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EmpowerNotes policy

Data Processing Terms

How EmpowerNotes processes customer-controlled personal information.

Effective 24 July 2026Customer organisations and privacy decision-makers

Roles and instructions

For customer content, the customer determines the purposes and authorised use of personal information. EmpowerNotes processes that information to provide the contracted service and on documented customer instructions.

EmpowerNotes will not sell customer content or use it for unrelated advertising.

Processing commitments

  • Maintain confidentiality obligations for personnel with authorised access.
  • Apply technical and organisational security controls appropriate to the risk.
  • Use subprocessors under written obligations and remain responsible for their contracted processing.
  • Assist customers with reasonable privacy requests, security investigations and regulatory enquiries.
  • Return or delete customer content at the end of service, subject to lawful retention and backup cycles.

Cross-border processing

Some subprocessors may process data outside Australia. Customers should assess whether their use and participant notices permit those disclosures. EmpowerNotes will provide available information about relevant processing locations and safeguards.

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