Data Protection

Privacy Policy

How Arcus collects, uses, and protects your personal information. Compliant with GDPR, Australian Privacy Act, and CCPA/CPRA.

Last updated: March 10, 2026

1. Introduction and Data Controller

Arcus Technologies Pty Ltd (ABN pending), operating as Arcus ("we," "our," or "us"), is the data controller responsible for your personal information. We are committed to protecting your privacy in accordance with the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), the EU General Data Protection Regulation (GDPR), and the California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI governance platform, website, and related services (collectively, the "Service"). Our principal place of business is in Melbourne, Victoria, Australia. By accessing or using the Service, you acknowledge that you have read and understand this Privacy Policy.

2. Information We Collect

We collect the following categories of personal information:

Information You Provide Directly

  • Account Information: Name, email address (corporate email required), job title, and organizational affiliation.
  • Organization Data: Company name, country of operation, industry sector, and employee count for compliance assessment purposes.
  • AI System Data: Descriptions, purposes, data types, decision categories, and deployment contexts of the AI systems you register for risk classification.
  • Risk Assessment Responses: Information you provide through the free AI risk screener and penalty calculator tools.
  • Communications: Information you provide when you contact us for support or feedback.

Information Collected Automatically

  • Usage Data: Pages visited, features used, time spent on the platform, and interaction patterns.
  • Device Information: Browser type, operating system, device identifiers, and IP address.
  • Cookies and Similar Technologies: As detailed in Section 6.
  • Log Data: Server logs including access times, pages viewed, and referring URLs.

3. Lawful Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal data on the following legal grounds:

  • Contract Performance (Article 6(1)(b)): Processing necessary to provide the Service you have subscribed to, including AI risk classification, compliance assessment, and document generation.
  • Legitimate Interests (Article 6(1)(f)): Processing for platform security, fraud prevention, service improvement, and aggregate analytics. We have assessed that these interests do not override your fundamental rights.
  • Legal Obligation (Article 6(1)(c)): Processing required to comply with applicable laws, regulations, or legal processes.
  • Consent (Article 6(1)(a)): Where required, such as for marketing communications or optional analytics cookies. You may withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

4. How We Use Your Information

We use the information we collect strictly for the following purposes:

  • To provide, maintain, and improve the Service, including AI risk classification, compliance documentation, and governance analytics.
  • To process and complete AI system risk assessments, generating classification results, applicable regulation references, and compliance recommendations.
  • To create and manage your account, authenticate your identity, and provide customer support.
  • To send service-related notifications, classification alerts, regulation change notifications, and compliance updates.
  • To analyze usage patterns in aggregate to improve user experience, platform performance, and classification confidence.
  • To comply with legal obligations, including EU AI Act and Australian Privacy Act requirements.
  • To detect, prevent, and address technical issues, security vulnerabilities, and fraudulent activity.
  • To generate anonymized, aggregate industry benchmarks (no individual company data is identifiable).

We do NOT use your data to train AI models. Your AI system descriptions and organizational data are processed solely via API calls to generate classifications and are not retained by our AI sub-processor (Anthropic) for training purposes.

5. Data Sharing and Sub-Processors

We do not sell your personal information. We will never sell your personal information. We may share your information in the following limited circumstances:

Service Sub-Processors

  • Supabase Inc. (United States): Cloud database hosting, authentication, and file storage. SOC 2 Type II certified.
  • Anthropic PBC (United States): AI language model processing via Claude API. Data is processed via API and is NOT used for model training per Anthropic's data processing terms.
  • Resend Inc. (United States): Transactional email delivery for notifications and alerts.
  • Stripe Inc. (United States): Payment processing for subscriptions. We do not store your credit card details.

Other Sharing

  • Within Your Organization: Team members within your organization can access shared AI system data, classification results, and compliance documents based on their assigned roles.
  • Government Regulatory Portal: ONLY if you explicitly opt in through the Data Sharing Portal. Sharing is granular (you choose which data types), revocable, and fully audited with an immutable access log.
  • Legal Requirements: We may disclose your information when required by law, regulation, legal process, or governmental request.
  • Business Transfers: In connection with a merger, acquisition, or sale of assets, your information may be transferred. We will notify you before your personal information becomes subject to a different privacy policy.

6. Cookies and Tracking Technologies

We use cookies and similar tracking technologies:

  • Essential Cookies: Required for authentication, session management, and security. These cannot be disabled as they are necessary for the Service to function.
  • Preference Cookies: Store your settings such as theme preference (light/dark mode) and language selection. These can be managed in your account settings.
  • Analytics Cookies: Help us understand how the Service is used and identify areas for improvement. These are only set with your consent. You can opt out of analytics tracking at any time via your account settings or browser settings.

We do NOT use advertising cookies or tracking pixels. You can manage cookie preferences through your browser settings. Disabling essential cookies may affect the functionality of the Service. For EU users, non-essential cookies are only set after you provide explicit consent.

7. Data Retention and Security

Data Retention Periods

  • Active account data is retained for the duration of your subscription.
  • Upon account deletion, personal data is permanently deleted within 30 days.
  • Anonymized usage analytics may be retained indefinitely for service improvement.
  • Audit logs required for regulatory compliance are retained for 7 years.
  • Risk screener/penalty calculator lead data is retained for 12 months, then deleted.
  • Backup data is purged within 90 days of primary deletion.

Data Security Measures

  • All data is encrypted in transit using TLS 1.3 and at rest using AES-256 encryption.
  • Access to personal data is restricted to authorized personnel on a need-to-know basis.
  • Row Level Security (RLS) policies ensure complete data isolation between organizations at the database level — no organization can access another's data.
  • Regular security assessments and vulnerability scanning are conducted.
  • AI system data submitted for classification is processed securely via API and is not stored by our AI provider.
  • All API endpoints are protected by rate limiting and authentication.

While we implement industry-leading security measures, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security but will notify affected users within 72 hours of discovering a data breach, as required by GDPR and the Notifiable Data Breaches scheme under Australian law.

8. International Data Transfers

Your data may be transferred to and processed in countries outside your country of residence, including the United States (where our primary sub-processors Supabase, Anthropic, and Stripe operate). For transfers from the EEA and UK, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission to ensure adequate data protection. For Australian users, these cross-border disclosures are made in compliance with APP 8 of the Australian Privacy Principles. We ensure that all receiving parties are contractually bound to provide protections equivalent to those in the originating jurisdiction. We evaluate the data protection laws of recipient countries and supplement contractual safeguards with technical measures (encryption, pseudonymization) where necessary.

9. Your Rights — GDPR and Australian Privacy Act

Depending on your jurisdiction, you have the following rights regarding your personal information:

Under GDPR (EEA/UK Residents)

  • Right of Access (Art. 15): Request a copy of the personal data we hold about you.
  • Right to Rectification (Art. 16): Request correction of inaccurate or incomplete personal data.
  • Right to Erasure (Art. 17): Request deletion of your personal data, subject to legal retention requirements.
  • Right to Data Portability (Art. 20): Request your data in a structured, commonly used, machine-readable format.
  • Right to Restrict Processing (Art. 18): Request limitation of processing of your personal data.
  • Right to Object (Art. 21): Object to processing based on legitimate interests.
  • Right Related to Automated Decision-Making (Art. 22): Our AI classifications are designed as decision-support tools, not fully automated decisions with legal effects. You always have the right to request human review of any AI-generated classification or assessment.
  • Right to Lodge a Complaint: You may lodge a complaint with your local Data Protection Authority.

Under Australian Privacy Act

  • Right of Access (APP 12): You may request access to the personal information we hold about you.
  • Right of Correction (APP 13): You may request correction of personal information that is inaccurate, out-of-date, incomplete, irrelevant, or misleading.
  • Right to Complain: You may lodge a complaint about our handling of your personal information with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

Timeline: We will respond to all rights requests within 30 days as required by applicable law. Contact: [email protected].

10. Your Rights — CCPA/CPRA (California Residents)

If you are a California resident, you have additional rights under the CCPA/CPRA:

  • Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collection, and the categories of third parties with whom we share your information.
  • Right to Delete: You may request deletion of your personal information, subject to certain exceptions.
  • Right to Opt-Out of Sale: We do not sell personal information. We have not sold personal information in the preceding 12 months.
  • Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.
  • Right to Correct: You may request correction of inaccurate personal information.
  • Right to Limit Use of Sensitive Personal Information: You may direct us to limit the use of sensitive personal information to that which is necessary to perform the Service.

We do not use or disclose sensitive personal information for purposes other than providing the Service. To exercise your California privacy rights, contact us at [email protected]. You may designate an authorized agent to submit requests on your behalf with proper written authorization.

11. Changes and Contact Information

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. We will notify registered users of material changes at least 14 days before they take effect via email. Changes will be posted on this page with an updated revision date.

For questions, concerns, or to exercise your privacy rights, please contact

Data Protection Inquiries: [email protected]

Legal Inquiries: [email protected]

Postal Address: Arcus Technologies Pty Ltd, Melbourne, Victoria, Australia

For GDPR inquiries, you may also contact our Data Protection representative at [email protected].

Committed to Transparency

Questions about your data privacy?

Our team is here to help with any privacy-related questions, data access requests, or concerns about how we handle your information.