← oswin.com.au · Terms and Conditions
Last updated: 18 June 2026
Oswin AI handles your financial documents — bank statements and receipts. Even though a small business under a certain size can be exempt from parts of Australia's privacy law (the Privacy Act 1988 and its Australian Privacy Principles, or APPs), we have chosen to follow that law as best practice. Anyone trusting us with their financial records deserves that standard. We commit to handling your personal information in accordance with the APPs, and we apply these protections regardless of whether we are strictly required to.
Oswin AI is an AI-led Australian technology company. Our first product, Oswin, is an automated bookkeeping reconciliation tool for Australian small businesses: you upload your bank statements and receipts, and our tool reads them and matches (reconciles) the transactions for you.
In this policy, "Oswin AI", "we", "us" and "our" mean Smart Saving Bookkeeping Pty Ltd (ABN 59 679 618 494; ACN 679 618 494), trading as Oswin AI, based in Australia. "Oswin" is our product — the bookkeeping reconciliation service this policy relates to. Our website is https://oswin.com.au and our contact email is admin@oswin.com.au. "You" and "your" mean the person using Oswin, or the business they are using it for.
What this policy does and does not cover. This policy covers how we handle your personal information. Pricing, account credit, top-ups, refunds and your consumer rights are covered in our Terms and Conditions, not here.
"Personal information" means information about you as an identified or identifiable individual. We collect:
To use the reconciliation tool, you upload bank statements and receipts. These documents, and the financial information inside them (such as transaction amounts, dates, account details, merchant names and payment details), are the core of what we hold for you. We treat them as highly sensitive because a breach of financial records can cause real harm — for example financial loss or identity theft.
Please note: receipts and statements can sometimes contain information you did not expect — for example, a receipt from a pharmacy or medical provider could reveal health-related details. Where any such sensitive information (a special category under the Privacy Act that attracts higher protection) appears in your uploads, we handle it with the same care as the rest of your financial documents and only use it as part of providing the reconciliation service. We do not deliberately collect sensitive information — where it appears in a document you upload, we collect it only because you have chosen to upload that document, and only to the extent reasonably necessary to provide the reconciliation service; we do not separately seek it out. We recommend you only upload documents relevant to your bookkeeping.
We do not buy personal information from list brokers, and we do not use bank-feed integrations to pull your data automatically — you upload your own documents. If we ever add bank-feed / open-banking integrations or any other indirect collection, we will update this section and Sections 2 and 6, and additional Consumer Data Right obligations may apply.
We collect, hold, use and disclose your personal information to: provide the reconciliation service; create and manage your account; manage credit and billing; support you; run, secure and improve the service; and meet our legal obligations.
We only use your information for the purpose we collected it for, or for a related purpose you would reasonably expect — or where you have consented, or the law allows or requires it. We do not sell your personal information, and we do not disclose it to third parties for their own marketing.
We may send you service messages (for example about your account, security, or changes to the service) — these are part of providing the service. We may also occasionally send you news or product updates about Oswin. Any such marketing is on an opt-out basis: every marketing message includes an easy way to unsubscribe, and you can opt out at any time by emailing admin@oswin.com.au, or in your account settings. We do not use your information for third-party marketing.
We may create de-identified and aggregated data from your activity and use it to operate, analyse and improve Oswin — for example, to improve and test the accuracy of our reconciliation (matching) logic, and to understand how the service is used.
We do not sell this data and we do not share it with third parties for their own purposes. We use it only to run and improve Oswin's own service. We do not use your data to train any third-party AI provider's models (see Section 6). Any de-identification we do is genuine, not cosmetic.
You can opt out at any time by emailing admin@oswin.com.au, or in your account settings. If you opt out, we will still use your information to provide the service to you — we just won't use your de-identified data to improve Oswin.
Scope: this is limited to improving Oswin's own service using de-identified/aggregated data. It does not include training our own AI models on your data. If we ever want to do that, we will update this policy and ask for your consent first.
We use reputable third-party cloud and AI service providers to store and process your information. Depending on the provider and the function, your information may be stored or processed in Australia and/or overseas, and we may change or add providers over time.
Important — your documents are read overseas. To read the documents you upload, their contents are sent to a third-party AI provider which processes them overseas (currently the United States), under a contract that prohibits the provider from training its models on your data. We choose providers on terms that require secure handling and that prohibit AI providers from training on your data, and we remain responsible to you for handling your information in line with the Australian Privacy Principles. See Section 6 for more on overseas handling.
Your uploaded documents are linked to your account, so the service can read and reconcile them for you. They are held securely alongside your account details, and access is limited to what is needed to run the service.
We take reasonable technical and organisational steps to protect your personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. Because bank statements and receipts are highly sensitive, we scale the protection we apply to how sensitive the data is. No online service can promise perfect security. We take reasonable steps to protect your information, but we cannot guarantee it can never be accessed, disclosed or lost. Please keep your password confidential, and tell us promptly at admin@oswin.com.au if you think your account has been compromised.
We use a small number of trusted third-party service providers to help us run Oswin — for example, for reading your documents (our AI provider), cloud hosting and storage, payment processing, and email. We share personal information with them only as needed to provide the service, we require them to protect it, and we remain accountable for how they handle it.
To read and extract information from the documents you upload, we send their contents to a third-party AI provider that runs a large language model on our behalf. We do not run that provider's systems. We choose providers on terms that contractually prohibit them from training their models on your data and require secure handling, and we remain responsible to you for handling your data in line with the Australian Privacy Principles.
Some of your personal information is stored or processed overseas, and some may be stored or processed in Australia. In particular, the contents of your uploaded documents are sent to our AI provider overseas (currently the United States) to be read, and some of our other providers may store or process information overseas. Where information is handled overseas, we have contractual terms requiring those recipients to handle it consistently with the Australian Privacy Principles, and we remain accountable for it. We may also disclose your information where the law requires or authorises it, or to protect our rights, your safety, or the safety of others.
If you top up your credit, your card details are handled directly by a third-party payment processor; we do not store, see, or have access to your full card number.
We keep your personal information only for as long as we need it to provide the service and to meet our legal obligations.
The legal obligation to keep your own business records (for example for the ATO) rests with you, the business — our 7-year retention is a safety margin so your documents remain available, not a substitute for your own record-keeping.
You have the right to ask for a copy of the personal information we hold about you, and to ask us to correct anything that is wrong, out of date, incomplete or misleading. Email admin@oswin.com.au. We will respond within 30 days, free of charge. We may need to verify your identity first. If we cannot give you access or make a correction, we will explain why in writing and tell you how to take it further.
Where it is lawful and practical, you can deal with us without identifying yourself, or under a pseudonym — for example when making a general enquiry. However, to use the reconciliation service we need enough information to create and run your account (your name, email, business name and ABN), so the core service cannot be used anonymously or under a pseudonym.
We take the security of your financial documents seriously, and we follow Australia's Notifiable Data Breaches (NDB) scheme as best practice. If we have reasonable grounds to suspect an eligible data breach involving your personal information, we will assess it quickly (within 30 days at the latest) and contain and remediate it. If we then conclude that an eligible data breach is likely to cause serious harm and we cannot prevent that harm, we will notify you and the OAIC as soon as practicable and tell you what happened, what information was involved, and the practical steps you can take. Because we hold financial documents, we treat the risk of serious harm from any breach as high.
We may update this policy from time to time — for example as the product grows, or as our providers or the law change. We will change the "Last updated" date at the top and post the new version on https://oswin.com.au. If a change is significant, we will take reasonable steps to let you know.
For any privacy question, request or complaint: Email: admin@oswin.com.au · Website: https://oswin.com.au. For pricing, account credit, top-ups, refunds and your consumer rights, see our Terms and Conditions.