Product and intended use
Define the configuration, people, information and tasks being assessed.
Search platform plus Tilly/MCP
Public claim only
InfoTrack Pty Limited (ABN 36 092 724 251). Product includes searches, Tilly AI agent, contract review, MCP (infotrack.ai) and Claude Cowork listing. New GTCs 1 Aug/1 Sep 2026.
Ask: Which of Tilly, MCP and contract review are on our account, and on the new GTCs?
Australian hosting
Public claim only
Privacy 12 March 2026: personal information stored in a secured location in Australia on infrastructure managed by InfoTrack. Criminal-history and InfoTrackID data must not be stored offshore.
Ask: Confirm Tilly/MCP inference also stays in Australia.
Tilly agent with per-step approval
Public claim only
Tilly: agentic model; acts only with explicit approval at each step; workflows and matter management. Site also lists MCP, contract review and Claude Cowork.
Ask: Which Tilly actions are live in our state, and can we disable MCP?
Australian official searches
Public claim only
Privacy: property searches/certificates, ASIC company searches, AFSA bankruptcy searches. Australian-specific GTC schedule (AUD, Privacy Act).
Ask: List every jurisdiction Tilly can order searches in.
Data, controls and requirements
Compare the actual configuration with firm, client and jurisdiction requirements, supported by evidence.
Privacy Act; client data licence
Public claim only
GTCs: Client owns Client Data; licence to InfoTrack solely to provide the products, not for other purposes without consent or a legal basis. Privacy Act and APPs apply.
Ask: What do we tell clients when Tilly reads matter context to suggest searches?
Not named
Not confirmed
Tilly is described as an agentic model. No OpenAI/Anthropic/Google name on the Tilly or privacy pages reviewed.
Ask: Name the model provider and region for Tilly and MCP.
No public dated list
Not confirmed
Privacy lists categories (marketing, hosts) and Vietnam read-only development access. No dated Tilly-model subprocessor table.
Ask: Provide the current list with locations, including the Tilly inference provider.
Client Data use limited
Public claim only
GTC 8.2: must not use Client Data for any other purpose without prior written consent (or a legal basis for Personal Information). No express no-training clause for Tilly was found. Privacy allows analytics of activity on the systems.
Ask: Confirm in writing that Tilly prompts and matter text are not used to train models.
Analytics of activity
Public claim only
GTCs allow gathering analytics on activity, product use and Client Data (wording in the terms extract). Privacy: ISMS and improvement of products.
Ask: Can Tilly prompts appear in analytics, and can we opt out?
AU storage; Retained Information on exit
Public claim only
Privacy: stored in Australia. New GTCs clause 18 simplifies Retained Information on termination. Live default not numbered.
Ask: State default retention for Tilly chats, search packets and MCP logs.
Cease use on termination
Public claim only
GTCs: on termination InfoTrack must immediately cease using Client Data (with Retained Information exceptions). Certified-deletion SLA not numbered in the extract.
Ask: Will you certify deletion of Tilly logs and MCP traces within 30 days?
AU teams; Vietnam read-only
Public claim only
Privacy: overseas people (Vietnam) may have read-only access for development under secure protocols and Australian-team supervision. Employees/contractors must comply with the ISMS.
Ask: Is Tilly support access logged, and can we forbid Vietnam access to our tenant?
User credentials
Public claim only
GTC 22.3: protect credentials; do not share; client responsible for all use. SSO/MFA for Tilly not described on pages reviewed.
Ask: Is SSO/MFA available for Tilly and the portal?
TLS and AES-256
Public claim only
Privacy: encrypted in transit using current TLS and at rest using AES-256.
Ask: Does Tilly inference use the same encryption, including MCP?
ISO 27001:2022 in GTCs; ISMS 2013 in privacy
Public claim only
New GTCs clause 22: each party must maintain controls that meet or exceed ISO 27001:2022. Privacy (12 Mar 2026) describes an ISMS with full consideration of ISO27001:2013. Treat the GTC standard as the newer contractual claim; certificate not inspected.
Ask: Provide the current ISO 27001 certificate with date and scope covering Tilly/MCP.
AU GTCs plus MCP agreement
Public claim only
General Terms (AU schedule, Privacy Act). iTrack MCP Agreement from 27 May 2026 for AI-agent connections. Privacy 12 March 2026. No standalone public DPA URL.
Ask: Will Tilly and MCP be on the new GTCs plus the MCP agreement, with a 72-hour breach clause?
AU storage; limited overseas access
Public claim only
Privacy: stored in Australia; no present disclosure to overseas organisations, but multinational groups in UK/US/NZ may receive information in Australia; Vietnam read-only development access. InfoTrackID and criminal-history data must not leave Australia.
Ask: Does Tilly inference or MCP ever leave Australia?
72-hour GTC notice
Public claim only
GTC 21: notify the other party in writing without undue delay and no later than 72 hours after becoming aware of a suspected Notifiable Data Breach; cooperate on OAIC notifications.
Ask: Who is notified for a Tilly incident, and does 72 hours apply to MCP integrators?
Continued use accepts new GTCs
Public claim only
Existing clients accept new GTCs by continued use from 1 September 2026; may close the account before then. Privacy may be revised by posting.
Ask: Will Tilly model-provider changes be notified in writing?
Cease use; Retained Information
Public claim only
On termination, cease using Client Data; clause 18 Retained Information is simplified in the new GTCs. Export of Tilly history not described.
Ask: What export is available for Tilly conversations and search history?
MCP and Claude Cowork
Public claim only
iTrack MCP Agreement governs connecting an integrator or AI agent to the InfoTrack MCP Server. Site nav names Claude Cowork. Those paths can send client data to third-party assistants.
Ask: Which MCP clients are approved, and how do we disable Claude Cowork?
Official searches, not open web
Public claim only
Product is official Australian searches. Whether Tilly also browses the open web was not stated.
Ask: Can Tilly browse the open web, and can we disable it?
Explicit approval each step
Public claim only
Tilly page: the agent acts only with explicit approval at each step. MCP may let other agents call InfoTrack products under the MCP agreement.
Ask: Can MCP clients place paid searches without a human click in InfoTrack’s UI?
Per-step approval claimed
Public claim only
Tilly: explicit approval at each step. GTCs still treat User Credentials use as the client’s responsibility.
Ask: Is the approval logged against a named user for every search?