Who we are
Bludge is operated by Jewell Group Pty Ltd (ACN 649 111 357) as trustee for Jewell Group Trust, trading as Jewell Projects (ABN 56 822 550 848). Our principal place of business is 1190 Dandenong Road, Murrumbeena VIC 3163, Australia. Our address for service is PO Box 933, Carnegie VIC 3163, Australia.
Contact [email protected] about personal information, or [email protected] about the service. You can request a copy of this policy in another accessible format.
This policy covers our website and the business software we host, configure and maintain, including enabled forms, records, communications, scheduling, payments and AI features. A business using Bludge also has its own privacy responsibilities and should provide its own privacy notice.
Our role and the business using Bludge
We handle account, enquiry, support, billing and security information to operate our own business. We also hold information that our customers collect through their systems. For that information, the customer generally decides what to collect, who can access it and what work the system performs. We process it to provide the agreed service and follow lawful instructions, with limited additional handling for our own security, billing, legal obligations and disputes.
Where a law uses controller and processor roles, those roles depend on the activity. Describing us as a processor does not remove our own Australian privacy obligations.
If your information was supplied to a business using Bludge, contact that business about its use of your information. You can also contact us; we will help identify the responsible business and address matters within our control.
Information we collect and hold
Depending on the features used, information includes:
- Account information: names, email addresses, business details, telephone numbers, account roles, authentication and account activity records. Password authentication uses password hashes rather than storing readable passwords.
- Enquiries and support: contact details, information you submit when arranging a call or requesting help, and our correspondence.
- Business records: form answers, customer and staff details, enquiries, tasks, notes, approvals, bookings, uploaded files, documents and communications. The contents depend on the business's configuration.
- Unexpected sensitive information: health, care or other sensitive details that someone supplies despite the supported scope. Sensitive-data workflows are not supported at launch. If such information is received, we restrict unnecessary access and use, assess the appropriate lawful response and arrange removal or other necessary handling. It is not permission to send that information to an external AI service.
- Phone and message information: numbers, caller details, live call audio, transcripts, summaries, messages, outcomes, timestamps and actions taken during a conversation.
- Transaction information: amounts, payment status, processor references, refunds, customer acceptance and audit evidence. Card entry takes place on Stripe-hosted payment pages. Do not give card numbers or security codes to the phone assistant or put them in ordinary forms or messages.
- Technical information: IP addresses, browser and device details, session identifiers, requested pages, security events, usage and error records.
We receive information directly from people using our website or software, from the business they deal with, and through imports, integrations, calls, emails and messages. If information needed for a particular service is not supplied, we may be unable to provide that service.
How we use and disclose information
We use information to respond to enquiries, configure and provide the agreed software, manage access, process records and communications, support users, bill for services, prevent misuse, investigate incidents and meet legal obligations. Customer-directed messages, bookings and other automated work use the information needed for the enabled workflow.
We do not sell personal information. Customer content is not available for another customer's use. We do not use customer content to train our own AI models. Supplier processing and retention are separate and are described below.
We disclose information to authorised users of the relevant business, suppliers needed to provide the enabled service, people or services the business instructs us to contact, professional advisers where necessary, and authorities where disclosure is required or authorised by law. We take reasonable steps to limit each disclosure to its purpose.
AI features and phone conversations
Staff drafting features use xAI. When a permitted user requests a draft, relevant notes, record content or conversation history are sent to xAI to produce the result. These features require the organisation's AI setting and a configured service. Staff must review generated material before relying on or sending it.
The optional business intake interview uses OpenAI for text questions and summaries, and xAI for browser voice. With your agreement, we send your intake answers, typed details and conversation to these services. Voice transcripts can be included in an OpenAI summary. You can submit the intake without using the AI interview.
The phone assistant is enabled separately. It uses Twilio for telephony and xAI for live voice understanding, transcription and responses. It receives the conversation and relevant business configuration. Enabled tools can supply information needed for a request, such as services, availability and booking details. Business information deliberately published for the assistant is uploaded to xAI Files and Collections for retrieval; this is stored supplier content, rather than only a passing voice stream.
The phone assistant identifies itself as AI. Call audio is transmitted to suppliers while the call is happening, and transcripts and related records are stored in Bludge. Routine replayable audio recording is not part of the service we offer. Live audio processing, written transcripts and supplier-held records are separate from replayable recordings. Any diagnostic recording must be separately enabled and must have appropriate notice, consent, restricted access and verified deletion after seven days before it is used. Provider-level recording settings and diagnostic cleanup have not yet been independently verified across all services.
Turning off staff drafting does not, by itself, disable separately enabled phone processing or remove information already stored. AI can misunderstand or generate inaccurate content. People should avoid providing unnecessary sensitive information and can ask the business for another way to communicate.
Suppliers and processing locations
Only suppliers needed for an enabled feature receive the relevant information. A customer's separately connected service also receives information according to that customer's instructions and its agreement with that service.
| Supplier | Purpose and information | Processing and storage locations |
|---|---|---|
| Fly.io | Application, database, worker and voice gateway hosting; technical and operational records | Application, worker and voice gateway hosting has been checked in Sydney, Australia. Fly says its volume snapshots are stored in the United States. Other hosting logs and recovery copies need their own location and retention checks. |
| Tigris | Uploaded files and database recovery backups | The service uses Tigris. The deployment record reports private Sydney-restricted storage and recovery buckets; historical copies, exports and backup expiry have not all been independently verified. |
| Google / Gmail | Outgoing email; recipients, subjects and message contents | Outgoing email uses Gmail SMTP. This can involve overseas processing, including the United States; Australian-only handling is not promised. Automatic inbound attachment of email replies to application records is not currently enabled. |
| Twilio | Phone numbers, live audio, call metadata, SMS recipients and message contents | The documented pilot uses US1 processing in the United States. Sydney application hosting does not make telephony Australian-only. |
| xAI | Live voice, transcription, staff drafting, AI setup assistance, relevant tool results and published business knowledge | The application uses the global API, with no Australian-only processing guarantee. Stored Files and Collections have separate storage and deletion arrangements. Account-specific processing countries and voice retention remain under review. |
| OpenAI | Optional intake text interviews and summaries; supplied answers, typed details and conversation, including voice transcripts | The global API can process information overseas. Australian-only processing is not promised. Requests disable response storage; this is not a zero-retention service. |
| Stripe | Enabled payment and connected-account processing; payer, business and transaction information | Handling depends on the enabled account arrangement and can involve overseas processing. The relevant contracting entity, account terms and recipient countries must be confirmed during payment setup. |
| jsDelivr and other enabled asset providers | Browser requests for interface assets, including IP address and normal request details | Some application interfaces request external assets from international infrastructure. The public website uses locally hosted assets where available. |
Overseas recipients include providers processing in the United States. Other recipient countries depend on the enabled service and supplier account arrangements; we have not yet verified a complete country list for every supplier. Contact [email protected] for information about a particular service. We permit overseas supplier processing needed for the supported service, assess applicable safeguards and limit the information sent. Primary application and storage arrangements are kept in Australia where practical; overseas supplier processing remains possible. We assess applicable Australian Privacy Principle 8 obligations. An organisation enabling a feature does not, on its own, establish an individual's informed consent to an overseas disclosure or waive our responsibilities.
Supplier contracts and settings govern their handling. Staff text requests disable provider conversation storage; this does not remove supplier security, abuse-monitoring or legal retention. xAI's published API guidance describes default audit retention and separately stored Files and Collections; its global endpoint does not guarantee a processing region. We do not opt customer content into supplier model training, and keep optional training permissions off where offered and controllable. Supplier security, abuse-monitoring and legal retention can still apply. We do not promise zero retention or that deleting a Bludge record deletes every supplier copy.
OpenAI's API data guidance says API content is not used for model training by default. It may keep request content in abuse-monitoring logs for up to 30 days, or longer for legal or safety needs. Prompt caching can also keep temporary processing data. Disabling response storage does not remove these supplier records.
Cookies and email preferences
We use cookies needed for sessions, authentication, security and supported preferences. The application uses a session cookie across its business subdomains. Some interface assets are requested from external providers, exposing normal browser request details to them.
The website also stores a country preference when you choose a country. That preference cookie is configured to last up to 20 years unless you clear it sooner. You can remove cookies using your browser settings, although removing session cookies can sign you out. The current public-page review found no separate advertising or analytics integration; customer-configured pages and enabled integrations may use additional tools and should give their own notice. We review new tracking or embedded tools before enabling them and provide any required choices.
Optional notification preferences can be changed where offered in the profile or message. Essential service, security and legally required notices may still be sent. A request to stop marketing can be sent to us or to the business sending it. Do not assume ending a call automatically blocks future contact.
Security and retention
We use access controls, business-specific permissions, secure connections and audit records. Phone transcripts, summaries and selected associated fields are encrypted at the application level. Authorised staff may access information where needed for support, security or a verified request. No system can guarantee absolute security. We assess suspected breaches and notify customers, affected individuals and regulators when applicable law requires it.
We keep information only for as long as needed for the purposes described here and applicable legal requirements. When no longer required, we take reasonable steps to destroy or de-identify it, subject to lawful retention duties.
Current implementation status: The schedule below is our approved retention schedule. General 90-day transcript cleanup and complete closed-account disposal are still being implemented, and expiry of all backups within 35 days has not been verified. Automatic deletion at these periods is not currently assured; information can remain beyond a target while these controls are incomplete. This does not remove our obligation to assess information that is no longer needed. Contact [email protected] to request a review, deletion or an explanation of the handling of particular records.
The approved schedule is:
| Information | Retention and disposal |
|---|---|
| Full phone transcripts and unnecessary conversation context | 90 days after the call ends, unless a documented lawful purpose requires longer. Useful booking details and necessary summaries follow the business-record schedule. |
| Diagnostic audio recordings | Seven days after creation, only where recording was specifically enabled with appropriate notice and consent. |
| Business records, supplied files, booking details, tasks and useful summaries | According to the customer's documented business purpose and applicable legal schedule. Review unnecessary information periodically; an open account alone is not a reason to retain everything. |
| Ordinary technical logs | 30 days after the event; avoid storing sensitive content. |
| Security and administrator activity records | 12 months after the event, with only necessary details retained. |
| Our sales enquiries and support correspondence | Review 12 months after the matter closes and remove unnecessary personal information; retain necessary contract, dispute or legal evidence under its applicable schedule. |
| Ordinary information in a closed account | Keep available for the 30-day export window, then remove through the disposal process, subject to necessary lawful retention. This includes associated records and attachments; provider-held knowledge and copies require their own disposal steps. |
| Recovery backups under our control | Target expiry within 35 days of backup creation. A copy made just before live-data disposal can therefore remain for up to a further 35 days. Supplier-held copies and legal holds have separate arrangements. |
| Necessary company financial records | At least seven years after the transactions covered by the records are complete, where the company record-keeping requirement applies. This is not a seven-year retention period for all conversations. |
The periods above must be applied across live records, attachments, phone actions, knowledge stores, logs and backups. Cleanup of retired xAI knowledge files and some temporary application records exists, but does not establish that the whole schedule is operating. The 30-day technical-log and 12-month security-record periods also remain subject to verification across the relevant systems. The backup period is a target until actual expiry is verified.
Necessary transaction, consent, complaint or dispute evidence may remain after other records are deleted. A requirement to retain financial evidence does not justify retaining an entire conversation indefinitely. Archiving, account closure, disabling a feature and erasure are different operations. Backups and supplier copies follow their own disposal processes; restored data must be handled consistently with earlier deletion and suppression decisions.
Access, correction and complaints
Contact [email protected] to request access or correction, raise a concern, or ask about deletion, restricted use or an unwanted communication. You can also contact [email protected] if you cannot reach us through the privacy address. Identify the business involved and enough information for us to locate the relevant records. We may verify identity or authority using proportionate checks.
Our business owner is initially responsible for privacy requests and incident coordination, reached through [email protected]. We aim to acknowledge ordinary privacy requests within two business days and provide a substantive response within 30 days, subject to applicable legal deadlines. If we need more time, we explain why. Where access, correction or deletion is limited by law or another person's rights, we explain the relevant reason and available complaint options. There is no charge for making a privacy complaint; any access charge must be permitted by law and explained in advance.
If you are dissatisfied, you can contact the Office of the Australian Information Commissioner through oaic.gov.au. You may also have rights to complain to another regulator under applicable law.
Children and other jurisdictions
The initial service supports Australian business customers and ordinary business operations. Health and care record systems, child-focused workflows, other workflows requiring special handling of sensitive information and service arrangements for overseas customers are not supported at launch. These uses may be considered later under a separately agreed scope and safeguards.
This scope does not guarantee that unsolicited information about children or other sensitive details will never arrive. We assess such information and restrict, remove or otherwise handle it appropriately, subject to applicable law. Customers must not deliberately configure unsupported collection or use.
Overseas suppliers can still process information for our Australian service as described above. Supporting overseas customer operations is a separate decision and would require assessment of the relevant privacy, communications and transfer obligations before activation. This policy does not itself execute a data processing agreement or international transfer instrument.
Changes
The date and version identify this policy. We update it when our handling changes and give appropriate notice of material changes before the new handling begins, obtaining additional consent where required. A policy update does not retrospectively authorise a new use of information.