Privacy Policy

1. Overview

Redbark Sync ("we", "our", "the Service") is committed to protecting your privacy and handling your personal information in accordance with the Australian Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and the Consumer Data Right (CDR) rules.

This policy explains what information we collect, how we use it, and your rights regarding your data. Sections 1 to 12 cover Redbark Sync. Section 13 covers Redbark Advisor, our product for financial advice firms and their clients.

2. Information We Collect

Account Information

When you create an account, we collect your name and email address via our authentication provider (Clerk). This information is used to identify you and manage your account.

Banking Data (via CDR)

When you connect a bank account, we access the following data categories under your explicit CDR consent:

• Account details (account name, type, masked account number)
• Account balances
• Transaction history (dates, amounts, descriptions, categories)

REDBARK PTY LTD (ACN 685 364 729), trading as Redbark Labs, is a CDR Representative of Fiskil Pty Ltd (ADR accreditation ADRBNK000246). Fiskil is our CDR Principal and collects and discloses CDR data to Redbark on your behalf under Fiskil's CDR Policy, which we adopt and comply with in accordance with CDR Rule 1.10AA(2)(e). We only access the data categories you have consented to, and only for the duration of your consent (maximum 12 months).

Google Account Data

When you connect Google Sheets, we access your Google Drive (read-only, to list spreadsheets) and Google Sheets (read/write, to sync transaction data). We only access the specific spreadsheets you select.

You Need a Budget Data (via You Need a Budget API)

If you connect You Need a Budget as a destination, we access your account via the You Need a Budget API using OAuth. We request access to your plans and transactions in order to import your bank transactions. We access only the minimum data necessary to provide the sync service:

• Plan names and IDs (to let you select a plan)
• Existing categories and payees (to map incoming transactions)
• Write access to create transactions in your selected plan

Your You Need a Budget OAuth access token is encrypted at rest using AES-256-GCM and is only used to communicate with the You Need a Budget API on your behalf. Transaction data synced to You Need a Budget is transmitted directly and is not permanently stored on our servers. Your You Need a Budget data will not be passed to any third party without your knowledge or consent.

You can disconnect your You Need a Budget account at any time via the Destinations page, which revokes our access and deletes the stored token. If you delete your Redbark account, all You Need a Budget tokens and associated configuration are permanently removed.

Notion Data (via Notion API)

If you connect Notion as a destination, we access your Notion workspace via the Notion API using OAuth. We access only the minimum data necessary to provide the sync service:

• Workspace and database listing (to let you select a database)
• Write access to create entries in your selected database

Your Notion OAuth access token is encrypted at rest using AES-256-GCM and is only used to communicate with the Notion API on your behalf. You can disconnect Notion at any time via the Destinations page, which revokes our access and deletes the stored token.

Airtable Data (via Airtable API)

If you connect Airtable as a destination, we access your Airtable account via the Airtable API using OAuth (with PKCE). We access only the minimum data necessary to provide the sync service:

• Base and table listing for the bases you grant access to (to let you select a table)
• Read and write access to records in your selected table (for deduplication and writing transactions)

Your Airtable OAuth tokens are encrypted at rest using AES-256-GCM and are only used to communicate with the Airtable API on your behalf. You can disconnect Airtable at any time via the Destinations page, which deletes the stored tokens.

Webhook Destinations

If you configure a webhook destination, we send your transaction data to the URL you specify via HTTPS. We do not control or have access to the receiving endpoint. You are responsible for ensuring the security of your webhook URL.

AI Assistants (via MCP)

You can connect Redbark to an AI assistant such as ChatGPT or Claude through our MCP server. When you connect, you approve the access on a Redbark consent screen, and you can revoke it at any time from Settings, API & MCP, Connected apps.

When you ask the assistant a question, it requests data from Redbark on your behalf. Depending on what you ask, this can include account names and balances, transactions (date, description, amount, merchant and category), brokerage holdings, and the status of your syncs. Redbark sends only the data needed to answer that request.

Data sent to an assistant is then handled by that assistant's provider under its own privacy policy, for example OpenAI for ChatGPT and Anthropic for Claude. Redbark does not sell this data, and does not receive or store your conversations with the assistant. Some assistants send a one-line description of the request with each call (for example, "summarise last month's spending"), which we keep in product analytics to improve Redbark. ChatGPT connections do not send this description.

Redbark keeps a record of which tools were called and when, for security and support. It does not keep the banking data returned to the assistant. Banking data is fetched from your bank at the time of the request, subject to the caching described in Data Retention.

Payment Information

Payment processing is handled by Stripe. We do not store your credit card details. Stripe may collect billing information in accordance with their privacy policy.

3. How We Use Your Information

• To provide the transaction synchronisation service you have requested
• To maintain and improve the Service
• To communicate with you about your account and the Service
• To comply with legal obligations, including CDR requirements

We do not use your banking data for any purpose other than providing the synchronisation service. We do not sell or share your personal information with third parties for marketing purposes.

4. Data Storage and Security

Financial data is fetched from the relevant banking or brokerage provider and returned to you or written directly to the destination you configured. No financial payload is persisted to our primary database or our logs. To improve performance and limit repeated provider requests, banking responses may be held in an encrypted-at-rest, per-connection cache hosted on Cloudflare. Fiskil balances are normally refreshed after 4 hours. During temporary provider failures or cooldowns, we may return the last successful live balance for up to 24 hours from when it was observed, without changing its observation time. We do not use this fallback after an authorisation or consent failure. Cached transactions expire within 60 minutes; account details within 15 minutes. Plaid responses are not held in this cache. Cached data is purged when a connection is revoked or deleted, and you can disable and clear this cache under Settings → Performance cache. What we otherwise persist, to run the service, is limited to:

• Account metadata — institution name, account name, account type, currency, and a masked account number (e.g. "xxxx1234") — so the UI can show your connected accounts without re-fetching on every page load.
• CDR consent records — status, purpose, data categories, expiry, and a history of state transitions.
• Encrypted OAuth and banking tokens, encrypted at rest with AES-256-GCM using unique random IVs.
• Sync configuration and execution statistics (record counts and timestamps, never transaction content).
• An audit log of state-changing actions.

All traffic is HTTPS / TLS. Our database is hosted on SOC 2-compliant infrastructure. Access to production systems is restricted and audited. Our error monitoring and logs run through a scrubbing layer that redacts CDR transaction fields, PII, and secrets before events leave the app.

5. Data Retention

• Account information is retained for the duration of your account.
• Banking data access is limited to the duration of your CDR consent (maximum 12 months).
• Cached Fiskil balances are automatically deleted no later than 24 hours after their successful live observation, including when unused. Other cached responses expire within their published cache windows. All cached data is purged immediately when a connection is revoked or deleted or when you disable the performance cache.
• Account metadata and consent records are retained while the underlying consent is active, and deleted when consent is withdrawn through Fiskil's consent dashboard or when you delete your Redbark account.
• Records of AI assistant tool calls (tool name and time, never banking data) are kept in our logs and product analytics under the same retention as other usage data.
• Sync run history (metadata only — record counts and timestamps, never transaction data) is retained for the duration of your account.
• Audit log entries are retained for 7 years to meet our record-keeping obligations under the CDR Rules, and are purged thereafter.
• When you delete your account, all of the above is permanently removed from our systems. Data already written to your own destinations (Google Sheet, YNAB plan, webhook endpoint, etc.) sits in your own accounts with those providers and remains under your control — we do not have the ability to delete it on your behalf.

6. Your Rights

Under Australian privacy law and CDR rules, you have the right to:

• Withdraw consent — Revoke CDR consent at any time through Fiskil's consent dashboard. This immediately stops data access.
• Delete your account — Request complete deletion of your account and all associated data via Settings.
• Access your data — Request a copy of the personal information we hold about you.
• Correct your data — Request correction of any inaccurate personal information.
• Complain — Lodge a complaint with the Office of the Australian Information Commissioner (OAIC) if you believe your privacy has been breached.

7. Third-Party Services

The Service integrates with the following third-party providers:

• Cloudflare — Application hosting, background job execution, edge security, and object storage
• PlanetScale — Managed database hosting
• Clerk — Authentication and account management
• Fiskil — CDR Principal (Accredited Data Recipient, ADRBNK000246). Redbark operates as Fiskil's CDR Representative. See Fiskil's CDR Policy.
• Akahu — New Zealand open banking data access
• Plaid — United States banking connectivity
• SnapTrade — Brokerage account connectivity
• Google — Sheets and Drive API for data synchronisation
• Airtable — Database platform; transaction sync destination via OAuth API
• You Need a Budget — Budgeting platform; transaction sync destination via OAuth API
• Notion — Database platform; transaction sync destination via OAuth API
• Stripe — Payment processing
• Resend — Transactional email delivery
• Loops — Lifecycle and product email
• Zendesk — Customer support ticketing; holds the content of support conversations
• Upstash — Rate limiting; holds short-lived request counters only
• PostHog — Product analytics (usage patterns, feature adoption)
• Anthropic — AI model inference, accessed via Cloudflare AI Gateway
• OpenAI — Receives the data you request through ChatGPT when you connect Redbark to ChatGPT
• Datadog — Observability: application logs, performance monitoring, and error tracking. Telemetry is redacted of banking data and personal identifiers before it is sent, and is processed on Datadog's United States infrastructure.

Each provider operates under their own privacy policies. We encourage you to review them.

8. Analytics

We use PostHog to collect anonymised product analytics, such as which features are used and how users navigate the Service. Analytics data does not include your banking data or transaction details. We use Datadog to monitor application performance and track errors; telemetry sent to Datadog passes through a redaction layer that strips banking data, personal identifiers, and secrets, and is processed in the United States. These services help us maintain and improve the Service.

9. Cookies

The Service uses essential cookies for authentication and session management, and analytics cookies for product usage tracking (via PostHog). We do not use third-party advertising cookies.

10. Children's Privacy

The Service is not intended for use by individuals under 18 years of age. We do not knowingly collect personal information from children.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via email or an in-app notice. The "Last updated" date at the top of this page indicates when the policy was last revised.

12. Access, Correction, and Complaints

To request access to personal information we hold about you, to request correction of any inaccurate personal information, or to raise a privacy or CDR-related enquiry, contact us at privacy@redbark.com or Level 1, 63-73 Ann Street, Surry Hills NSW 2010, Australia. We will respond within 30 days.

If you are not satisfied with our response, you may escalate:

• Privacy complaints — Office of the Australian Information Commissioner at www.oaic.gov.au.
• CDR-specific complaints — Our CDR Principal is Fiskil Pty Ltd, who operates their complaints process under Fiskil's CDR Policy. The external dispute resolution body for Fiskil is the Australian Financial Complaints Authority (AFCA, member 83521) at www.afca.org.au.

13. Redbark Advisor

Redbark Advisor ("Advisor") is software for financial advice firms. A firm uses it to manage its clients, collect their documents and bank data, record meetings, and prepare advice documents. This section explains how Advisor handles personal information. Where it differs from sections 1 to 12, this section applies.

Our role and the firm's role

There are two kinds of people in Advisor:

• Members: the people at a firm who use Advisor, such as advisors and support staff.
• Clients: the people a firm advises, who are invited to the firm's client portal.

Redbark is responsible for members' account information. For client information, the firm decides what is collected and why, and is responsible for it under its own privacy policy. Redbark handles client information on the firm's behalf, only to provide Advisor to that firm. If you are a client, contact your firm about your information. We will help the firm answer your request.

Information Advisor holds

• Member accounts: name, email address, role, and the firm's business details. Sign-in is handled by Clerk.
• Client details: names, contact details, dates of birth, relationships, employment and income, assets, debts, super, insurance held, goals, and notes the firm records.
• Documents: files a client or member uploads, such as statements, payslips, tax returns, trust deeds and risk profile reports, and the details read from them.
• Bank data: transactions, balances and account details a client chooses to share through the Consumer Data Right. Banking data is collected through Fiskil as described in section 2. Unlike Redbark Sync, Advisor stores the transactions a client shares, so the firm can see them, until the client withdraws consent or the firm closes the client.
• Meetings: when a member uses the meeting notetaker, a recording, a transcript and notes of the meeting, and the member's calendar entries for client meetings.
• Advice documents: fact finds, Statements of Advice, Records of Advice, reviews and consent forms, with the records each one was drafted from.

Advisor is not designed to hold medical details. A firm can record the health fund and cover a client holds. When an advice document is drafted, medical details are removed from notes, meetings and briefs before they are sent to an AI model.

Artificial intelligence

Some Advisor features use an AI model to read and write text:

• the client summary on a client's page
• the assistant, which answers a member's questions about a client's records
• notes and actions drafted from a meeting transcript
• drafts of advice documents, from the records a member chooses
• turning a firm's own document into an Advisor template

For these features, the client information the feature needs is sent to Anthropic, which runs the model, through Cloudflare AI Gateway. Anthropic processes it in the United States. Under its commercial terms, Anthropic does not use this information to train its models and deletes it after a limited period. We do not keep a copy of these requests in Cloudflare AI Gateway.

Everything an AI model writes is a draft. A member reviews it before it is used, sent or relied on. Advisor does not make decisions about clients. Advice is given by the firm's advisor.

Reading documents

When a document is uploaded, Advisor sends it to Extend, a document processing service, to read the details from it. A member checks those details before they are added to the client's records. Extend processes documents in the United States. When a document is deleted, we also delete the copy Extend holds.

Meeting recordings

The meeting notetaker joins a call when a member asks it to. Recording and transcription are provided by Recall.ai, which processes them in Japan. The member must tell everyone in the meeting that it is being recorded and get their agreement first. Transcripts are stored encrypted with a key held for each firm. When a recording is deleted, we ask Recall.ai to delete its copy.

Where information is stored

Advisor's database is hosted by PlanetScale in Sydney, Australia. Files are stored in Cloudflare R2 in the Oceania region. Some of the providers listed below process information outside Australia, as stated in this section and the list below. Before we disclose personal information overseas, we take reasonable steps to make sure the recipient handles it in line with the Australian Privacy Principles, including through our contracts with them.

Advisor providers

As well as Cloudflare, PlanetScale, Clerk, Fiskil, Stripe, Resend and Datadog from section 7, Advisor uses:

• Anthropic: AI model processing, United States
• Extend: reading uploaded documents, United States
• Recall.ai: meeting recording and transcription, Japan
• Google and Microsoft: a member's calendar, and filing documents to the firm's Google Drive or SharePoint, when the member connects them
• Slack and Microsoft Teams: notifications to the firm's own workspace, when the firm connects them
• PostHog: product analytics about how members use Advisor, United States. It does not receive client records.
• Attio: our customer records about firms and their members
• Context.dev: looking up a firm's public logo and details from its website

Retention and deletion

• Client information is kept while the firm's client is open. When a firm closes a client, their records, documents, reports and chats are deleted. A firm that must keep advice records for longer should keep its own copy of them.
• When a client withdraws their bank data consent, the accounts, balances and transactions from that connection are deleted.
• When a firm deletes its Advisor account, all of its information is deleted, including copies held by our document, meeting and filing providers. Encryption keys for the firm's transcripts are destroyed first.
• Member accounts are kept while the member belongs to a firm.

Security

Information is encrypted in transit with TLS and at rest. Each firm's information is kept separate from every other firm's. Access to production systems is restricted and logged.

Questions

Members can contact us at privacy@redbark.com or through section 12. Clients should contact their firm first.