Privacy Policy
Last updated: 28 September 2026 · Effective immediately
The short version: we collect as little as we can, we never sell your personal information, we don't use it for advertising, and you can ask us to delete it at any time by writing to info@sterlingbay.com.au.
1. Who we are
“Sterling Bay”, “we”, “us” and “our” refer to Sterling Bay, an Australian investment and technology business owned by David Ball, with technical consultancy provided by Tycho Luyben. We are the controller (the “APP entity” under the Australian Privacy Act 1988) of the personal information described here.
Contact: info@sterlingbay.com.au
2. What this policy covers
This policy applies to:
- the website at sterlingbay.com.au (the “Site”);
- the mobile, desktop and web applications that Sterling Bay publishes, including on the Apple App Store, Google Play, the Microsoft Store, the Mac App Store and for Linux (the “Apps”); and
- email and other correspondence with us, including investment pitches.
Some Apps may show an additional, app-specific privacy notice that describes features unique to that App. Where it does, that notice supplements this policy; if they conflict, the app-specific notice applies to that App.
3. Information we collect
3.1 Information you give us
- Contact and pitch information — your name, email address, company, and anything you choose to send us (such as a pitch deck, financial information or product links).
- Account information (Apps with accounts) — email address, display name, and authentication data such as a hashed password or one-time sign-in codes. Some Apps let you sign in with Apple or Google; we then receive only the details you agree to share (usually your name and email, or an Apple private-relay address).
- Content you create — messages, files, notes, settings and other content you enter into an App so that the App can provide its features. Where an App offers end-to-end or on-device encryption, we cannot read that content.
- Support requests — what you tell us when you ask for help.
3.2 Information collected automatically
- Server and security logs — when you visit the Site or an App talks to our servers, our hosting and content-delivery providers record technical data such as IP address, date and time, requested address, browser or device type and response status. We use these logs to keep services running, secure and free of abuse.
- Diagnostics (Apps) — crash reports and performance data (for example device model, operating-system version, app version and the error that occurred). Diagnostics are not used to identify you and are not used for advertising.
- Purchase information — if you subscribe or buy in an App, the payment is processed by Apple, Google or Microsoft (or, on the web, by our payment processor). We receive a confirmation of the purchase and its status; we never receive your full card details.
3.3 Device permissions
An App asks for access to your camera, microphone, photos, location, contacts, notifications or files only when a feature needs it, explains why at that moment, and works without it where it can. You can change these permissions in your device settings at any time. Data obtained through a permission is used only for the feature you are using — for example, microphone audio for voice input is processed to turn it into text and is not kept afterwards unless you save it.
3.4 Information we do not collect
We do not knowingly collect sensitive information (such as health, biometric, religious or political information), and we do not buy personal information from data brokers.
4. How we use information
- to provide, maintain and improve the Site and Apps, and the features you ask for;
- to create and secure your account, including detecting fraud, abuse and security incidents;
- to process purchases and subscriptions, and to provide receipts and support;
- to reply to your enquiries and investment pitches and to assess investment opportunities;
- to send service messages (for example security alerts or changes to these terms). We send marketing email only if you have opted in, and every marketing email has an unsubscribe link;
- to comply with the law and enforce our terms.
AI features. Some Apps include features powered by artificial-intelligence models. When you use such a feature, the content you submit is sent to the model provider solely to produce the response. We do not allow providers to use your content to train their models where we are able to opt out, and we do not use your content to train our own models without your explicit consent.
5. Legal bases (EU, UK and similar laws)
Where the GDPR or similar laws apply, we rely on: performance of a contract (providing the Apps you signed up for); legitimate interests (security, preventing abuse, improving our services, assessing pitches — balanced against your rights); consent (optional features, marketing, device permissions — which you can withdraw at any time); and legal obligations (for example tax records).
6. Who we share information with
We do not sell personal information, and we do not share it for cross-context behavioural advertising. We share it only with:
- Service providers who help us run the Site and Apps — hosting and content delivery, email delivery, authentication, crash reporting, payment processing and AI model providers — under contracts that require them to protect it and use it only on our instructions;
- App stores and payment platforms (Apple, Google, Microsoft) to process purchases, subscriptions and refunds, under their own privacy policies;
- Professional advisers (lawyers, accountants, auditors) under a duty of confidentiality;
- Authorities when required by law, or to protect the rights, property or safety of our users, the public or us;
- A successor if a business or App is sold or restructured, in which case this policy continues to apply to your information.
Pitch materials you send us are treated as confidential and are shared only with the people at Sterling Bay (and our advisers) who need them to assess the opportunity.
7. Cookies, analytics and tracking
The Site does not use advertising or analytics cookies, tracking pixels or third-party trackers, and loads no third-party fonts or scripts. Our Apps do not track you across other companies' apps and websites, and do not access your device's advertising identifier (IDFA/AAID) for tracking. If an App ever wants to do so, it will ask for your permission first, using Apple's App Tracking Transparency prompt on iOS.
8. Children
The Site and our Apps are not directed to children under 13 (or under 16 where local law sets a higher age), and we do not knowingly collect personal information from them. If you believe a child has given us personal information, contact us and we will delete it.
9. International transfers
We are based in Australia, and some of our service providers store or process data in other countries, including in the European Union and the United States. When information leaves your country we take reasonable steps to ensure it is protected to a standard comparable to Australian law and, where applicable, use safeguards such as the European Commission's Standard Contractual Clauses.
10. How long we keep information
| Information | Kept for |
|---|---|
| Account and App content | While your account is active; deleted within 30 days after you delete your account (backups roll off within a further 30 days) |
| Server and security logs | Up to 90 days, unless needed to investigate an incident |
| Diagnostics / crash reports | Up to 90 days |
| Purchase and tax records | Up to 7 years, as required by Australian tax law |
| Pitches and correspondence | As long as reasonably needed to assess and follow up the opportunity, then deleted on request |
11. Security
We protect information with encryption in transit (TLS), encryption at rest where supported, least-privilege access, strong authentication for staff systems and regular security updates. Several Apps also offer end-to-end or on-device encryption, so that only you hold the keys. No system is perfectly secure; if a data breach is likely to cause you serious harm, we will notify you and the relevant regulator as the law requires (including under Australia's Notifiable Data Breaches scheme).
12. Your rights and choices
Depending on where you live, you may have the right to:
- access the personal information we hold about you and receive a copy of it;
- correct information that is wrong or out of date;
- delete your information (see section 13);
- object to, or restrict, certain processing, and withdraw consent;
- data portability — receive your data in a machine-readable format;
- opt out of marketing at any time;
- not be discriminated against for exercising these rights (California).
Email info@sterlingbay.com.au from the address linked to your account. We reply within 30 days, and we may need to verify your identity first. There is no charge for a reasonable request.
13. Deleting your account and data
You can delete your account and associated data at any time, either from within the App (Settings → Account → Delete account, where available) or by following the steps on our Delete your data page. Deleting an App from your device does not delete your account, and does not cancel a subscription — manage subscriptions in your Apple, Google or Microsoft account settings.
14. Changes to this policy
We may update this policy as our services or the law change. We will change the “last updated” date above and, for significant changes, notify you in the App or by email before they take effect.
15. Contact and complaints
Questions, requests or complaints: info@sterlingbay.com.au. We aim to resolve complaints within 30 days. If you are not satisfied, you may complain to the Office of the Australian Information Commissioner (oaic.gov.au) or, in the EU/UK, to your local data-protection authority.