Privacy policy

Last updated 11 August 2026.

This policy explains how Tranche Capital Pty Ltd (ABN 83 700 835 687) — “Tranche Capital”, “we”, “us” — handles personal information in the course of providing the Tranche Capital platform, deal management software licensed to commercial finance and private credit firms. We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

1. Two different roles, and why the difference matters

Almost everything in the platform is information a customer firm put there in the course of its own business — its borrowers, its sponsors, its lenders, its correspondence. For that information, the firm decides what is collected and why; we hold and process it on the firm's instructions, under our agreement with that firm.

If your dealings are with a finance firm that uses our software and you want to know why your information was collected or ask for it to be corrected or deleted, that firm is the right place to start — it holds the relationship and it controls the record. We will help any firm meet such a request, and you may also contact us directly using the details in section 11.

A smaller category — the account records of the people who sign in, and our own billing and support records — we determine ourselves. This policy covers both, and says which is which where it matters.

2. Information we collect

Account information

Name, work email address, role and permissions within a firm, sign-in and session activity, and an audit record of significant actions taken in the platform. Accounts are created by a firm's administrator or by us at a firm's request — there is no public sign-up, and signing in with Google never creates an account.

Information a firm places in the platform

Deal records and the parties to them (borrowers, guarantors, sponsors, brokers, lenders and their contact details), security and property details, facility terms and financial figures, documents uploaded to a deal, information supplied by a borrower through the borrower portal, and correspondence relating to a deal.

Information from connected Google accounts

Only where a user explicitly connects one — see section 3.

Technical information

Server logs recording requests to the service, including IP address, time and the page or endpoint requested, kept for operating and securing the platform. This website (tranchecapital.net) sets no cookies, runs no analytics and makes no request to any third party; the pages are static files. The application itself uses a session token strictly to keep you signed in.

3. Google user data

Connecting a Google account is optional and is always initiated by the user, from within the application. Nothing is accessed until you grant it, and access can be withdrawn at any time (section 8).

What we request, and why

What we never do with Google data

• We never write to it. The Drive integration can list files, read a file's details and download a file's contents. There is no code path that can create, rename, move, share, trash or delete anything in your Drive. Gmail is read and send only — no label, filter, draft or mailbox setting is ever changed, and nothing is ever deleted.
• We never sell it, and never transfer it to anyone outside the service providers listed in section 6.
• We never use it for advertising, and never to develop, improve or train any generalised or personalised AI or machine-learning model.
• Our staff do not read it, except where you ask us to investigate a specific problem, or where the law requires it.

Limited Use

4. The two boundaries the database enforces

These are not undertakings the application is trusted to remember. They are row-level security policies in PostgreSQL: a query that failed to respect them would be refused by the database itself.

• A connected personal mailbox is visible to exactly one person: its owner. Not to their colleagues, not to their firm's administrators, and not to us. This boundary is stricter than the separation between firms, because two colleagues share a firm.
• Firms cannot see one another's data at all. Every request to the service runs as an unprivileged database role to which row-level security always applies.

When our support staff enter a firm's workspace to help — which is recorded in that firm's own audit trail, and shown on screen throughout — the session carries no user identity, and therefore no personal mailbox is visible to it. Support sees strictly less mail than the firm's own administrator does.

5. How information is stored and protected

• All data is stored in Australia, in Amazon Web Services' Sydney region.
• Each firm's data is held in its own separate stack — its own database and its own document storage.
• Databases and document storage are encrypted at rest; traffic to the service is encrypted in transit (HTTPS).
• Google credentials receive a second layer of encryption in the application before they are stored, with a key held outside the database in a managed secrets store. They are never stored in readable form.
• Credentials and message contents are never written to our logs.
• Access to production systems is restricted to personnel who need it to operate the service.

No system is perfectly secure, and we do not claim otherwise. If a data breach occurs that is likely to result in serious harm, we will notify affected parties and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme.

6. Who we share information with

We do not sell personal information. We disclose it only:

• to the customer firm whose workspace holds it, and its authorised users;
• to the service providers below, who process it on our behalf;
• where you or the firm direct us to — for example, sending an email you compose;
• where required by law, or to establish or defend a legal claim.

7. Artificial intelligence

The platform uses large language models to draft replies, summarise correspondence and answer questions about a firm's own records. The limits below are enforced in the software, not merely instructed:

• Only deal-related mail is ever sent to a model. The test is a single one — the message must be matched to a deal — and it is applied on every path, automatic or on request. General personal mail in a connected mailbox is never transmitted to a model provider by any path.
• One stated exception. Where a message in a firm's shared deals mailbox has not been matched to a deal, a user may press a control that asks a model to suggest which deal it belongs to. That feature refuses outright to operate on any personal mailbox.
• Processing stays in Australia. Inference runs on Amazon Bedrock in Australian regions, which does not retain prompts or use them to train models.
• Nothing is sent on your behalf by a model. Drafts are suggestions; a person presses send.

8. Withdrawing access, retention and deletion

• Disconnecting a mailbox or Drive account revokes the stored credential and stops all further access immediately. You can also revoke our access at any time from your Google account permissions page. Correspondence already brought onto a deal is retained, because it forms part of the firm's record of that deal.
• If a user is deactivated, their personal mailbox stops syncing at once and no one else gains access to it at any point.
• If a user is deleted, their personal mail and everything derived from it is deleted with them. It was never the firm's to keep.
• While a firm's account is open, we retain its deal records for as long as it remains a customer, because the firm relies on them and may have its own record-keeping obligations. We do not set an arbitrary deletion date we would not honour.
• When a firm leaves, its data is deleted on request, and otherwise within a reasonable period after the account is closed. Backups age out on their own retention cycle.

9. Your rights

You may ask us for access to the personal information we hold about you, and to correct it if it is wrong. Where the information sits in a customer firm's workspace, we will refer you to that firm or act on its instructions, as section 1 explains. We will respond within a reasonable period and will tell you if we cannot give access and why.

If you are unhappy with how we have handled your personal information or your request, write to us first (section 11). If we do not resolve it, you may complain to the Office of the Australian Information Commissioner — oaic.gov.au.

10. Changes to this policy

We may update this policy as the platform changes. The date at the top records the current version. Where a change materially affects how personal information is handled, we will tell customer firms directly rather than rely on this page being re-read.

11. Contact

Privacy questions, access and correction requests, and complaints:
privacy@tranchecapital.net

Tranche Capital Pty Ltd
ABN 83 700 835 687 · ACN 700 835 687
Sydney, New South Wales, Australia.