Privacy Policy
How Klarite Pty Ltd collects, uses, discloses and protects personal information in ProveCONSULT — both the information of people who use the platform and the stakeholder information our client organisations record in it. We operate in accordance with the Privacy Act 1988 (Cth) and the 13 Australian Privacy Principles.
01Who this policy covers
ProveCONSULT is a consultation register used by organisations (our clients) — typically offshore petroleum titleholders and their consultants — to record consultation with relevant persons for environment plans. This policy covers two groups of people:
- Users — people with a ProveCONSULT account. For your account information, Klarite Pty Ltd is responsible for how it is handled.
- Stakeholders — relevant persons, their contacts, and anyone whose details appear in consultation correspondence our clients record, and people who make a public comment on a client’s environment plan (submitters) when the client uses the public comment add-on. This information is collected and controlled by the client organisation running the consultation. We hold and process it on that client’s behalf and on its instructions, and the client’s own privacy notice governs why it collects it.
If you were consulted by an organisation that uses ProveCONSULT and want to know what it holds about you, contact that organisation first. We will help it respond, and you can also contact us directly (section 9).
02What personal information we collect
We collect personal information only where it is reasonably necessary to provide the platform.
Users
| Category | Examples | Why we collect it |
|---|---|---|
| Account | Name, email address, the organisations you belong to and your role in each | Account creation, sign-in and access control |
| Security | Two-factor authentication enrolment (one or more authenticator apps), sign-in sessions, the times of recent password-change attempts | Protecting your account; two-factor sign-in is required for every user; limiting password guessing; emailing you when your sign-in security changes |
| Support | Messages you send through Support in the app or to services@klarite.com.au | Responding to your enquiries |
Stakeholder information our clients record
| Category | Examples |
|---|---|
| Relevant persons and contacts | Names, organisations, roles, email addresses, phone numbers, postal addresses, functions, interests and activities, contact preferences and notes |
| Consultation events | Emails, letters, meeting notes, phone call records, dates, summaries and attached files |
| Feedback and responses | Objections, claims and questions raised, the client's responses, commitments and themes |
| Email preferences | When a stakeholder uses the email preferences link at the foot of a campaign email: their choice (fewer emails, another way of being consulted, not the right person, or no longer wishing to be consulted), how they would like to be contacted, any other contact they suggest, and any reason or comment they give. It is recorded in the client's consultation record and the client's owners and admins are told |
| Correspondence from connected mailboxes | Where a client connects a Microsoft 365 project mailbox: sender, recipients, subject, message body and attachments of messages in its Inbox and Sent Items |
| Public comment (public comment add-on) | The files of public comments NOPSEMA passes to the client (Outlook .pst or .msg), and from them each submitter's name, email address, the text of their submission and its attachments; the points (claims) drawn from submissions; and whether the client's response email to a submitter was sent, failed or bounced |
Information collected automatically
| Category | Examples | Why we collect it |
|---|---|---|
| Activity and audit records | Security events (invites, role changes, two-factor resets, plan and cap changes), records of permanent deletions, AI usage (model, tokens, cost), the change history of each consultation event (who changed what, with old and new values), and a record of each time a Klarite platform administrator who is not a member opens or changes a client's pages | Security monitoring, incident response, cost control and billing |
| Technical | IP address, browser details and standard server logs held by our hosting providers | Security, authentication and abuse prevention |
Sensitive information
We do not ask for sensitive information (as defined in the Privacy Act). However, consultation correspondence can contain it — for example, a stakeholder may mention their health, their cultural connection to an area, or their political views. Clients can mark material as sensitive and keep it in a separate sensitive information pack. We apply the same security controls to all stakeholder information regardless of content.
ProveCONSULT does not process payments. Plans are invoiced by Klarite; no payment card details are collected or stored in the platform.
03How we use personal information
We use personal information to:
- create and manage accounts, and enforce each client’s roles and access;
- provide the platform to our clients — recording, organising, summarising and reporting their consultation;
- send system emails such as invitations, password resets, AI usage warnings and service alerts to owners and admins (a mailbox that needs reconnecting, a send that stopped);
- send the emails and replies a client chooses to send, from the client’s own connected mailbox;
- with the public comment add-on, read the public comment files a client uploads, and send the client’s response to submitters through our email provider when the client chooses to send it;
- respond to support and privacy enquiries;
- detect and prevent misuse and security incidents, and keep audit records;
- calculate AI usage for cost caps and invoicing; and
- comply with our legal obligations and enforce our Terms of Service.
We do not sell, rent or trade personal information, use stakeholder information for our own purposes, or use any of it for marketing. Stakeholder information is used only to provide the service to the client that recorded it.
04AI processing
On plans that include AI features, ProveCONSULT uses Anthropic’s Claude models to summarise events and documents, extract feedback items, suggest and apply themes, and draft responses and reply letters. With the public comment add-on, it also picks out the separate points (claims) each public comment makes. AI output is for a person to review — feedback items stay marked as AI-generated until a person reviews them, AI event summaries are flagged until a person reviews them, and nothing is sent to a stakeholder unless a person sends it. Themes are the one exception: they are applied to feedback items automatically as an organising aid, and a person can change them at any time.
4.1What we remove before text is sent
Before stakeholder text is sent to the AI service, ProveCONSULT replaces email addresses, Australian phone numbers, the names of recorded people (relevant persons, contacts, staff and email correspondents) and other personal names it detects with placeholders such as [PERSON_1]. If a known name or email address would still be sent, the request is stopped. AI summaries and feedback items refer to “the relevant person”, and claims to “the submitter”, rather than a person’s name. Public comments are de-identified the same way, including the submitter’s own name and email address.
4.2What is not removed
- Names of organisations, projects and titleholders are not replaced.
- Postal addresses are not replaced.
- Text in scanned documents and images is read on our servers in Sydney (optical character recognition) and only that text, de-identified as above, is sent; the image itself is not. Recognition can misread a name, so one may occasionally pass through. A scan or image with no readable text (a photo, a map, handwriting) is not sent at all.
- The text of project documents a client uploads to its document library (for example environment plan sections) is sent without names being replaced.
- Name detection is automated and may occasionally miss a name that has not been recorded in the register.
4.3What is kept
We log each AI request’s model, token counts and cost, but not the text sent or received. To avoid paying twice for the same work, we keep a cache of AI results (which contain placeholders, not the removed names) linked to a fingerprint of the request, and delete each result 30 days after it was last used. Under Anthropic’s commercial terms, content sent through its API is not used to train its models.
4.4Automated decisions
ProveCONSULT does not use computer programs to make decisions that could reasonably be expected to significantly affect the rights or interests of an individual. The AI drafts, summarises and organises consultation records for our clients’ staff; decisions about a relevant person — including how to respond to them and whether consultation was adequate — are made by people at the client organisation, and decisions about an environment plan are made by the regulator.
05Disclosure and sub-processors
We disclose personal information only to the service providers below, and only as needed to run the platform. We do not disclose a client’s data to any other client.
| Provider | Purpose | Country | Data processed |
|---|---|---|---|
| Supabase Inc. | Database, file storage, authentication | United States | Database and files hosted in Sydney (ap-southeast-2). All account and stakeholder information. |
| Amazon Web Services, Inc. | Backup copies of stored files and of the database | United States | Held in Sydney (ap-southeast-2) in a separate Klarite account. A nightly copy of the stored files (emails as PDFs, attachments, documents, reports and public comment files), kept until 35 days after a file is changed or deleted, and a nightly copy of the database, encrypted in Sydney before it is stored and kept for 35 days. Not read except to restore lost or damaged data. |
| Vercel Inc. | Application hosting | United States | Application functions run in Sydney (syd1); pages are served from Vercel's global network. Request logs held by Vercel. |
| Anthropic, PBC | AI processing (AI plans only) | United States | De-identified text, including text read from scanned documents and images, as described in section 4. Processed in the United States. |
| Resend Inc. | Email delivery | United States | Sent through Resend's Tokyo (ap-northeast-1) region. Recipient email address and content of invitations, password resets, usage warnings and service alerts. With the public comment add-on: submitters' email addresses, the client's response to them, and delivery and bounce notices. |
| Functional Software, Inc. (Sentry) | Error reporting | United States | Stored and processed in the European Union (Frankfurt). Receives only the technical details of an application error: the error type and message, the code location, the page or route path, and the software version (for a failed background job, only its type, reference number and status). Request contents, names, email addresses and consultation data are removed before anything is sent, and Sentry is set not to store IP addresses. |
Microsoft 365. When a client connects a project mailbox, ProveCONSULT reads and sends mail through Microsoft Graph using that client’s own Microsoft 365 account, with permission granted by a person at the client. Microsoft holds that mail under the client’s own agreement with Microsoft, not as our sub-processor.
Public comment files. Reading uploaded .pst and .msg files is paused for now. When it resumes it will run in Sydney, and this page will be updated first.
5.1Cross-border disclosure — APP 8
The providers above are United States companies. AI processing takes place in the United States, email is delivered through Resend’s region in Japan (Tokyo), application error reports (technical details only) are held in the European Union (Frankfurt, Germany). By using the platform, users and clients acknowledge that personal information may be processed in the United States and Japan. Before disclosing personal information to an overseas recipient, we take reasonable steps to ensure it handles the information in a way that is substantially similar to the Australian Privacy Principles, including through each provider’s data processing terms.
5.2Sharing within a client organisation
Projects and their records belong to the client organisation. Members of that organisation can see them according to their role (owner, admin, officer or viewer); viewers can read but not change anything. Owners and admins invite and remove members.
5.3Legal requirements
We may disclose information where the law requires it, or to a client’s regulator only at that client’s direction. Reports such as the Report on Consultations are generated by the client and submitted by the client, not by us.
06Storage and security
Encryption
All traffic to the platform uses HTTPS (TLS), with HTTP Strict Transport Security. Data is stored in Supabase, which encrypts its databases and file storage at rest. Microsoft 365 mailbox tokens are additionally encrypted by ProveCONSULT (AES-256-GCM) and can only be read by the server.
Sign-in
Accounts are created by invitation only. Passwords must be at least 12 characters and are checked against known breached passwords; they are hashed by Supabase Auth and never stored by us. Two-factor authentication is required for every user, and the database itself refuses access to sessions that have not completed it.
Separation between clients
Every record carries its client organisation, and database row-level security policies ensure a user can only read or change records of organisations they belong to, within their role. This separation is tested automatically before each release.
Access by Klarite personnel
Klarite platform administrators can see account-level information needed to run the service — organisation names, member emails and roles, project counts and AI usage — but platform admin rights do not grant access to a client’s consultation records. Klarite staff work in a client’s records only where the client has engaged us to, or to give support the client has asked for. When a platform administrator who is not a member of a client opens that client’s pages or makes a change in it, ProveCONSULT records who, when and which page or change; the client’s owners and admins can see that record, and nobody can edit or delete it. Authorised technical staff with database administration credentials can technically reach stored data; this is limited to support, security, maintenance and incident response.
For a fuller technical description, see our Data Handling document.
07Where your data is located
| Data | Stored | Processed |
|---|---|---|
| Accounts and consultation records | Supabase — Sydney | Vercel — Sydney |
| Emails, attachments, documents and reports | Supabase Storage — Sydney | Vercel — Sydney |
| Backup copies of stored files | Amazon Web Services — Sydney | Vercel — Sydney (the nightly copy) |
| Encrypted nightly copy of the database | Amazon Web Services — Sydney | Amazon Web Services — Sydney (the nightly copy) |
| AI requests (AI plans only) | Not stored by us beyond the result cache in Sydney | Anthropic — United States |
| System emails | Resend — Japan (Tokyo) | Resend — Japan (Tokyo) |
| Public comment files, submissions and attachments (add-on) | Supabase — Sydney | Vercel — Sydney (reading uploaded files is paused; it will run in Sydney when it resumes) |
| Responses to public comment submitters (add-on) | Resend — Japan (Tokyo) | Resend — Japan (Tokyo) |
| Application error reports (technical details only) | Sentry — European Union | Sentry — European Union |
| Connected mailbox | The client's Microsoft 365 tenant | Microsoft — per the client's own arrangement |
08Data retention
| Data | Retention |
|---|---|
| Accounts | While the account is in use. We close an account when you ask (section 9), and close it automatically once it has belonged to no organisation and has not been used for 12 months. When an account is closed, we delete your sign-in and email address, but your name stays against the consultation records you made, shown as a former member, because those records belong to the client |
| Consultation records and files | While the client keeps them. We never delete them automatically. Clients archive records (restorable) and can permanently delete archived records, projects or their whole organisation; permanent deletion removes the database records and stored files |
| Synced email | Kept with the project when a mailbox is disconnected, so the consultation record stays complete; deleted with the project |
| Public comment | The uploaded .pst and .msg files, submissions, their attachments and claims are kept with the project, and deleted with the project or the client's organisation |
| Audit and history records shown to the client | Event history, records of permanent deletions, AI usage records, member security history (such as invitations, role changes and member removals) and the Klarite support access log. Kept for the life of the client account so the client can see its consultation and security history; deleted with the client’s organisation |
| Klarite security records | The sign-in audit trail held by our authentication provider, Supabase (sign-ins, failed sign-ins and IP addresses), our record of platform-wide emergency stops, and our record of account closings (which account, who closed it and when). Kept for 12 months, then deleted automatically |
| Operational records | Deleted automatically: finished background jobs 30 days after they finish; sign-in and action rate-limit counters after 7 days; saved AI results (kept so the same request is not paid for twice) 30 days after they were last used |
| Support messages | Messages you send to Klarite through Support in the app: kept for 2 years after they were sent, then deleted automatically |
| Backups | Deleted data can stay in backups for up to 35 days. Database backups are held by Supabase and expire on its backup cycle (currently 7 days). An encrypted nightly copy of the database is held by Amazon Web Services in Sydney and removed after 35 days. Backup copies of stored files are held by Amazon Web Services in Sydney and removed 35 days after the file is changed or deleted |
| Our providers’ logs | Our hosting, email and error-reporting providers keep their own short-term logs on their own cycles, currently 30 days or less, and Sentry up to 90 days depending on our plan |
Consultation records often need to be kept for regulatory purposes, so we do not delete a client’s records automatically. When a client’s agreement ends, we keep its data for 30 days so the client can export it or ask us for a copy, then delete it, unless we agree otherwise in writing. Keeping records for the longer term, including for a regulator, is the client’s responsibility: once the agreement ends, the client’s export is its record, and we do not keep an archive. Exports are made project by project, in Excel and Word, and the client can ask us for a copy of a project’s stored files.
09Your rights
Under the Privacy Act, you can:
- access the personal information held about you (APP 12);
- ask for correction of information that is inaccurate, out of date, incomplete, irrelevant or misleading (APP 13);
- ask for deletion of your account, subject to legal retention obligations; and
- complain to us, and if you are not satisfied, to the Office of the Australian Information Commissioner (OAIC).
Users can contact us at services@klarite.com.au. Stakeholders should contact the organisation that consulted them, which controls its consultation records; if you contact us instead, we will pass your request to that organisation and help it respond. We aim to respond to access and correction requests within 5 business days, and always within 30 days.
10Notifiable Data Breaches
We follow the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act. If a data breach involves a client’s information, we will tell that client promptly and work with it to assess the breach, contain it and notify the OAIC and affected individuals where required.
11Cookies
ProveCONSULT uses only cookies it needs to work: the sign-in cookies that keep you signed in, and, when an owner or admin connects a Microsoft 365 mailbox, a short-lived cookie (15 minutes) that ties the Microsoft sign-in back to that request. It uses your browser’s local storage to remember display preferences (light or dark theme, the collapsed side menu, and report form choices). We do not use analytics, advertising or tracking cookies. When the application hits an error, a technical report with no personal or consultation data goes to our error-reporting service (section 5). Emails sent through ProveCONSULT carry no open or click tracking.
12Children
ProveCONSULT is a professional tool for business users and is not directed at children. We do not knowingly collect children’s personal information. If you believe a child’s information has been recorded, contact us at services@klarite.com.au.
13Changes to this policy
We may update this policy from time to time. We will tell client organisations about material changes by email at least 14 days before they take effect. The date at the top of this page shows the current version.
14Contact and complaints
Privacy enquiries
For any question about this policy, your information, or how we handle it.
If you are not satisfied with our response to a privacy complaint, you can complain to the Office of the Australian Information Commissioner (OAIC):
- Website: oaic.gov.au
- Phone: 1300 363 992
- Post: GPO Box 5218, Sydney NSW 2001