Privacy Policy
This Privacy Policy explains how ALS Global Holding Pty Ltd (ACN 697 094 867, ABN 15 697 094 867) trading as transpera.ai ("transpera", "we", "us", "our") collects, holds, uses and discloses personal information, and how you can contact us about it.
1. Who we are and how this policy applies
transpera builds and operates artificial intelligence (AI) tools and automations for agencies and consulting firms. We are based in Melbourne, Australia.
We handle personal information consistently with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Our Privacy Officer is Austin Smith, who can be contacted at austin@transpera.ai or by post at 4 Sulky Court, Endeavour Hills VIC 3802, Australia.
This policy applies to personal information we collect through our website (transpera.ai), in the course of providing services to our clients, and in running our business. Where we process personal information on behalf of a client under a services agreement, that agreement and the client's own privacy policy also govern how the information is handled.
2. What personal information we collect
The kinds of personal information we collect depend on how you interact with us. They may include:
Identity and contact information: your name, organisation, role, email address, phone number and postal address.
Enquiry and correspondence information: the content of messages, forms and meetings, and any information you provide when engaging our services.
Technical and usage information: IP address, browser and device information, pages visited and interaction data collected through cookies and analytics tools.
Client-supplied information: personal information contained in documents, datasets, systems or communications that a client provides to us so that we can build, configure, test or operate AI tools for them. This may include information about the client's own customers, staff or contacts.
AI-generated information: information that an AI tool produces or infers about an identifiable person during the delivery of our services (see section 5).
We do not seek to collect sensitive information (such as health information, racial or ethnic origin, or political opinions) unless it is reasonably necessary for a specific engagement and the client confirms that the required consents have been obtained. If sensitive information is included in client-supplied material, we handle it in accordance with the client's instructions and this policy.
Where it is lawful and practicable, you may deal with us anonymously or using a pseudonym, for example when making a general enquiry.
3. How we collect personal information
We collect personal information directly from you when you contact us, fill in a form on our website, subscribe to communications or engage our services. We collect information from our clients when they provide it to us for an engagement. We collect technical information automatically through our website and the third-party analytics and hosting services it uses.
If we receive personal information we did not ask for and could not lawfully have collected, we will destroy or de-identify it as soon as practicable, unless the law requires us to keep it.
4. Why we collect, use and disclose personal information
We collect, hold, use and disclose personal information for the following purposes:
to respond to your enquiries and communicate with you;
to scope, deliver, support and improve our services for clients, including building, testing and operating AI tools;
to manage our relationship with clients, including invoicing, contract administration and account management;
to operate, secure and improve our website and internal systems;
to send you information about our services and related content that we think may interest you, where you have agreed or would reasonably expect it (you can opt out at any time; see section 9);
to comply with our legal obligations, including responding to lawful requests from regulators and law enforcement; and
for other purposes that you would reasonably expect, that you have consented to, or that are otherwise permitted or required by law.
5. How we use artificial intelligence
AI is central to what we do. This section explains how personal information may be processed by AI tools and what protections apply.
5.1 Third-party AI providers
We build and operate tools that use large language models and other AI services supplied by third-party providers. Depending on the engagement, these providers currently include OpenAI, Anthropic and Google, and may include other model, voice, automation or hosting providers identified in the relevant client agreement (together, "AI Providers"). Personal information may be included in prompts, documents, datasets or system integrations processed by these tools in order to deliver our services, operate our own business systems, and test and quality-assure our work.
We access AI Providers under business, enterprise or API terms that prohibit the provider from using the information we submit to train or improve its models, and that limit how long the provider retains that information. We do not enter personal information into consumer-grade or publicly available AI tools that do not offer these protections.
5.2 No training on your information
We do not use personal information we hold for clients to train or fine-tune our own models, and we do not permit AI Providers to do so, unless the client has expressly authorised it in writing and the individuals concerned have been notified or have consented as required by law.
5.3 AI-generated and inferred information
Information that an AI tool generates or infers about an identifiable person (including summaries, classifications, scores and recommendations) is treated as personal information and is subject to this policy. AI outputs can be incomplete or inaccurate. We take reasonable steps to ensure that AI-generated personal information we rely on is accurate, and we destroy or de-identify AI-generated personal information that we are not permitted or do not need to hold.
5.4 Interacting with AI systems
Where a tool we operate interacts with you directly (for example a chatbot or voice assistant), we identify it as an AI system so that you know you are not communicating with a person.
6. Automated decision-making
This section describes our use of computer programs, including AI, to make or assist in making decisions that could reasonably be expected to significantly affect the rights or interests of individuals. It is provided in line with the transparency requirements of Australian Privacy Principle 1, which apply from 10 December 2026.
Kinds of personal information used: [Edit to match your inventory — e.g. contact and identity details; enquiry and correspondence content; website usage and interaction data; job application information; client-supplied customer records as described in the relevant engagement.]
Decisions made solely by a computer program (no human involvement): [Edit — e.g. "None at present." or list them, such as automatic routing of enquiries.]
Decisions where a computer program does something substantially and directly related to the decision, with a person making the final decision: [Edit — e.g. scoring and prioritising sales leads; shortlisting candidates for roles we advertise; recommending pricing or scope for proposals.]
A person reviews these decisions before they take effect. If a decision we make with the help of an automated process affects you, you may ask us to explain it or to have it reviewed by a person by contacting our Privacy Officer.
Where we build automated tools for clients, the client determines how those tools are used and is responsible for describing any automated decision-making in its own privacy policy. We provide clients with the information they need to do so.
7. Who we disclose personal information to
We may disclose personal information to:
AI Providers and other service providers that help us operate our business and deliver our services, such as cloud hosting, productivity, communication, analytics, payment and customer-relationship platforms;
our clients, in respect of information relating to the engagement we are performing for them;
professional advisers, including lawyers, accountants and insurers;
regulators, law enforcement agencies and other authorities where we are required or permitted to do so by law; and
any person you have authorised us to disclose it to.
We require service providers to protect personal information and to use it only for the purposes for which we disclose it.
7.1 Overseas disclosure
Some of our AI Providers and other service providers store or process information outside Australia, principally in the United States. We are therefore likely to disclose personal information to recipients in the United States and, depending on the providers used for a particular engagement, other countries identified in the relevant client agreement. Before doing so, we take reasonable steps, including contractual protections and provider due diligence, to ensure that the recipient handles the information in a way that is consistent with the APPs. Where a client requires that information be processed only in Australia, we will use Australian-region services where they are available and will record this in the engagement terms.
8. Security, retention and data breaches
We take reasonable technical and organisational steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure. These include encryption of information in transit and at rest, access controls and multi-factor authentication, logging and monitoring, due diligence on AI Providers and other vendors, staff training, and defined retention periods for prompts, logs, datasets and AI outputs.
We keep personal information only for as long as it is reasonably necessary for the purposes described in this policy or as required by law. Client-supplied information, including prompt logs and retrieval or vector stores created for an engagement, is deleted or returned in accordance with the client agreement, ordinarily within 30 days of the engagement ending. When personal information is no longer needed, we take reasonable steps to destroy or de-identify it.
If a data breach involving personal information is likely to result in serious harm to any individual, we will notify the affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme. Where we hold information on behalf of a client, our agreement with the client sets out which of us is responsible for assessment and notification, and we will cooperate with the client to respond to the breach.
9. Direct marketing
We may send you information about our services and related content where you have consented, where you would reasonably expect it, or where otherwise permitted by the Spam Act 2003 (Cth) and the Privacy Act. Every marketing message we send identifies us and includes a way to unsubscribe. You may opt out at any time by using the unsubscribe link in any message or by contacting us; we will action your request within 5 business days.
10. Cookies and analytics
Our website uses cookies and similar technologies, including third-party analytics services, to understand how the site is used and to improve it. You can control cookies through your browser settings. Disabling cookies may affect some features of the website.
11. Access, correction and complaints
You may request access to the personal information we hold about you, or ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Contact our Privacy Officer using the details in section 12. We will respond within 30 days. We do not charge for making a request, but may charge a reasonable fee for providing access in some circumstances. If we refuse a request, we will give you written reasons and information about how to complain.
If you believe we have mishandled your personal information or breached the APPs, please contact our Privacy Officer. We will acknowledge your complaint within 7 days and aim to resolve it within 30 days. If you are not satisfied with our response, you may complain to the OAIC at www.oaic.gov.au or by calling 1300 363 992.
12. Contact us
Privacy Officer: Austin Smith
Email: austin@transpera.ai
Post: ALS Global Holding Pty Ltd (ACN 697 094 867, ABN 15 697 094 867) trading as transpera.ai, 4 Sulky Court, Endeavour Hills VIC 3802, Australia
13. Changes to this policy
We may update this policy from time to time. The current version is always available at transpera.ai/legal/privacy-policy and shows the date it was last updated. Material changes will be highlighted on our website.