Last updated: 25 October 2026
This policy explains how Bezeled Pty Ltd (ACN 691 164 315, ABN 12 691 164 315), trading as Cupid ("Cupid", "we", "us", "our"), handles personal information in connection with the Cupid website at cupid.legal and the Cupid CPD management application.
Cupid is a continuing professional development record-keeping tool for Australian legal practitioners and the firms, chambers and in-house teams they work in. The information we hold is professional information about a person's practice: what they did, when, under which category, and the evidence that it happened. This policy is written for the practitioner whose record it is and for the person doing privacy and procurement review at a firm, so it states what we do, what we do not do, and where the limits are.
It should be read with the Security and data handling page, the Cookie Policy and the Terms of Use. Where the Security page describes a control in more detail, this policy links to it rather than restating it.
1.Summary
The full policy follows. In short:
- We hold account details, practising details, CPD activities, evidence documents, credentials, session and attendance records, billing status, and the technical records needed to run and secure the service.
- We do not use artificial intelligence on your records, and we do not send them to any AI provider. No model is trained on anything you put into Cupid. See section 11.
- We do not sell personal information, we do not disclose it for anyone else's marketing, and the application carries no advertising or marketing cookies.
- A firm workspace is the firm's. The firm decides who is in it and what is recorded there. Cupid holds and processes that information on the firm's instructions. See section 3.
- Some of what a firm records about a practitioner is sensitive information under the Privacy Act, and is handled to a higher standard. See section 6.
- Some of our service providers are outside Australia. We do not make a data residency commitment. See section 15.
- You can ask us for access to your information, ask us to correct it, or complain, at hello@cupid.legal. See sections 20 and 24.
2.Our commitment to the Privacy Act
Bezeled Pty Ltd may currently fall below the three million dollar annual turnover threshold at which the Privacy Act 1988 (Cth) automatically applies to a business. We do not rely on that exemption.
We handle personal information in accordance with the Privacy Act 1988 (Cth) and the thirteen Australian Privacy Principles, and we treat the obligations in this policy as binding commitments to the individuals whose information we hold and to the firms that engage us. Where this policy states that we will do something, we hold ourselves to it whether or not the Act presently compels it.
We take this position because the information in Cupid belongs to a regulated profession, and because a firm that is itself an APP entity cannot discharge its own obligations by handing records to a supplier that has not accepted equivalent ones.
Where the General Data Protection Regulation or the UK GDPR applies to a person's information, section 22 sets out the additional rights and the lawful bases we rely on.
3.The two positions Cupid occupies
The Privacy Act does not use the words "controller" and "processor", but the practical distinction matters here, because Cupid holds information in two different capacities.
Where we decide. For your Cupid account itself, for the marketing website, for demonstration workspaces, for billing, for support correspondence and for the security and operational records that keep the service running, we decide what is collected and why. We are responsible for that handling, and this policy governs it in full.
Where your firm decides. A firm workspace exists because a firm created it. The firm decides which practitioners and staff are members, what CPD information is recorded, which categories and requirements apply, who inside the firm may see another member's record, whether internal sessions are run, who is emailed about them, and what is exported. We hold and handle that information on the firm's instructions and to provide the service. The firm is responsible for having a lawful basis to hold its members' records, and for its own privacy obligations to them.
What that means in practice:
- If you are a member of a firm workspace and you want to know why your firm records something, who inside the firm can see it, or how long the firm intends to keep it, ask your firm first. We cannot answer for the firm's decisions.
- If you ask us for access to, or correction or deletion of, information held in a firm workspace, we will help you, and where the request concerns the firm's own records we will refer it to the firm and tell you that we have done so. See section 20.
- If you use Cupid as an individual practitioner outside any firm workspace, only the first position applies. The record is yours.
Under the GDPR, the first position is that of a controller and the second is that of a processor.
4.Whose information this policy covers
- Practitioners and staff who hold a Cupid account.
- People invited to a workspace who have not yet accepted.
- People named in a workspace's records without holding an account, such as an external speaker credited on an internal session, or an attendee recorded at one.
- Visitors to the marketing website, and people who start a demonstration workspace.
- People who contact us for support, sales or security reasons.
Cupid is not for people under 18. See section 25.
5.The personal information we handle
| Category | What it includes | Where it comes from |
|---|---|---|
| Account and identity | Name, email address, profile image, username, whether a password is set, email verification status, and the account's role | You, or an administrator who invites you |
| Authentication | Password hashes, two-factor authenticator secrets and backup codes, session tokens, sign-in provider account identifiers and tokens, device and session records including IP address and browser user agent | Generated when you sign in; identity providers |
| Practising details | Profession, practising jurisdiction, practising certificate type, job title, practising role, practice periods, and the regulator practitioner identifier where you supply one | You, or a firm administrator |
| CPD activities | Activity title, date, provider, delivery format, category, unit or point value, duration, notes and free-text descriptions | You, or a person your firm has authorised to record on your behalf |
| Evidence and documents | Certificates, receipts, agendas, materials, and any other file uploaded as evidence, together with its file name, type and size | You, or an authorised person in your firm |
| Credentials | Practising certificates, specialist accreditations and licences: type, name, issuing body, reference number, issue and expiry dates, status, and any uploaded document | You, or a firm administrator |
| Exemptions and adjustments | The reason a reduced requirement applies, any supporting note, the deciding authority and its reference, conditions, and any supporting document | You, or a firm administrator |
| Sessions and attendance | Internal sessions you organise, present at, are invited to or attend; your response to an invitation; attendance confirmation; and generated certificates | Your firm's workspace |
| Session mailing lists | For somebody who asks a firm to email them about its future sessions: name, email address, organisation, when they asked, the session page they asked it on, the wording they agreed to, the session emails that firm has sent them, and when they unsubscribed | You, when you register for a firm's session |
| Firm community content | Posts, comments and reactions in a workspace's internal community spaces, where a firm has enabled them | You and your colleagues |
| Workspace identity | Firm trading and legal name, ABN and ACN, phone, website and principal place of business. For a sole practitioner these may also be personal information | A firm owner or administrator |
| Billing and session tickets | Subscription details; for tickets, purchaser name, email, organisation and optional practitioner ID, amount and GST, payment/refund/dispute identifiers and status, the organising firm’s connected-account identifier, and accepted ticket terms | Stripe, Cupid and the organising firm |
| Communications | Support, sales and security correspondence; transactional-email records; and, where you opt in on a public session page, the consent wording and version, time, source session, unsubscribe history and promotional session emails sent for that organising firm | You, the organising firm, and our email provider |
| Technical and security | Application and error logs, request metadata, IP addresses, timestamps, rate-limiting counters, and aggregate page-view and performance measurements | Generated when the service is used |
| Audit trails | The workspace's own activity trail, and our separate append-only record of administrative acts by Cupid staff | Generated by the service |
| Demonstration and enquiry | Name, email address, job title, practising role and the persona chosen when starting a demonstration workspace | You |
We do not receive your full payment card details. Card data is entered directly with Stripe and we receive subscription and ticket payment identifiers, amounts, payment outcomes, refunds and dispute information from Stripe.
6.Sensitive information
Some information a CPD record can carry is sensitive information under section 6 of the Privacy Act 1988 (Cth), and attracts a higher standard than ordinary personal information. In Cupid this arises in three places:
- Exemption reasons. A reduced or waived CPD requirement may be recorded against a reason such as illness or parental leave, and may carry a supporting note or document. An exemption recorded on health grounds is health information, and health information is sensitive information.
- Evidence and credential uploads. These fields accept a document you choose. A medical certificate, a regulator's decision, or correspondence about a personal circumstance would be sensitive information if uploaded.
- Free-text fields. Activity notes, exemption notes and community posts accept whatever is typed into them.
Our position on all three:
- We do not ask for sensitive information, and the service does not require it. An exemption can be recorded without stating a medical reason and without attaching a document. Where a firm's own policy or a regulator's process requires supporting material, that requirement is the firm's or the regulator's, not ours.
- We collect sensitive information only where the individual it concerns has consented and it is reasonably necessary for the CPD record, or where the Act otherwise permits it. Recording it yourself is consent for us to hold it for that purpose.
- Where a firm administrator records sensitive information about a practitioner, the firm is responsible for obtaining that practitioner's consent. We rely on the firm's assurance that it has done so.
- Sensitive information is protected by the same access controls as the rest of the record, and is not used for any purpose beyond the one it was recorded for.
Please do not upload documents containing more than the CPD record needs. If a certificate of attendance will do, a document that also discloses a health condition should not be uploaded in its place. If sensitive information has been recorded in error, tell us and we will remove it.
7.Government related identifiers
The service can store a regulator practitioner identifier — the number a legal profession regulator or admitting authority has assigned to a practitioner — where you or your firm chooses to record one. Some of these are government related identifiers under the Privacy Act.
- We do not adopt any government related identifier as our own identifier for you. Accounts, workspaces and records are keyed to identifiers we generate ourselves.
- We use and disclose a regulator practitioner identifier only to prepare and populate a submission to the regulator that assigned it, such as a lodgement file for a professional standards scheme, and only where you or your firm directs us to.
- We do not use one to link records across firms, to match against any external dataset, or for any analytical purpose.
8.How we collect personal information
We collect personal information by lawful and fair means, and wherever reasonably practicable from the individual it concerns. In practice it reaches us in five ways:
- Directly from you, when you create an account, complete onboarding, record an activity, upload a document, respond to an invitation, contact us, or start a demonstration workspace.
- From your firm, when an administrator invites you, imports a roster, records an activity on your behalf under a permission or delegation you or the firm has granted, runs an internal session, or confirms your attendance at one.
- From an identity provider, when you choose to sign in with Google or Microsoft. We receive the account information covered by the permission shown to you at sign-in, and no more.
- From a service provider, such as subscription status from Stripe, or delivery and bounce outcomes from our email provider.
- Automatically, when the service is used: logs, request metadata, timestamps, session records, and aggregate website measurements.
If we ever receive personal information we did not solicit and could not have collected lawfully, we destroy or de-identify it as soon as practicable, unless it is contained in a Commonwealth record or the law requires us to keep it.
9.Why we use personal information
We use personal information only for the purposes below, for a directly related purpose you would reasonably expect, or for a purpose you have consented to.
| Purpose | What it involves | Lawful basis where the GDPR applies |
|---|---|---|
| Providing the service | Creating and authenticating accounts, running workspaces, applying roles and permissions, recording activities, storing evidence and credentials, running sessions and attendance, issuing certificates, producing exports and audit packs | Performance of a contract |
| Calculating CPD position | Applying the published requirements for your profession and jurisdiction to your recorded activities to show units, categories, carry-over and remaining requirement | Performance of a contract |
| Reminders and notifications | Verification, invitation, security, expiry, threshold and session emails, and the in-application inbox | Performance of a contract; legitimate interests |
| Session mailing lists | Emailing people who asked a firm to tell them about its future sessions, on that firm's instructions, with an unsubscribe link in every email and no further email once somebody leaves the list | Consent |
| Support | Answering your questions, investigating faults, and correcting records | Performance of a contract; legitimate interests |
| Billing | Establishing and reconciling subscriptions, and administering plan capacity | Performance of a contract; legal obligation |
| Security and integrity | Authentication, rate limiting, bot protection, fraud and abuse prevention, incident detection and investigation, and the audit trails | Legitimate interests; legal obligation |
| Service reliability | Error monitoring, performance measurement and diagnosing faults | Legitimate interests |
| Improving the service | Understanding which features are used, in aggregate and de-identified form wherever it will do | Legitimate interests |
| Sales and marketing | Responding to enquiries, and following up a demonstration you started | Consent; legitimate interests |
| Firm session marketing | Sending a firm's future-session announcements only where an outside attendee expressly opted in on that firm's public registration page | Consent |
| Legal and regulatory | Meeting our obligations, keeping the records the law requires, and establishing or defending a legal claim | Legal obligation; legitimate interests |
We do not use CPD records, evidence, credentials or workspace content for advertising, for profiling, or for any purpose unrelated to running the service. We do not sell personal information and we do not disclose it to anyone for their own marketing.
Where we publish or share aggregate figures about how the service is used, they are de-identified first and we do not attempt to re-identify them.
10.Automated processing and how CPD position is calculated
Cupid calculates a practitioner's CPD position by applying published requirement rules to the activities recorded against that practitioner. This section is provided in the terms of Australian Privacy Principle 1.7.
- The information used in the calculation is: your profession, your practising jurisdiction, your practising certificate type and practice periods, the CPD year, your recorded activities and their categories and unit values, and any recorded exemption or adjustment.
- The rules applied are the published requirements of the relevant regulator, encoded as deterministic rules. The calculation contains no artificial intelligence, no machine learning, no scoring model and no profiling. The same inputs always produce the same output, and the rules that produced it are shown alongside it.
- Cupid does not make decisions about you. It shows a calculated position and the evidence behind it. Whether you have met your obligations is a matter for you and your regulator, and a progress figure or export from Cupid is not a regulator's finding. This is stated in clause 1.2 of the Terms of Use.
- Cupid does not decide your employment, your engagement, your remuneration or your standing at your firm. If your firm uses information from Cupid when making such a decision, that decision is the firm's, made by people at the firm, under the firm's own policies.
11.Artificial intelligence
Cupid uses no artificial intelligence or machine learning to process your information.
Specifically:
- No account information, CPD activity, evidence document, credential, session record, community post or export is sent to any large language model, generative AI service or third-party AI provider, by us or on our behalf.
- No model, ours or anyone else's, is trained, fine-tuned, evaluated or improved on anything held in Cupid.
- The application contains no AI assistant, no automated summarisation of your records, and no AI-generated content derived from them.
- Nothing in a workspace is exposed to search engine crawlers or AI crawlers. Workspace content sits behind authentication and is never published.
If this ever changes, we will say so in this policy before the change takes effect, we will explain what the feature does and what it is given, and where consent is the appropriate basis we will ask for it rather than assume it.
12.Who can see a practitioner's record inside a firm
Within a firm workspace:
- A practitioner can always see, export and download their own record, its evidence and its history, for as long as the workspace is active.
- Holding an owner or administrator role does not by itself grant access to a colleague's CPD record. Access requires either a record-access capability the firm has granted, or a standing delegation the practitioner has made and can withdraw. Both are written to the workspace's audit trail.
- Where such access exists, it can extend to activities, categories, units, evidence documents, credentials, exemptions and attendance.
- Community spaces, where a firm enables them, are visible to the members of the space. Posts, comments and reactions are attributed to their author.
- A firm can require two-factor authentication of every member, and controls whether members may change their own work email address and whether a practitioner may email their own record outside the firm. Turning off outbound email never prevents a practitioner downloading their own record.
Regulators have no direct access to Cupid. A practitioner or firm decides what to export and provide to a regulator.
Section 2 of the Security and data handling page describes these boundaries in more detail.
13.Access by Cupid staff
We state this plainly because a firm assessing us is entitled to know it.
- A small number of Cupid personnel can access production systems, and through them the information in a workspace, in order to operate the service, investigate a fault, restore data, or answer a support request.
- Cupid personnel can, in limited circumstances, sign in to the application as a user in order to reproduce a fault that cannot be diagnosed any other way. This is done through a single-use link that expires shortly after it is issued, and the resulting session is marked as an impersonated session.
- Every administrative act by Cupid personnel is written to an append-only operator audit trail recording who acted, on which account or workspace, when, from which address, and what was done. The trail cannot be edited or deleted, including by us.
- Access is limited to what the task requires. We do not read CPD records for any purpose other than operating the service and responding to a request or an incident.
- Cupid personnel are bound by confidentiality obligations, and access is removed when a person's role no longer requires it.
If you would prefer that we do not access your workspace to investigate a support request you have raised, tell us, and we will work from the information you can give us instead.
14.Who we disclose personal information to
We disclose personal information to the following categories of recipient, and to no others:
Your firm. Where you are a member of a firm workspace, to the people in that firm whose role, capability or delegation gives them access. See section 12.
Service providers. The providers listed in section 15, each for the function stated there and under contractual obligations of confidentiality and security.
Professional advisers. Our lawyers, accountants, insurers and auditors, where reasonably required and under obligations of confidentiality.
Authorities and legal process. Where we are required or authorised by law, including in response to a valid legal process; where reasonably necessary to establish, exercise or defend a legal claim; or where necessary to lessen or prevent a serious threat to life, health or safety. Where we are permitted to tell you about a compelled disclosure, we will.
A successor. If our business or a relevant part of it is transferred, personal information may transfer with it. The recipient would be bound by this policy or a policy no less protective until we notified you of any change.
We do not disclose personal information to data brokers, advertising networks or any recipient for their own purposes.
15.Service providers and overseas disclosure
The service is configured to use the providers below. Which of them handle information depends on the production configuration and the features in use.
| Provider | Function | What it handles | Where it is likely to process |
|---|---|---|---|
| Vercel | Website and application hosting; aggregate web analytics and performance measurement | Request metadata, IP address, page and performance measurements | United States, and its global edge network |
| PostgreSQL hosting provider | The application database | All application records | To be confirmed on provisioning; may be outside Australia |
| S3-compatible storage provider | Evidence, credential and generated documents | Uploaded and generated files | To be confirmed on provisioning; may be outside Australia |
| Stripe | Subscription and session-ticket payment processing, connected-account onboarding and payouts | Billing contact, subscription and ticket transaction data. Card details go directly to Stripe and are not disclosed to us | United States and Australia |
| Resend | Transactional email delivery | Recipient name and address, message content, delivery and bounce outcomes | United States |
| Google, Microsoft | Optional external sign-in, at your choice | Authentication with the identity provider you select | United States and their global infrastructure |
| PostHog | Product analytics, disabled for the soft launch | No information is sent while disabled | European Union, if enabled in a future release |
| Sentry | Error monitoring, where configured | Error reports, which may include request metadata and account identifiers | United States |
| Cloudflare | Bot protection on public forms, where configured | Request metadata and IP address | Global network |
Overseas disclosure. Some of these providers are located outside Australia, or process information outside Australia, most commonly in the United States. By using Cupid you acknowledge that your information may be handled overseas by the recipients above.
Before disclosing personal information to an overseas recipient we take reasonable steps to ensure it is handled consistently with the Australian Privacy Principles, including by contract. We do not ask you to consent to an overseas disclosure in a way that would release us from accountability for it. Where APP 8.1 applies, we remain accountable for the recipient's handling.
We do not make a data residency commitment. We do not currently guarantee the country in which application data or its backup replicas are stored. If your firm requires an Australian data residency commitment, ask us before contracting rather than assuming one. This is also stated in section 8 of the Security and data handling page.
We publish this register so that a firm can assess it. We will update it when a provider changes.
16.Direct marketing
- Transactional messages — verification, invitations, security notices, expiry and threshold reminders, session notices and billing notices — are part of the service and are not marketing. They cannot be switched off entirely while your account is active, though notification preferences control many of them.
- Cupid marketing messages are sent only where you have asked for them, or where you gave us your details in a commercial context such as starting a demonstration workspace or making an enquiry, and we are following that up.
- A firm's session announcements are sent only if you tick the unticked, optional box naming that firm on one of its public registration pages. We keep the wording version, time and source session as the consent record. The firm can export its currently subscribed contacts to its own email service and is responsible for how it uses that export.
- Every marketing message sent through Cupid identifies the firm or Cupid as applicable, carries an unsubscribe link, and records the request immediately. The link does not require a Cupid account. A firm may also record an unsubscribe for you if you ask it another way.
- We do not use CPD records, evidence, credentials or workspace content to target marketing, and we never disclose personal information to any other party for that party's marketing.
- We record whether an email was delivered, bounced or was reported as spam. We do so to keep the service's email working and to stop sending to addresses that fail. We do not track whether you opened an email, and we do not track whether you clicked a link in one.
- You can ask us at any time to stop sending you marketing, and to tell you where we got your contact details, by writing to hello@cupid.legal.
17.Cookies, analytics and website measurement
The application uses cookies that are necessary to keep you signed in and to remember interface preferences. The public website uses Vercel Web Analytics and Vercel Speed Insights for aggregate page views and performance measurements without third-party cookies. These measurements exclude signed-in pages, private record and certificate links, attendance pages and authentication pages; query strings are removed before measurement.
Product analytics, campaign attribution cookies and session recording are disabled for the soft launch. Cupid does not record your screen or send account-linked usage histories to PostHog. Error monitoring remains available to diagnose service failures, with request bodies, session credentials and private link tokens removed before reporting.
The website and the application carry no advertising cookies, no marketing cookies and no cross-site tracking.
The Cookie Policy sets out the detail.
18.Security
We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification and disclosure. The measures include workspace-scoped queries on every request, role and capability checks on record access, hashed passwords, optional and firm-enforceable two-factor authentication, session listing and revocation, rate limiting on authentication and public write endpoints, sign-in that does not disclose whether an address has an account, private document storage served through short-lived single-purpose links, upload validation against a file's actual contents, and encryption in transit.
The Security and data handling page describes these controls, the assurance process behind them, and what we do not claim — we do not hold ISO 27001, SOC 2 or an equivalent third-party attestation, and we do not make a data residency commitment.
No online service can guarantee absolute security. Keep independent copies of any document that is critical to your professional obligations, and report a suspected compromise to hello@cupid.legal.
19.How long we keep personal information
We keep personal information only while it is needed for a purpose set out in this policy, or while the law requires us to keep it. When it is no longer needed, we destroy it or irreversibly de-identify it.
| Information | While in use | After closure, or a deletion request |
|---|---|---|
| CPD records, evidence, credentials, attendance and certificates | While the workspace is active | An export is offered first. Records and stored files are deleted within 30 days unless a documented legal hold applies |
| Account and workspace identity information | While the account is active | Deleted or irreversibly anonymised within 30 days |
| Application audit and security logs | Operational need | Rolling 90 days, unless preserved for an active incident or a legal requirement |
| Operator audit trail | Retained as an integrity record | Retained; it records that an act occurred and by whom |
| Database and file backups | Disaster recovery | Daily recovery points kept for 35 days, so deleted records age out of backups no later than 35 days after deletion |
| Billing and transaction records | While the subscription is active | Up to seven years, where required for tax, accounting or audit purposes |
| Marketing and enquiry contact details | While the relationship is live | Deleted on unsubscribe or request, or when no longer needed for the follow-up |
Backups exist to restore the service, not to retain information a customer has asked us to remove. Where information cannot be deleted immediately because it sits in a backup, it is isolated from further processing until the backup expires.
Records created inside a firm workspace may remain part of that firm's records after you leave the firm, in the same way that other records of your employment do. Export your own record before you leave if you need it. Contact us before closing a workspace if you need an export or want to know what will be deleted.
20.Access, correction and deletion
Access. You can see and edit much of your information directly in the application, and you can export your CPD record and download your evidence at any time. For anything else, write to hello@cupid.legal. We will confirm your identity, then respond within 30 days. There is no charge for making a request; if a request requires substantial work we will tell you about any charge before we incur it, and it will not apply to making the request itself.
Correction. Tell us if information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, and we will correct it. Name, profession and some practising details are deliberately not self-editable, because a record that cites them is relied on by a firm and a regulator; write to us and we will correct them. If we decline to correct something, we will give you our reasons in writing and, if you ask, attach a statement of your view to the record so that anyone who later reads it sees both.
Deletion. You can request deletion of your account in the application. Where your information is part of a firm workspace, see section 3 and section 19: the firm's records are the firm's, and we will refer the request to the firm and tell you we have done so.
If we refuse. If we refuse a request for access or correction, we will tell you why in writing, and how to complain about the refusal.
Requests about a firm workspace. Where a request concerns information a firm decides about, we will help where we can, and pass the request to the firm where we cannot. We will not delete a firm's records on the instruction of a member without the firm's authority, and we will not disclose one member's records to another member who is not authorised to see them.
21.Anonymity and pseudonymity
You can browse the Cupid marketing website, read the documentation, and start a demonstration workspace without telling us who you are.
You cannot use the CPD application anonymously or under a pseudonym. A CPD record has to be attributable to a named practitioner with a stated profession and jurisdiction, because that is what makes it usable for the purpose it exists for. This is a case where it is impracticable for us to deal with an individual who has not identified themselves.
22.If the GDPR or UK GDPR applies to you
Where you are in the European Economic Area, the United Kingdom or Switzerland, the following applies in addition to the rest of this policy.
Controller. Bezeled Pty Ltd is the controller for the handling described in the first position in section 3. Where the second position applies, your firm is the controller and we are its processor.
Lawful bases. The bases we rely on are set out in the table in section 9. Where we rely on legitimate interests, those interests are providing and securing a service our customers have asked for, and we have assessed them against your rights and freedoms.
Your rights. Subject to the conditions in the legislation, you may request access to your personal data, its rectification or erasure, restriction of its processing, or its portability in a structured, commonly used, machine-readable format. You may object to processing based on legitimate interests, and to direct marketing at any time. Where we rely on consent, you may withdraw it at any time, which does not affect processing already carried out.
Transfers. Personal data will be transferred to and processed in Australia and in the countries listed in section 15. Where a transfer leaves the EEA or the UK we rely on an adequacy decision where one exists, and otherwise on the European Commission's or the UK's Standard Contractual Clauses together with any additional measures the transfer requires. You can ask us for information about the mechanism applied to a particular transfer.
Complaints. You may complain to the supervisory authority in your country of residence, place of work, or the place of the alleged infringement.
Exercise any of these rights by writing to hello@cupid.legal.
23.Data breaches
We maintain a written incident procedure: contain, escalate, assess, remediate, notify, review. A suspected disclosure of one firm's information to another is treated as our highest severity of incident.
If we suspect an eligible data breach, we will assess it promptly and complete the assessment within 30 days. Where the breach is likely to result in serious harm and we cannot prevent that harm through remedial action, we will notify affected individuals and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme, and we will give affected firms a named contact.
Where we hold information for a firm, we will notify the firm promptly so that it can meet its own obligations, and we will not delay our own notification in doing so.
24.Complaints
If you think we have breached the Australian Privacy Principles or mishandled your personal information, tell us first.
Write to: hello@cupid.legal, marked for the attention of the Privacy Officer.
Please describe what happened, when, and what outcome you are looking for. We will acknowledge your complaint within 7 days, investigate it, and give you a written response within 30 days. If we need longer, we will tell you why and when to expect a response.
If you are not satisfied with our response, or we do not respond within 30 days, you can complain to the Office of the Australian Information Commissioner:
- Online and by post: oaic.gov.au/privacy/privacy-complaints
- Telephone: 1300 363 992
The OAIC generally expects you to raise your complaint with us first and to allow us 30 days to respond.
25.Children
Cupid is a professional tool for admitted legal practitioners and the people who work with them, and is not directed to anyone under 18. We do not knowingly collect personal information from a child. If we learn that we hold information about someone under 18, we will delete it.
26.Changes to this policy
We will update this policy when our handling of personal information changes, when a service provider changes, or when the law changes. The date at the top identifies the current version.
Where a change materially affects how we handle your information, we will tell account holders before it takes effect, by email or through the application, rather than relying on you to notice the date. The application records which version of our legal documents an account has accepted.
27.How to contact us
- Entity — Bezeled Pty Ltd, trading as Cupid
- ACN — 691 164 315
- ABN — 12 691 164 315
- Privacy contact — hello@cupid.legal, marked for the attention of the Privacy Officer
Write to us for a privacy question, an access or correction request, an unsubscribe request, a complaint, or a security report.
Public session registrations and ticket purchases
You can register for a firm's public session without creating a Cupid account. The organising firm receives your registration and attendance details to run the session, deliver joining instructions and prepare attendance certificates. An optional, unticked box lets you separately ask that named firm to email you about its future sessions. Leaving it unticked does not affect registration. If you tick it, the firm can send session announcements through Cupid or export its currently subscribed list, and you can unsubscribe from any announcement without an account. Cupid records the ticket terms version, acceptance time and the organiser's refund terms at purchase. A browser recovery token allows you to resume or close your own pending checkout; the server stores a hash rather than the token itself.
Contact the organising firm or hello@cupid.legal for access, correction, export or deletion requests concerning an outside-attendee registration. We verify the requester's identity before disclosing or changing records. Payment records must first be reconciled; cancelling a session does not delete the transaction history. Accounting, refund and dispute records may need to be retained for those purposes, and we will explain any applicable retention requirement when handling a deletion request. Optional organisation and practitioner ID fields are used only for the session and its attendance records.