Prop-CEO

Investor portal

Privacy Policy

1. Who We Are

Prop-CEO is operated by Ethan Kelly (ABN 87 153 967 375), a sole trader based in Queensland, Australia. References to "we", "us", or "our" in this policy refer to Ethan Kelly trading as Prop-CEO.

For privacy-related enquiries, contact: help@prop-ceo.com

2. Information We Collect

2.1 Information You Provide

• Account information: Full name, email address, and password (stored as a bcrypt hash — we never store your plain-text password)
• Property data: Property addresses, purchase prices, loan balances, valuations, and ownership structures you enter
• Financial records: Income entries, expense entries, depreciation schedules, and capital expense records
• Documents: Files you upload (leases, insurance policies, invoices, contracts, and other property documents)
• Subscription information: Billing details collected and stored by our payment processor, Paddle (we do not store your card details)

2.2 Email Inbox Content

If you use the Email Inbox feature, we receive the emails you forward to your private Prop-CEO address, including the sender and recipient addresses, subject line, message text and attachments (for example invoices, receipts and rental statements). We analyse this content using an AI model to propose income and expense records, which you review, edit, approve or discard before anything is added to your records. These emails may contain personal information about other people, such as tenants or agents, so please forward only content you are entitled to share. We use this content only to provide the Service to you and never for advertising.

2.3 Information Collected Automatically

• Usage data: Login timestamps, pages visited, features used, and general interaction patterns
• Device information: Browser type, operating system, and screen resolution
• IP address: Collected for security monitoring and fraud prevention
• Analytics: Aggregated usage statistics via Google Analytics 4 (anonymised)

2.4 Information We Do Not Collect

• We do not collect payment card numbers or full banking details
• We do not collect government identifiers (TFN, Medicare number) unless you voluntarily enter them in notes
• We do not collect biometric data

3. How We Use Your Information

We use your personal information for the following purposes:

• Service delivery: To provide, maintain, and improve the Prop-CEO platform
• Account management: To create and manage your account, authenticate your identity, and provide customer support
• Communications: To send transactional emails (account creation, trial reminders, receipts) and important service announcements
• Security: To detect, investigate, and prevent fraudulent transactions and other illegal activities
• Analytics: To understand how the Service is used and to improve features and performance
• Legal compliance: To comply with applicable Australian laws and regulations

We will not use your information for purposes that are incompatible with those listed above without your consent.

4. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties for marketing purposes. We share information only in the following limited circumstances:

4.1 Service Providers

We share information with trusted third-party service providers who assist in operating Prop-CEO:

• Google Cloud Platform / Firebase (USA) — database storage, file storage, and user authentication. Privacy policy
• Paddle (UK) — subscription and payment processing. Privacy policy
• Postmark (USA) — receives emails forwarded to your private Prop-CEO address and passes them to our systems. Privacy policy
• Anthropic (USA) — AI processing of forwarded emails and attachments to propose income and expense records. Content is sent through Anthropic's API and, under Anthropic's commercial terms, is not used to train its models by default. Privacy policy
• Resend (USA) — transactional email delivery. Privacy policy
• Google Analytics (USA) — anonymised usage analytics. Privacy policy

Each provider is bound by their own privacy commitments.

4.2 Legal Requirements

We may disclose your information if required to do so by law, court order, or government authority, or where we believe disclosure is necessary to protect the rights, property, or safety of Prop-CEO, our users, or others.

4.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of our assets, your information may be transferred to the acquiring entity. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

4.4 With Your Consent

We may share your information with third parties when you explicitly consent to such sharing, such as when you use the "Share access" feature to grant your accountant read-only access to your portfolio data.

5. Data Storage and Security

5.1 Where Your Data is Stored

Your data is stored on Google Cloud Platform infrastructure. Our database and document files are held in Google Cloud's Sydney region (australia-southeast1). Document files are stored in Google Cloud Storage with private access controls.

5.2 Security Measures

We implement industry-standard security measures to protect your data, including:

• Encryption in transit using TLS 1.2 or higher
• Encryption at rest for all stored data
• Password hashing using bcrypt
• JWT-based authentication with secure token handling
• Access controls limiting data access to authorised systems only
• Regular security reviews

5.3 No Guarantee

While we take reasonable steps to protect your information, no internet transmission or electronic storage is 100% secure. We cannot guarantee absolute security of your data.

6. Data Retention

• Active accounts: Data is retained for as long as your account is active
• After cancellation: Data is retained for 30 days after account cancellation or subscription expiry, then permanently deleted
• Email Inbox content: Forwarded emails and attachments are stored in your account as part of your data and follow the retention periods in this section
• Backup retention: Automated backups may be retained for up to 90 days before deletion
• Legal holds: We may retain data longer if required for legal proceedings or regulatory compliance

7. International Data Transfers

Your account data and uploaded documents are stored in Australia (Sydney). Some processing happens outside Australia: our application servers (United States), email handling through Postmark (United States), and AI processing of forwarded emails through Anthropic (United States). By using Prop-CEO, you consent to this processing.

We take steps to ensure adequate protection is in place for any international transfers, including engaging service providers who comply with applicable data protection standards.

8. Your Rights Under the Australian Privacy Principles

Under the Privacy Act 1988 (Cth), you have the following rights:

• Access: You may request a copy of the personal information we hold about you
• Correction: You may request correction of inaccurate or incomplete information
• Deletion: You may request deletion of your personal information, subject to legal retention requirements
• Complaints: You may lodge a privacy complaint with us or with the Office of the Australian Information Commissioner (OAIC)

To exercise any of these rights, email help@prop-ceo.com. We will respond within 30 days.

9. Cookies and Tracking

Prop-CEO uses the following tracking technologies:

• Session storage: Used to maintain your login session during use of the app
• Local storage: Used to store non-sensitive preferences (e.g. dark mode, last viewed screen)
• Google Analytics: Uses cookies to collect anonymised usage statistics. You can opt out via Google's opt-out tool

We do not use advertising cookies or sell data to advertisers.

10. Children's Privacy

Prop-CEO is not directed at children under 18 years of age. We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information, please contact us at help@prop-ceo.com and we will delete it.

11. Third-Party Links

Prop-CEO may contain links to third-party websites. We are not responsible for the privacy practices of those sites. We encourage you to review the privacy policies of any third-party sites you visit.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or by displaying a prominent notice in the app at least 14 days before changes take effect. The "Last updated" date at the top of this page reflects the most recent revision.

Your continued use of Prop-CEO after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

13. Complaints

If you believe we have breached the Australian Privacy Principles, please contact us first at help@prop-ceo.com. We will acknowledge your complaint within 5 business days and aim to resolve it 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: oaic.gov.au
• Phone: 1300 363 992
• Post: GPO Box 5218, Sydney NSW 2001

14. Contact Us

For any privacy-related questions, requests, or complaints:

• Email: help@prop-ceo.com
• Business: Ethan Kelly (ABN 87 153 967 375)
• Location: Queensland, Australia