Privacy governance
Public-layer data governance, retention, and compliance operations
This is not the final entity-specific legal opinion. It is the governance layer Corteran has already implemented in product and operations: collection points, processors, retention rules, incident handling, and AI-use boundaries. It closes the gap between having a privacy page and having a visible governance posture.
Collection flows
5
Key borrower, investor, and capital-partner collection paths are mapped to public notices and route boundaries.
Processors
4
Database, file storage, notification, and AI support layers are now visible in a governance register instead of only in code.
Retention rules
4
Active workflow data, consent history, controlled-disclosure evidence, and audit material all have explicit retention posture.
Response controls
3
Complaints intake, rollback visibility, and incident controls are aligned; the remaining gap is the formal external playbook.
Point-of-collection coverage
These are the public paths that already carry a collection notice or an explicit handling boundary.
Flow
Route
Purpose
Cross-border / processor
Follow-up boundary
Status
Flow
Borrower contact
Route
/contactPurpose
Lead triage, borrower enquiry routing, and consent-aware follow-up.
Cross-border / processor
Cloud email, analytics, and CRM storage.
Follow-up boundary
Only when consent to follow up is granted.
Status
liveFlow
Borrower precheck
Route
/precheckPurpose
Readiness triage, missing-item detection, and routing.
Cross-border / processor
Document and AI support tooling may process outside AU.
Follow-up boundary
Linked to readiness, upload, and status center.
Status
liveFlow
Borrower upload
Route
/uploadPurpose
Document intake, checklist recovery, and next-step routing.
Cross-border / processor
Storage, notification, and review tooling.
Follow-up boundary
Used for document review and status updates.
Status
liveFlow
Investor access request
Route
/applyPurpose
Jurisdiction and eligibility review before controlled disclosure.
Cross-border / processor
Controlled diligence and notification vendors.
Follow-up boundary
Limited to request-related diligence review.
Status
liveFlow
Capital partner apply
Purpose
Mandate fit, access-tier screening, and diligence routing.
Cross-border / processor
Email, file review, and diligence operations.
Follow-up boundary
Limited to application handling and diligence.
Status
liveGovernance registers
Governance material that previously lived only inside the legal-pack export is now visible on the public layer for launch review.
Consent controls
3 rowsBorrower follow-up consent
Borrower ops
Captured through contact and consent-center flows, with grant/revoke history in audit logs.
Investor diligence follow-up
IR / investor ops
Investor access requests record controlled follow-up permission and qualification acknowledgements.
Capital partner application follow-up
Capital partnerships
Partner applications now capture disclosure and privacy acknowledgements before submission.
Processor register
4 rowsPrimary structured storage
Platform ops
Customer records, audit logs, tasks, and consent history are stored in the primary database layer.
Private object storage
Borrower ops
Borrower and diligence files are stored privately and referenced through controlled document workflows.
Email / notification processors
Ops automation
Ops notifications and diligence outreach rely on SMTP / mail-routing processors.
AI support tooling
Platform ops
AI is used for organisation and triage support with fallbacks and human-review boundaries.
Retention schedule
4 rowsBorrower precheck and upload records
Borrower ops
Retain while the borrower workflow is active and while dispute, compliance, or audit retention is still required.
Consent history
Compliance / ops
Keep grant and revoke history for auditability and preference handling.
Investor and partner access requests
IR / capital partnerships
Retain long enough to evidence controlled-disclosure handling and later complaints review.
Audit logs and release evidence
Platform ops
Retain for governance, dispute handling, release verification, and incident follow-up.
Incident response
3 rowsIncident triage and release rollback
Platform ops
Release state, rollback context, health status, and audit visibility now sit in admin settings.
Complaints intake path
Customer support
Public complaints page links concerns into contact, privacy, and dispute handling paths.
Regulator-ready breach playbook
Compliance
Still needs formal outside-the-app playbook and escalation timing matrix.
AI governance
3 rowsAI usage disclosure
Product / ops
Borrower forms and privacy notice now explain that AI is used for triage support only.
Human review gate
Borrower ops
Manual review exit remains contract-driven and blocks release when posture is misaligned.
AI output traceability
Platform ops
AI routing and workflow outputs are tied back into stored case state and audit-aware processes.
What still needs external confirmation
Related trust pages
Privacy notice
Review the public privacy notice, collection logic, sharing boundary, and preference path.
Public disclosures
Review entity facts, boundary posture, and where formal documents take over.
Complaints and concerns
Review the formal concern and complaint entry path.
Borrower credit guide
Review borrower-side routing, role boundary, and handoff posture.
Make the governance visible before the entity details are final
The common launch failure is not that a page is missing. It is that the governance posture stays implicit. Corteran now exposes the parts that can be made real inside the product; the remaining blocker is external legal fact confirmation.