 1988 (Cth) and the National Consumer Credit Protection Act 2009 (Cth) continue to apply. We hold the saved workspace on your behalf to provide the product. We do not disclose it to anyone else, do not use it for our own purposes and do not use it to train any model. A request from one of your clients about their information should go to your brokerage in the first instance; we will help you respond to it from the saved workspace if asked.
6. Who else is involved
We use a small number of service providers. The current list, what each one does, and where each is located is published at sub-processors.html and is kept up to date.
Two of them are outside Australia:
| Provider | Purpose | Country |
|---|---|---|
| Anthropic PBC | Generates responses for the in-product AI assistant | United States |
| GitHub, Inc. | Source control and deployment pipeline (no customer data) | United States |
Sending information overseas engages Australian Privacy Principle 8. Where we disclose personal information to an overseas recipient, we remain accountable for how it is handled.
7. Security
Access to your account requires authentication. Data held on our servers is encrypted in transit and at rest. Our security posture, the standards we work to, and how to report a vulnerability are set out at security.html.
Your saved workspace is encrypted at rest and each account can read only its own. Separately, a working copy of your workspace is kept in your browser while you use the product, so its security also depends on your device: anyone with access to your unlocked device and browser profile can read that copy. Use a device password and sign out on shared machines. Your access PIN is held on our servers and locks after repeated wrong attempts.
8. Retention and deletion
Your saved workspace stays in your account until you delete it. "Clear all data" in Settings removes the working copy from your browser and, if you leave the option ticked, every saved version from your account as well; it cannot be undone. If you clear only the browser, the saved copy is restored the next time you sign in. Saved versions older than the latest 5 are removed automatically. Account details are retained while your account is open and deleted within 90 days of closure, unless we are required to keep them longer; on closure the saved workspace is deleted with them.
You are responsible for your own record-keeping obligations. Brokers are typically required to retain credit records for seven years under the NCCP. A saved copy in your account is not an archive you can rely on for that: export a backup from Settings and keep it yourself.
9. Accessing and correcting your information
You can see and change everything in your workspace directly in the product. To obtain, correct or have deleted the account details or saved workspace we hold, email privacy@yoursoftware.com.au and we will provide or correct them.
10. Data breaches
If a breach of the information we hold is likely to result in serious harm, we will notify affected individuals and the relevant regulator in line with the Notifiable Data Breaches scheme. Because we hold your saved workspace, a breach of our systems could involve it; that is why it is encrypted at rest and why access to it is restricted to your own account.
11. Changes to this policy
We will publish updated versions at this URL with a revised effective date. Material changes will be notified in the product.
12. Contact and complaints
Email: privacy@yoursoftware.com.au.
We will acknowledge a privacy complaint within 5 business days and respond substantively within 30
days. If your complaint concerns information held by your brokerage rather than by us, we will tell
you and direct you to them.