Privacy Policy

Version 2.0 · Last updated 26 May 2026 · Drawn Mind Solutions Pty Ltd · ACN TBA · Brisbane, Australia

Read alongside our Terms of Service, Sub-processor list, and Data Processing Agreement template.

1. About this policy

Drawn Mind Solutions Pty Ltd (“Drawn”, “we”) is bound by the Privacy Act 1988 (Cth) and the 13 Australian Privacy Principles (APPs). This policy is our APP 1.3 statement of how we manage personal information. It applies to every visitor, prospect, and customer of the Drawn platform.

Complaints process: if you believe Drawn has breached the APPs or this policy, email privacy@drawn.com.au with the subject line “Privacy complaint”. We will acknowledge your complaint within 5 business days, investigate, and provide a written response within 30 days. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) on 1300 363 992.

Policy versioning: this is version 2.0, effective 26 May 2026. Prior versions are available on request from privacy@drawn.com.au.

2. Anonymity & pseudonymity (APP 2)

Where lawful and practicable, you may deal with Drawn anonymously or under a pseudonym:

  • You can browse the Drawn marketing site without identifying yourself.
  • You can ask general questions of our team via privacy@drawn.com.au using a pseudonymous email if you prefer.
  • You cannot create a Drawn account anonymously — the product is bound to a real ABN-registered business so we can comply with contractual, tax, and Privacy Act record-keeping obligations. This is the “not practicable” carve-out under APP 2.1(b).
  • Callers into a connected voice agent are identified by phone number, which Drawn stores as an HMAC-SHA-256 hash by default — a pseudonymous identifier, not the raw number.

3. What Drawn collects

Drawn collects four classes of data:

  • Account data: business name, ABN, owner contact details, billing email, time-zone, industry.
  • Phone-call data: full call audio (from your connected voice provider), call transcripts, call metadata (caller phone in HMAC-hashed form, duration, timestamps), AI-generated summaries, sentiment classifications, and extracted business facts.
  • Knowledge facts: structured facts Drawn learns from your calls, chats, and uploaded documents. Each fact is anchored to your business and never shared with another customer.
  • Behavioural signals: how you interact with the dashboard, used to shape Drawn’s UX to your habits.

Why we collect this (APP 3.2): each class above is reasonably necessary for Drawn to perform the service you have asked us for. We collect only the minimum needed.

Sensitive information (APP 3.3): Drawn does not solicit sensitive information (health, racial or ethnic origin, religious beliefs, sexual orientation, criminal record, biometrics). In practice, a connected voice agent may incidentally capture sensitive information when a caller discloses it. Where this happens we treat that information as sensitive under the APPs — same encryption, same isolation, never used for industry aggregation, and de-identified on the retention TTL. If you operate in a sensitive-data industry, you must obtain caller consent to recording and to Drawn’s processing as part of your own opening disclosure — Drawn does not collect that consent on your behalf.

Data from connected systems (APP 3.6): when you connect a third-party system (Retell, Twilio, a Supabase database), Drawn collects personal information about your customers from that system. You warrant that you have an APP 5- compliant collection notice in place authorising that onward disclosure to Drawn and our sub-processors, and you agree to update your own privacy policy to name Drawn and Anthropic as additional processors before activating the connector. The connector wizard records your written confirmation.

4. Unsolicited personal information (APP 4)

If Drawn receives personal information that we did not ask for — for example, a connected database returns a table we didn’t request, or a support email contains a customer list we have no need for — we will assess within a reasonable time whether we could have collected it lawfully under APP 3. If we could not, we destroy or de-identify it as soon as practicable. If we could, we treat it as if it had been solicited. The generic Supabase connector samples only the tables you nominate; tables outside that nomination are never read.

5. Collection notice (APP 5)

This is Drawn’s standing APP 5 collection notice. It applies every time Drawn collects personal information from you, your business, or from a connected system:

  • Who we are: Drawn Mind Solutions Pty Ltd, an Australian proprietary company. Contact privacy@drawn.com.au.
  • How we collect: directly from you on sign-up; from connected voice providers when calls are received; from connected databases when a sync runs; from documents you upload; from dashboard interactions.
  • Whether collection is required by law: no. You provide information voluntarily; without it, we cannot deliver the service.
  • Purposes: see §6 below.
  • Consequences of not providing: we cannot create your account, ingest calls, or generate briefings.
  • Usual disclosures: to our sub-processors listed in §13, to any successor entity on a corporate sale, and as required by Australian law.
  • Overseas disclosures: to Anthropic PBC (United States) for AI inference — see §8.

6. Use & disclosure (APP 6)

Primary purpose. Drawn uses your personal information to deliver the service you signed up for: answering and analysing your calls, learning facts about your business, generating briefings, and reshaping your dashboard to your habits.

  • Extracts structured facts about your business, stored in your isolated knowledge graph.
  • Generates briefings, summaries, and chat answers grounded in your own data.
  • Reflects nightly to identify patterns, supersede stale facts, and reshape your dashboard.

Secondary use — industry aggregation (consent-based). Drawn can contribute anonymised, redacted patterns from your data to an industry-wide layer so other businesses in your category inherit useful defaults. This is a use related to but not the same as the primary purpose. We rely on your consent under APP 6.1(a):

  • The aggregation toggle is presented on first sign-in and you must actively choose. The default is OFF until you choose.
  • You can change the setting any time at Settings → Security → Aggregation. The opt-out is enforced in the nightly aggregator cron.
  • Identifiable rows never leave your account. Only counts and statistical summaries computed across ≥5 contributing businesses are emitted.

Other disclosures (APP 6.2). We will only disclose your personal information beyond the sub-processors listed in §13 where: (a) you have consented; (b) a secondary purpose is directly related to the primary and you would reasonably expect it; (c) it is required or authorised by Australian law; or (d) a permitted general situation under s16A of the Act applies.

No selling. Drawn does not sell personal information.

7. Direct marketing (APP 7 + Spam Act 2003)

Drawn sends two kinds of email:

  • Transactional — briefings you asked for, security notices, billing receipts, password resets. Part of the service; can’t be unsubscribed without closing your account.
  • Marketing — invitations to join when your industry opens, product announcements, customer-research outreach. Every marketing email contains a one-click unsubscribe link as required by the Spam Act 2003 (Cth) and APP 7.3.

Email privacy@drawn.com.au with “unsubscribe” in the subject line and we will remove you from all marketing within 5 business days. On request we will tell you the source of your contact details (APP 7.5).

8. Cross-border disclosure (APP 8)

Drawn hosts your data in Australia where possible. Your Supabase project sits in ap-southeast-2 (Sydney). Static-asset edge caches sit on Vercel’s global network; persistent customer data doesn’t flow through those caches.

Personal information leaves Australia in one circumstance: when Drawn sends a call transcript, uploaded document, chat message, or sampled connector row to Anthropic PBC’s inference API in the United States. The request body is in transit there for the seconds it takes to receive the response, then dropped. Anthropic’s contractual commitment is not to train on customer API inputs by default — verify directly at anthropic.com/legal.

Accountability under APP 8.1. Drawn remains accountable for Anthropic’s acts and practices in relation to your personal information as if Drawn had performed them ourselves. The steps we have taken: (a) using Anthropic’s Commercial Terms which include data-processing commitments materially equivalent to the APPs; (b) using only the API tier with the no-training default; (c) sending only the minimum text needed for each request; (d) not sending raw caller phone numbers; (e) maintaining the right to a written DPA on request.

No other overseas recipients. Supabase is configured AU-region; Vercel’s edge proxy touches request bodies in transit only (no persistent storage of customer content); Retell / Twilio data stays with that provider under your direct contract with them.

9. Government-related identifiers (APP 9)

Drawn collects your ABN to verify that the account belongs to a real Australian business and for tax-invoice purposes. Drawn does not adopt your ABN as our own identifier for you (we use an internal account UUID instead) and does not disclose your ABN except to our payment processor and as required by Australian tax law. Drawn does not collect TFN, Medicare, driver-licence, or passport numbers.

10. Data quality (APP 10)

Drawn takes reasonable steps to keep personal information accurate, up-to-date, complete, and relevant:

  • Every fact Drawn learns is shown on the “What Drawn Knows” page with its source and confidence level. You can correct or delete any fact directly.
  • Superseded facts retain audit-trail metadata (who corrected, when, with what value).
  • Drawn’s reflection cron runs nightly and demotes facts that contradict newer information.
  • For information disclosed to a sub-processor, corrections you make are reflected on the next request.
  • If you spot inaccurate information about a third party, edit it on the call detail page or email privacy@drawn.com.au and we will correct within 5 business days.

11. Security & data breaches (APP 11 + Part IIIC)

Drawn takes reasonable steps under APP 11.1 to protect personal information:

  • TLS 1.2+ on every endpoint.
  • AES-256-GCM at-rest encryption on connector credentials.
  • Caller phone numbers stored as HMAC-SHA-256 hashes by default.
  • Row-level security on every customer-data table — enforced at the database layer.
  • Service-role keys held server-side only.
  • Security headers (CSP, HSTS, X-Frame-Options DENY, Permissions-Policy) on every response.
  • Rate limits on export, deletion, and connector endpoints.

Destruction & de-identification (APP 11.2). When Drawn no longer needs personal information for any permitted purpose, we destroy or de-identify it per the retention schedule in §14. Disconnecting a connector additionally soft-deletes every fact extracted from that connector; the next retention cron sweeps them.

Notifiable Data Breaches (Part IIIC). If Drawn becomes aware of an eligible data breach — unauthorised access or disclosure of personal information likely to result in serious harm — we will: (a) contain it; (b) assess within 30 days whether the “serious harm” threshold is met; (c) notify the OAIC and every affected individual as soon as practicable, by email and in-dashboard banner, with the matters required by s26WK of the Act. We maintain a written incident- response runbook available on request as part of a customer DPA.

12. Cookies & local storage

Drawn uses the minimum browser storage needed to keep you signed in. We do not use advertising cookies, analytics cookies, social-media tracking pixels, or any third-party behavioural tracker.

First-party cookies (strictly necessary):

  • sb-<project>-auth-token — your signed JWT, keeps you logged in. HttpOnly, Secure, SameSite=Lax. Expires after ~1 hour; renewed silently.
  • sb-<project>-refresh-token — silent session renewal. Same flags. 7-day inactivity expiry.

Local storage (never transmitted to Drawn):

  • Your light/dark theme preference
  • Your business logo (preview only — never POSTed)
  • “Dismissed banner” UI state

Trackers we explicitly do NOT use:

  • Google Analytics / GA4 / Tag Manager
  • PostHog / Mixpanel / Amplitude / Heap / Segment
  • Hotjar / FullStory / LogRocket session replay
  • Facebook / LinkedIn / Twitter advertising pixels
  • Vercel Analytics or Speed Insights
  • Any third-party A/B testing or feature-flag service

The only external content your browser loads while using Drawn: Google Fonts (Geist typeface) and call-recording audio from your voice provider’s CDN (e.g. Retell’s CloudFront) when you open a call detail panel. When you sign out, cookies are deleted server-side. When you delete your account, every cookie association is severed.

13. Sub-processors

Drawn uses these third-party services to process your data. Each is contractually bound to handle the data only on Drawn’s instructions. A version-pinned list lives at /legal/sub-processors.

  • Supabase — primary database + authentication. Project hosted in ap-southeast-2 (Sydney). Row-level security on every customer-data table.
  • Anthropic PBC (USA) — AI model provider (Claude). Receives transcripts, uploaded documents, chat messages, and sampled connector rows for the duration of each request. No training on API inputs by default.
  • Retell / Twilio / similar voice providers — only when you connect one. The provider holds the audio + transcript; we read it via their API.
  • Vercel— hosting + edge proxy. Executes Drawn’s server code and proxies every request to Supabase/Anthropic; request bodies pass through Vercel’s network for the milliseconds it takes to serve the response. Vercel retains short-lived request logs (1-7 days) for operational debugging but does not persistently store customer content.

We will notify you at least 30 days before adding a new sub-processor that processes customer content. If you reasonably object on data-protection grounds, you may terminate this agreement and receive a pro-rata refund of pre-paid fees.

14. How long Drawn keeps it (retention)

  • Call transcripts: 6 months, then de-identified.
  • Call records (timestamps, duration, outcome): 12 months, then hard-deleted.
  • Knowledge facts: kept for the life of the account. Superseded facts retain audit-trail metadata.
  • Facts derived from a connected database: retained while the connection is active. On disconnect, de-activated immediately and hard-deleted on the next retention pass (≤24h).
  • Behavioural signals: 30 days, then aggregated into preferences; raw rows discarded.
  • Interest-list submissions: 24 months from submission if not converted, then hard-deleted.
  • Account export downloads: not stored — generated on demand.

Retention TTLs are enforced by a nightly cron job. The cron’s code is reviewable; ask for the deployment log if you need it for an audit.

15. Your rights (APP 12 + APP 13 + GDPR-equivalent)

  • Access (APP 12) — every row Drawn holds about you is downloadable from Settings → Security → Export My Data, as a single JSON file. No request, no waiting. If self-serve fails, email privacy@drawn.com.au — we respond within 30 days as required by APP 12.4. If we refuse access (e.g. it would unreasonably impact another person under APP 12.3), we give you written reasons and your APP 12.10 complaint options.
  • Correct (APP 13)— every fact can be corrected or deleted directly on the “What Drawn Knows” page. Correction is free of charge. If we have previously disclosed the information to a sub-processor and you ask us to notify them of the correction, we take reasonable steps under APP 13.2(b). If we refuse, we give written reasons and, on request, attach a statement to the record under APP 13.4.
  • Delete — Settings → Security → Delete Account schedules a 30-day soft-delete with a cancellation window. After 30 days every row is hard-deleted from active systems, every connected integration is disconnected, and your contributions to the industry layer (if opted in) are removed from the aggregate.
  • Object — to industry aggregation at any time, via Settings → Security → Aggregation opt-out.
  • Complain — to us at privacy@drawn.com.au; if unresolved, to the OAIC.

16. Healthcare + financial-services customers

If you are a registered health practitioner (AHPRA-bound) or registered tax agent (TASA-bound), additional obligations apply to the data you hand Drawn. Drawn’s base posture supports both regimes — RLS isolation, retention TTLs, audit-trailed corrections, encryption at rest. For a written addendum mapping Drawn’s controls against your specific regulator, email privacy@drawn.com.au. We’ll send you the AHPRA / TASA / Privacy Act addendum and arrange a written DPA before you sign.

17. Changes to this policy

We’ll email you and post a notice in the dashboard at least 14 days before any material change to this policy takes effect. Non-material changes (typos, link fixes) we’ll just push. Each version is numbered and dated at the top of this page; superseded versions are retained on request so you can see exactly what changed and when.

18. Contact

Privacy questions, DPA requests, complaints: privacy@drawn.com.au. Anything else: hello@drawn.com.au.