Altivane Privacy Policy

1. About this policy

This policy says what personal information we hold about the people we deal with for Altivane, why, where it is held and for how long, and how to see it, correct it or complain.

Who we are. We are [Legal entity] (ABN [ABN]) of [Address] ("we", "us", "our"). We make Altivane, a Windows desktop app for managing Microsoft cloud tenants, and run its website at [Website address], the website's accounts, our forms service, the licensing service and the update service.

Who it covers. People who visit the website or contact us; people who hold a website account; our customers, their contacts and the people who use Altivane under their licences; partners who resell Altivane, and their contacts; people we ask to sign a form; and anyone named in what a customer sends us for support.

What it doesn't cover. The data in the Microsoft tenants that Altivane manages. Altivane keeps that on the customer's own computer and sends none of it to us (section 4). Nor does it cover Microsoft's services or the AI provider a customer chooses for AI summaries and Build with AI: their own terms and privacy statements apply.

The law we follow. We handle personal information under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). We follow them whether or not the Privacy Act requires it of us, such as under the small business exemption. This policy is also our notice of collection under APP 5, and the website's sign-up page links to it.

How it fits with our agreements. Our website and account terms of use, end user licence agreement, MSP partner and reseller agreement, data processing and security statement (the data statement) and support and maintenance policy all refer to this policy. This policy is a notice. It isn't a contract and doesn't change those agreements. For a customer, the data statement also sets our commitments about the data we hold for its licence, and where it gives the customer more than this policy does, the data statement applies.

This version. Version 1, in force from the day we publish it at [Website address]/privacy.

2. The short version

A summary only. Where it differs from the sections below, they apply.

• Altivane runs on your computer. What it reads from your tenants stays there, and we never receive it unless you send it to us.
• We hold only what we need to license, update and support Altivane, run the website and its accounts, have forms signed and bill: mostly names, email addresses, company names, computer names, IP addresses and the messages you send us.
• The website has no analytics, no advertising and no tracking cookies.
• We don't sell personal information, use it for advertising or use it to train AI models.
• Our services run on Microsoft Azure in Australia. Microsoft holds website account details outside Australia, and our email and accounting providers hold our records in the countries section 8 names.
• To see or correct what we hold, or to complain, write to [Privacy contact email]. We answer within 30 days.

3. What we collect and how

We collect personal information only when you use our services or deal with us, and only what this table lists.

What counts as personal information. An IP address, a computer's name or a User-Agent can sometimes identify a person, so we treat them as personal information.

Service logs. The licensing service and the update service log their requests and errors, with request IDs. The licensing service also logs repeated failures from 1 IP address or installation, with that address or installation ID. A licence key appears in these logs only as its last 4 characters.

Your licence key. Altivane sends the key to the licensing service to check it, but the service never stores it. It keeps a keyed hash of the key, to look it up, and its last 4 characters, so you can tell keys apart. We can't show a lost key again, so we replace it instead. The licensing service holds no email address.

Details others give us. When your organisation or a partner gives us your details, such as naming you as a contact, it must tell you it does so and have the right to give them.

What we don't ask for. We don't ask for sensitive information, such as health or racial origin, or for government identifiers. If any reaches us in something you send, we handle it as support data (section 6) and delete it with that data. Never send us a full licence key, a password, a certificate or its private key, an AI key or a client secret. We will never ask for them.

Information we didn't ask for. If we receive personal information we didn't ask for, such as a client's details in an email, we keep it only if we could have collected it for a purpose in section 5. Otherwise we destroy or de-identify it as soon as we reasonably can.

If you don't give it. Without the details we need, we may not be able to issue a licence, open an account, have a form signed or help you.

4. Data in your tenants, which we don't collect

What Altivane reads from and writes to a tenant stays with the organisation that runs Altivane. We never receive it unless that organisation sends it to us.

It stays on your computer. Altivane runs on the customer's computer, against 1 tenant at a time. It reads and changes the tenant through Microsoft's public APIs, and keeps what it reads and makes on that computer and in the folders the customer chooses: settings, reports, documents, change logs, kept data and its diagnostic log. We have no service that receives, stores or can read that data.

No telemetry. Altivane sends no usage data or diagnostics to us. It connects only to Microsoft's services for the tenant, to the licensing service, to the update service when a person asks, and to the customer's AI provider if the customer turns AI summaries on, or when a person selects Build in Build with AI.

AI summaries. They are off until the customer adds its own AI provider and turns them on. Altivane then sends the scorecard reports' headings, status counts and summary figures, with names, addresses and IDs replaced first, straight from the customer's computer to that provider. Nothing passes through us. The customer's agreement with its provider governs what the provider keeps and where, and the customer is responsible for that choice.

Build with AI. On Altivane's Blueprints page, New > Build with AI writes a Blueprint from a description a person types. It shows only when the customer has added its own AI provider, with its API key and a model. Only when the person selects Build, Altivane sends that provider the description they typed and a description of the Blueprint format, straight from the customer's computer, under the customer's own API key and terms. Nothing from a tenant is sent: no names, IDs or tenant data. Nothing passes through us. If Altivane finds problems in the answer, it sends the answer back to the same provider once, with the problems, to be corrected. The answer is saved as a new Blueprint on the customer's computer. Altivane's diagnostic log records only that a Blueprint was built, the service, the model and the description's length in characters, never the description.

If you are a person in a tenant. Your details in a tenant, such as your mailbox, devices and sign-ins, are held by the organisation that runs Altivane, under its own privacy obligations and its agreements with its clients and with Microsoft. To ask about them, contact that organisation, or whoever manages your organisation's Microsoft 365.

When we do receive it. We receive tenant data only if a customer sends it to us, such as in a support bundle. We then handle it as support data (section 6).

5. Why we collect and use it

We collect, hold, use and disclose personal information only for these purposes:

• to issue, activate, renew and deactivate licences, and to count and free seats;
• to tell Altivane about updates and supply them, and to limit how often 1 IP address can check;
• to run the website, its accounts and the user guide;
• to have forms signed, and to keep a record of what was signed, by whom and when;
• to give the support you ask for;
• to invoice, take payment and keep our tax records;
• to send notices about your licence, your account, security, and changes to our terms and this policy;
• to keep our services secure, stop misuse and explain refusals;
• to send news about Altivane, only if you agreed to receive it (section 9); and
• to meet our legal obligations, and to deal with claims and disputes.

We use it for another purpose only if you agree, if you would reasonably expect it and it relates to a purpose above, or if the law requires or allows it.

We don't sell personal information, use it for advertising or use it to train AI models.

Decisions a computer makes. The licensing service decides by itself whether to grant an activation or renewal. It applies the licence's rules: whether the licence is active and has a free seat, whether the request is signed by the installation's own key, and whether 1 IP address or installation is asking too often. It uses the licence and activation records in section 3 to decide. If you think a refusal is wrong, contact us and a person will look at it.

6. Support records

We see only what you choose to send us for support, use it only to help you, and delete the files and tenant data you send within 30 days after the request closes.

What we receive. Support is by email to [Support email address]. A request can hold your messages, the licence details from Help > Licence > Copy details (the version, the licence's state and its IDs, never the key), screenshots, logs and a support bundle. Together we call the files and tenant data you send support data.

Support bundles. A support bundle is a .zip file Altivane saves on your computer, from Help > Save a support bundle, and sends nowhere. It holds the last 14 days of the diagnostic log, with details of Altivane and Windows. It leaves out the settings file, the licence key, the sign-in cache, kept data, AI keys, change logs and documents. Its logs can name your tenants, people and devices, so check it before you send it, and send tenant data only if your agreements with your clients allow it.

How we use it. Only to give that support, keep it secure and meet our legal obligations. Only our people working on the request see it. We share it only with our email provider (section 7), or where the law requires.

Screen sharing. We join a screen-sharing session only when you invite us, in a tool you choose, with you in control. We don't record it unless you agree first. We never ask for or keep tenant passwords or certificates, and we don't run changes in a tenant: you do.

How long we keep it. We delete support data within 30 days after its request closes. We delete it sooner, or keep it longer, if you ask. We keep the request's emails, and our own record of the request, for 2 years after it closes.

Through a partner. If you bought Altivane through a partner, the partner supports you first and may bring your request to us. We then deal with the partner, and handle what it sends us the same way.

7. Who we share it with

We share personal information with the providers below, which run our services for us, and with the others this section names. None of them may use it for their own marketing.

We run support through our email, with no separate support or ticketing tool. Before we add or replace a provider, we update this table, and give customers the notice the data statement requires.

We also share personal information with:

• the customer and its partner: we tell a customer, and the partner it bought through, about its own licence, such as which computers use its seats, so they can manage seats and get support;
• our advisers and insurers: our lawyers, accountants and insurers, where they need it to advise or cover us, and they keep it confidential;
• government, courts and police: only what the law requires. We tell the customer first, unless the law stops us; and
• a buyer of our business: if we sell the business that supplies Altivane, the buyer, which must keep to this policy. We tell customers before it passes.

Microsoft, as the provider of your tenants, and your AI provider act for you, not for us. What Altivane sends them is between you and them.

8. Personal information held outside Australia

The licensing service, the update service, the forms service and the website hold their records in Australia. 3 kinds of record are likely to be held in other countries:

Why External ID data is outside Australia. Microsoft keeps External ID data in Australia only with its paid Go-Local add-on, and our External ID tenant was set up without it. Microsoft explains where Entra data is held.

Microsoft's access to Azure. Our records on Microsoft Azure stay in the Australia East region. Microsoft may reach them from other countries to run and support Azure, under its own terms. It doesn't say in advance which countries.

How we protect it. Before personal information goes to a provider outside Australia, we take reasonable steps to make sure the provider handles it in line with the APPs, through its contract with us, such as Microsoft's data protection terms. We stay accountable for how it handles that information, as the Privacy Act provides.

Before anything moves. We update this section before we hold any other personal information outside Australia. Before we move the licensing service's records outside Australia, we give customers at least 30 days' notice and partners at least 60 days' notice.

Your AI provider. If a customer turns on AI summaries or uses Build with AI, its own AI provider may be outside Australia. The customer chooses that provider and is responsible for what it sends there.

9. Marketing, anonymity and your choices

News only if you agree. We send news about Altivane only if you agree to receive it. Each message has a way to unsubscribe, as the Spam Act 2003 (Cth) requires, and you can also write to [Contact email]. Notices about your licence, your account and security aren't marketing, so they still come while you hold a licence or an account.

Partners' clients. While a partner agreement runs, we don't use the details of a client that a partner gives us to market Altivane to that client directly, except as that agreement allows.

No sharing for marketing. We don't give or sell your details to anyone for their marketing.

Staying anonymous. You can read the website without an account and without telling us who you are. You can ask us a general question without your name, or under another name. To issue a licence, open an account, have a form signed, bill you or help with your licence, we need to know who you are.

Your choices.

• Close your website account at any time by writing to [Contact email] from the account's email address. Closing it doesn't end a licence or deactivate Altivane.
• Free a computer's seat with Help > Licence > Deactivate this computer. Uninstalling doesn't deactivate it.
• Decide what to send us for support, and leave out what we don't need.
• Keep AI summaries off, or turn them off in Settings at any time.
• Use Build with AI only when you choose: it sends nothing until you select Build.
• Ask us to see, correct or delete what we hold (section 14).

10. The website and cookies

The public pages need no account, and collect nothing about you beyond the request logs below. The website has no analytics, no advertising and no tracking cookies, and uses only the cookies below.

The website needs these cookies to work, so it doesn't ask for consent. You can block cookies in your browser, but you then can't sign in. Sign out when you finish on a shared computer.

Your choice of theme. The website's light and dark switch keeps your choice in your browser's local storage. It is never sent to us.

Request logs. Our hosting on Microsoft Azure may log each request to the website and the forms service: the page, the time, the IP address it came from and the browser's User-Agent. We use these logs only to keep the services running and secure, and keep them for up to 30 days.

Sign-in pages. Microsoft runs the sign-in pages for us, through Microsoft Entra External ID. Microsoft holds your password, and the website never sees it. Microsoft's privacy statement covers any cookies its sign-in pages set.

Other websites. The website links to others, such as Microsoft's documentation. Their own privacy policies apply there.

11. How we keep it safe

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, change or disclosure. The data statement sets out our measures in full. The main ones:

• Encrypted in transit. Our services work over HTTPS only.
• Keys and IDs never stored in full. The licensing service keeps only a keyed hash of each licence key and its last 4 characters. Altivane hashes the computer's and Windows user's IDs on the computer, and never sends the raw IDs.
• Signed requests. Each request from Altivane is signed with a key it makes on the computer and keeps there, where it can't be exported.
• Encrypted at rest. The licensing database and its backups are encrypted, and the backups stay in Australia. The service reaches its database with its own Microsoft identity, with no password to steal.
• Few people, checked at sign-in. Only people we assign can sign in to our admin portals, through Microsoft Entra ID with multi-factor authentication. Only our people who need personal information for a purpose in section 5 can see it, and they must keep it confidential.
• Logs kept clean. Our logs never hold private keys, secrets, tokens, request bodies or full licence keys.
• Nothing kept too long. We delete or de-identify what we no longer need (section 12).

No independent party has yet tested our services, and we hold no security certification. We will update this section when that changes.

To report a security flaw in Altivane or our services, write to [Security contact email]. Keep your licence key private, and tell us at once if someone else may have it.

12. How long we keep it

We keep each record only for the period below, then delete or de-identify it.

Some of our services can't yet delete records by themselves, so we do it by hand: every 3 months, we delete or de-identify each record whose period has passed. We keep a record longer only where the law requires it, or to deal with a claim or dispute already raised.

On your own computer, Altivane deletes its diagnostic log after 14 days and keeps page data for 7 days by default. Everything else stays until you delete it. The data statement lists the steps.

13. Data breaches

If personal information we hold is accessed, disclosed or lost without authority, we act at once to contain it, and follow the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act, whether or not it applies to us.

• We assess it. We assess a suspected eligible data breach within 30 days.
• We tell you. If it is likely to cause serious harm, we notify the Office of the Australian Information Commissioner (OAIC) and the people at risk as soon as practicable. We say what happened, what information it involved and what you should do.
• We tell customers sooner. We tell a customer within 72 hours of becoming aware of an incident affecting its data, as the data statement says.

If you think your information, a licence key or a computer running Altivane has been compromised, write to [Security contact email] at once.

14. Access and correction

You can ask to see the personal information we hold about you, and to correct or delete it, by writing to [Privacy contact email]. We answer within 30 days, at no charge.

How to ask. Say what you want to see or change. We check who you are before we act, usually by replying to the email address we hold for you. This applies to everything this policy covers, the forms service included.

Seeing it. We give you access in the way you ask, where that is reasonable. We may refuse only where the Privacy Act allows, such as where access would affect another person's privacy or a legal dispute. If we refuse, we tell you why in writing and how to complain.

Correcting it. If what we hold is inaccurate, out of date, incomplete, irrelevant or misleading, we correct it. If we gave it to a provider or partner, we tell them of the correction if you ask. If we don't agree that it needs correcting, we tell you why and how to complain, and if you ask, we keep a note with the record that you say it is wrong.

Deleting it. We delete or de-identify what you ask us to, by hand. We keep only what we must: invoices, which the law requires us to keep; a signed form, for 7 years after it is signed, as the record of what was signed; and the audit history, for its period in section 12, for security. Deleting a licence's records ends its activations. In the forms service, we first remove your access, so you can no longer see or sign anything there.

A forgotten password. Sign out, then select Forgot password? on the sign-in page.

Data in a tenant. We hold it only if it was sent to us for support (section 4). For anything else, ask the organisation that runs Altivane for that tenant.

15. Complaints

If you think we have breached the APPs or this policy, tell us first. We answer in writing within 30 days.

1. Write to [Privacy contact email] with "Privacy complaint" in the subject, or by post to [Legal entity], [Address]. Say what happened and what you would like us to do.
2. We confirm we have it within 1 week, and look into it.
3. We give you our answer in writing within 30 days. If we need longer, we tell you why and when to expect it.

If you aren't satisfied with our answer, or haven't had one within 30 days, you can complain to the Office of the Australian Information Commissioner at www.oaic.gov.au or on 1300 363 992.

Complaining doesn't affect any other right you have, including under the Australian Consumer Law or our agreements.

16. Children

Altivane and our services are for businesses. A website account is for people aged 18 or over, and we don't knowingly collect personal information about children. If a child's details reach us, such as in a support bundle, we handle them under this policy and delete them with the support data.

17. Changes to this policy

We may change this policy. The version in force, with the date it took effect, is always at [Website address]/privacy.

Before a change that materially affects how we handle your personal information, such as a new provider or a new country, we email account holders and our customers' and partners' contacts at least 30 days before it takes effect. Customers and partners also get the notice their agreements and the data statement require. Other changes, such as clearer wording, take effect when we publish them.

18. Contact us