Cruisy (the "Service") is provided by Claudia Bryant, trading as Cruisy, ABN 37 684 400 792 ("we", "us"). We are a CDR Representative of Fiskil Pty Ltd, an Accredited Data Recipient (ADR) under Australia's Consumer Data Right (CDR). We access your banking data only through Fiskil, acting as Fiskil's CDR Representative under a CDR Representative Arrangement. This CDR Policy explains how we handle CDR data. It sits alongside our Privacy Policy, which covers all other personal information.
If you connect a bank account, we collect your account details (account name, a masked account number, BSB, product type, balance) and your transactions (date, description, merchant, amount) through Fiskil under your CDR consent. We only ever collect the accounts you choose to share on your bank's own consent screen.
We use your CDR data solely to run the Service for your farm: displaying your transactions, categorising them into a farm bookkeeping vocabulary, matching them to your invoices and receipts, and preparing summaries such as BAS worksheets and cash-flow and net-worth reports. We do not sell CDR data. We do not use CDR data to train AI models. We disclose CDR data only to the service providers needed to run the Service (see "Who we share CDR data with" below); we do not disclose it to any other third party.
We share CDR data only with the providers needed to run the Service, and all of it stays in Australia: Supabase (our database and file storage, hosted in Sydney), Vercel (our application compute, pinned to Sydney), and Amazon Web Services (Amazon Bedrock, which runs our AI assistant inside our own AWS account in Australia). When you ask our assistant a question about your money, the details needed to answer it are processed by the AI entirely within Australia. Depending on the question, this can include a transaction's description, merchant and amount, an account's balance, a masked account number (last digits only), and your bank's name. We do not send your full account number, your BSB, or your bank login credentials to any AI provider, and CDR data is not used to train AI models. Our automatic overnight categorisation sends only a payee label, an amount and, where available, the bank's own category label. We do not disclose CDR data outside Australia.
You share CDR data only under a consent you give at your bank, which lasts at most 12 months and which we will prompt you to renew before it expires. You can withdraw your consent at any time: in the app under Settings, in Connections, or through your bank's or Fiskil's own consumer dashboard. Disconnecting a bank stops future collection; the CDR data already collected is then deleted or de-identified as described below, and we ask Fiskil to delete it on their side.
When your consent ends (by withdrawal, expiry, your election, or a direction from Fiskil), we delete or de-identify your CDR data. You may ask us to delete it entirely. We keep CDR data only as long as we need it to run the Service, and we destroy or de-identify redundant CDR data as soon as practicable, as the CDR Rules require. To ask what CDR data we hold, or to request its deletion, email claudia@grounded-ai.com.au.
You can see your shared transactions and accounts in the app at any time. To request a copy of the CDR data we hold, or to correct information, contact us at claudia@grounded-ai.com.au. If a correction concerns the source banking data itself (for example a wrong amount from your bank), that request is directed to your bank as the data holder; we will help you route it.
If you have a concern about how we have handled your CDR data, contact us first at claudia@grounded-ai.com.au. We will acknowledge your complaint promptly and aim to resolve it within 30 days. If you are not satisfied, you can complain to Fiskil as the Accredited Data Recipient, or to the Office of the Australian Information Commissioner (oaic.gov.au), which oversees the CDR.
We use the service providers named above to store and process CDR data on our behalf. We do not otherwise outsource the handling of CDR data. Fiskil, as the Accredited Data Recipient, is our CDR Representative principal.
We will post any changes to this CDR Policy on this page and update the date above.
Email us about CDR matters at claudia@grounded-ai.com.au.