Privacy

Privacy

How we collect, use, disclose and protect personal information — for visitors to this site, for the people who use the product, and for the personal information that may sit inside the documents our customers send us.

1. Overview

1.1 TNX Data Pty Ltd (ACN 696 783 463) of 40/2 Park St, Sydney NSW 2000 (“TNX”, “we”, “us”) publishes tnxdata.com (the “Website”) and provides the TNX platform (the “Services”). This Policy explains what personal information we collect, how we use it, and the choices you have.

1.2 Our role differs depending on whose information it is. For personal information about Website visitors and individuals who use the Services, TNX is the controller. For Customer Data that our business customers submit to the Services, which may contain personal information about their own investors, staff, or advisers, TNX acts as a processor on that customer’s instructions, under the Data Processing Addendum, which forms part of our Terms of Service. Where this Policy and the Data Processing Addendum differ on Customer Data, the Data Processing Addendum governs.

1.3 This Policy is informed by the Australian Privacy Principles under the Privacy Act 1988 (Cth), the EU/UK General Data Protection Regulation, and the California Consumer Privacy Act.

1.4 We may update this Policy from time to time. Material changes will be notified by email or by notice on the Website before they take effect.

2. Collection of personal information

2.1 We collect information that identifies you — name, role, organisation, work email, and phone number. We do not collect biometric data or device geolocation, and have no facility to do so.

2.2 We collect this information when you: submit the Website contact form; are provisioned an account by your organisation or by us; use the Services; correspond with us; or send documents to a TNX intake address. Documents sent for processing may themselves contain personal information, which we handle as a processor (see clause 1.2).

2.3 We also collect standard web analytics (pages visited, referring site, browser type, IP address) through Google Analytics. The Website sets no cookies unless you accept them when first asked; if you accept, we load Google Analytics to see which pages are read, and if you decline, nothing is loaded and the only thing stored in your browser is your preference, so we don’t ask again. We do not use advertising cookies and do not track you across other websites.

2.4 We do not seek sensitive personal information (health, political opinions, religious beliefs, sexual orientation, racial or ethnic origin) and ask that you not submit it to us other than where it appears incidentally within documents you send for processing.

2.5 We use personal information only to: provide and administer the Services; respond to enquiries; send service messages; maintain the authorship and change records the Services are designed to produce; secure and improve the Services; and meet legal obligations.

3. Use of data for AI and analytics

3.1 Models used by the Services are invoked within the same regional deployment as the rest of that deployment, through a managed model service within our cloud provider’s environment; content is not used to train third-party models; figures are extracted by deterministic rules rather than generated by a model.

3.2 TNX may process data collected through the Services, including Customer Data, using de-identification techniques for purposes including improving the Services, developing new features, and generating aggregated insights.

4. Where your data is processed

4.1 Customer Data is processed only in the region agreed with the customer (for example Australia, the United Kingdom, the United States, or Canada). Each region is a separate deployment with its own storage, database, encryption keys, identity provider, and application — and Customer Data is not copied or synchronised between regions. Access is restricted geographically at the network edge.

4.2 Some personal information is not part of the core Services and is instead part of running the business itself, for example, contact details of Authorised Users used for billing and support, and the provider that delivers our email. That limited business-operations data may be processed outside the customer’s region. Where that happens, we put appropriate safeguards in place, including standard contractual clauses where required, and will describe them on request.

5. Storage and security

5.1 We maintain technical and organisational measures designed to protect personal information against unauthorised access, disclosure, alteration, or loss. No method of transmission or storage is completely secure, and we do not guarantee absolute security.

5.2 If a data breach is likely to result in serious harm, we will notify the Office of the Australian Information Commissioner and affected individuals as required under the Notifiable Data Breaches scheme. Where the GDPR or UK GDPR applies, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, and affected individuals where required. Where we act as a processor for a business customer, we will notify that customer without undue delay.

5.3 If you become aware of any unauthorised use of your personal information in connection with the Website, contact hello@tnxdata.com and we will investigate.

6. Disclosure of personal information

6.1 We disclose personal information only where needed to provide the Services, and only to: TNX Group entities; sub-processors we engage to operate the Services (cloud infrastructure, email delivery, error monitoring), each bound by terms no less protective than the Data Processing Addendum; and professional advisers or regulators where required by law. Website analytics are provided by Google under Google’s data processing terms. Our current sub-processor list is available on request.

6.2 We do not sell personal information. We do not share it with third parties for targeted advertising or marketing purposes.

7. Your rights

7.1 Subject to applicable law, you may: access the personal information we hold about you; request correction; request deletion; object to or request restriction of processing; request portability; and withdraw consent where processing relies on it.

7.2 To exercise any of these rights, email hello@tnxdata.com. We may ask you to verify your identity before acting on a request, and will explain our reasons if we decline a request.

8. Children’s privacy

8.1 The Website and Services are directed to businesses and the people who work for them, not to children. We do not knowingly collect personal information from children. If you believe a child has provided personal information to us, contact hello@tnxdata.com and we will delete it.

9. California residents

9.1 If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, “CCPA”), gives you rights to know, access, correct, and delete your personal information, and to opt out of the sale or sharing of personal information. TNX does not sell personal information and does not share it for cross-context behavioural advertising.

9.2 Regulations under the CCPA that took effect 1 January 2026 expanded requirements around automated decision-making technology, cybersecurity audits, and risk assessments for businesses that meet the applicable thresholds, and extended how far back a consumer’s access request must reach.

9.3 To exercise CCPA rights or ask a question, email hello@tnxdata.com. We will not discriminate against you for exercising these rights.

10. European and UK residents

10.1 If you are in the European Union or United Kingdom, TNX processes personal information in accordance with the GDPR / UK GDPR. Our legal basis depends on context: consent, performance of a contract, a legal obligation, or a legitimate interest that does not override your rights. You may contact hello@tnxdata.com with any question about the basis for processing your information.

11. Contact us

11.1 For any question about this Policy, or to exercise a right described above, email hello@tnxdata.com.

How our security works

The controls behind all of this — where data is held, how it is encrypted, and the record we keep of changes to it — are described on our security page.

Last updated 17 September 2026