Utily Privacy Policy
Last updated: 2025-12-07 Operator: Raven Amiatu (ABN 28 271 300 438) — contact: support@utily.me
1. Overview
- This Privacy Policy explains how Utily ("we", "us") collects, uses, discloses, and protects personal information when you use the Service.
- This Policy is designed to align with the Australian Privacy Principles (APPs) and to prepare for GDPR/CCPA readiness for overseas users.
2. What We Collect
- Account data: email, password hash.
- Billing data: payer contact details, plan selection, payment status (via payment provider).
- Service data: uploaded/forwarded utility invoices and derived usage/billing insights.
- Technical data: IP address, timestamps, request metadata, error logs; minimal cookies as described in the Cookie Notice.
- Support communications: messages you send to us.
3. How We Use Data
- Provide and operate the Service, including parsing invoices and generating insights.
- Secure the Service, detect abuse, and debug issues.
- Communicate about your account, updates, and support.
- Improve features (in aggregated or de-identified form where possible).
- Comply with legal obligations and enforce Terms.
4. Legal Bases (GDPR readiness)
- Contract necessity: to provide the Service you request.
- Legitimate interests: service security, fraud prevention, product improvement (balanced against your rights).
- Consent: where required for optional analytics or marketing (not enabled by default).
5. Sharing and Transfers
- Service providers: cloud hosting, email, storage, and analytics vendors bound by confidentiality and data-protection obligations.
- Legal: disclosures required by law, court order, or to protect rights and safety.
- Business transfers: in the event of a merger, acquisition, or asset sale, subject to safeguards.
- Cross-border transfers: we may process data outside Australia. Where required, we will use appropriate safeguards (e.g., SCCs) for EEA/UK data.
5.1 Key Service Providers (Sub-processors)
Utily uses third-party providers to operate the Service. Depending on your region and configuration, these may include:
- Hosting/compute: Fly.io
- Database: Neon (PostgreSQL)
- File storage (S3-compatible): Tigris (via Fly)
- Email ingestion/delivery: Mailgun
- Payments: Stripe
- Caching/queues: Upstash/Redis (and job queue infrastructure)
- Analytics: PostHog
- Error monitoring: Sentry (if enabled)
6. Cookies and Tracking
- See the Cookie Notice for details on cookies and similar technologies.
- Analytics: Utily uses PostHog (a third-party analytics provider) to measure product usage and improve the Service. PostHog may use cookies/localStorage/sessionStorage to recognise returning sessions. We aim to send pseudonymous identifiers (e.g., internal user ID) and avoid sending invoice PDF contents or raw invoice text.
- Operational events: we may send limited system events (e.g., mail ingestion started/succeeded/failed) to help monitor reliability. Where possible, we avoid sending direct identifiers (for example, by hashing inbound recipient addresses).
- No third-party marketing trackers are enabled by default.
- You can disable product analytics in-app (Settings → Data & Privacy). When disabled, analytics events are not sent from that device. Disabling analytics does not automatically delete past analytics events; you can request deletion via support@utily.me.
7. Data Retention
- Account and billing data: kept while your account is active and for a reasonable period thereafter for compliance and record-keeping.
- Invoice data: retained while your account is active. PDF documents and derived artifacts may be retained for model training/quality and service integrity even if you delete invoice records, unless you request full removal and it is technically and legally permissible. Backups may persist until natural rotation.
- Logs: kept for security and diagnostics for a limited period, then deleted or aggregated.
8. Security
- Transport encryption (HTTPS in production), access controls, least-privilege for operations, and monitoring for abuse.
- No system is perfectly secure; notify us promptly of any suspected incident.
9. Your Rights
- Access and correction: request access to or correction of your personal information.
- Deletion: request deletion of your account and associated personal data, subject to legal retention requirements, backups, and any retained documents kept for model training/quality where permissible. If you need full removal of documents/files, contact us to discuss feasibility.
- Objection/Restriction/Portability (GDPR readiness): where applicable, you may object to certain processing, request restriction, or request a copy of your data.
- CCPA/CPRA readiness: California residents may request deletion or information about categories of personal information and may opt out of sale/share (Utily does not sell personal information).
- Submit requests via support@utily.me. We may need to verify identity before responding.
10. Children's Data
- The Service is not directed to children under 16. If you believe a child has provided personal data, contact us to delete it.
11. Data Breaches (APP Notifiable Data Breaches readiness)
- We will assess suspected breaches promptly and, where required, notify affected individuals and regulators in line with the APP Notifiable Data Breaches scheme and any applicable overseas regimes.
12. Changes
- We may update this Policy. Material changes will be notified; continued use after the effective date constitutes acceptance.
13. Contact
- Privacy queries and requests: support@utily.me (or the contact channel listed in the app).