1. OVERVIEW

1.1 This Privacy Policy explains how Recallia collects, uses, stores and discloses personal information, including health and other sensitive information, in connection with the App.

1.2 Recallia is committed to handling personal information in accordance with applicable privacy laws, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles, where they apply.

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2. WHAT INFORMATION WE COLLECT

2.1 The types of personal information we may collect include:

(a) identifying information such as your name, email address, phone number and other contact details

(b) account information such as username, login credentials and user role (patient or carer)

(c) information about carers or other authorised contacts, including their relationship to the patient and contact details.

2.2 The App may also collect health information and other sensitive information, including:

(a) medication logs and schedules

(b) insulin regimens and insulin‑related events (for example logged doses, missed doses, attempted double doses)

(c) blood sugar readings and other health metrics entered by you or a carer

(d) symptom reports, mood indicators, cognitive task performance and other health‑related information

(e) SOS events, geofencing / safe‑zone triggers and similar safety‑related events.

2.3 Over time, the App may also process information that could be considered biometric or behavioural information (for example voice patterns, interaction patterns or, in future versions, facial or other sensor‑based inputs) if such features are enabled and you provide consent. Any such information will be treated as sensitive information.

2.4 We may also collect technical and usage information, including:

(a) device identifiers, operating system, App version and device settings

(b) IP address, time zone, crash logs and performance data

(c) usage patterns such as features used, timestamps of interactions, and configuration choices.

2.5 If location‑based features are enabled, the App may collect location information from the user’s device. This may include approximate or precise location data, depending on device settings and permissions.

2.6 Location information may be used for features such as safe‑zone or geofencing alerts, SOS flows and informing carers when a user appears to be outside a configured area.

2.7 Continuous location tracking will not occur unless this is necessary for a specific feature the user has turned on and the device is configured to allow background location access. If location permissions are disabled, location‑dependent features may not function or may be limited.

3. HOW WE COLLECT INFORMATION

3.1 We collect personal information directly from you when you:

(a) create an account or update your profile

(b) enter information into the App (for example readings, medication events, symptoms or notes)

(c) use App features such as SOS, safe‑zone, conversational or cognitive tasks

(d) communicate with us (for example by email or through in‑App support).

3.2 We may collect information about you from carers, clinicians or other persons you authorise to use or configure the App on your behalf.

3.3 The App automatically collects certain technical and usage information when you use it, as described above.

3.4 Where we introduce features that use additional data sources (for example facial recognition or other biometric inputs), we will obtain your express consent before collecting or using those data and will provide additional information about how they are used.

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4. WHY WE COLLECT AND USE INFORMATION

4.1 We collect, hold and use personal information for purposes including:

(a) operating, maintaining and providing the App and its features to you;

(b) logging and displaying information you or your carers enter into the App;

(c) generating alerts and notifications to you and your nominated carers (for example missed medication alerts, low blood sugar logs, SOS notifications and cognitive or mood change flags);

(d) supporting non‑clinical, supportive conversational features and user reassurances;

(e) enabling carers to monitor and respond to information you choose to share with them;

(f) personalising your experience, such as by tailoring reminders or support prompts to your configuration;

(g) analysing usage patterns to maintain, protect and improve the App, including developing new features;

(h) complying with legal obligations, resolving disputes and enforcing our rights.

4.2 We do not use your personal information to make automated clinical decisions about diagnosis or treatment. Any automated or AI‑driven features are intended for support and information only.

4.3 We may de‑identify personal information and use or disclose de‑identified data for research, analytics, service improvement, reporting or other purposes. De‑identified data does not identify you and is not treated as personal information under this Policy.

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5. LEGAL BASES

Where required by law, we collect and use personal information on the basis that it is reasonably necessary for our functions and activities in providing the App, and, in the case of health and other sensitive information, with your consent or as otherwise permitted by law.

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6. DISCLOSING YOUR INFORMATION

6.1 We may disclose personal information to:

(a) your nominated carers or authorised contacts, based on the configuration of your account and your sharing settings. Patients can add or remove carers at any time, and when a carer is removed, reasonable steps will be taken to stop sharing information with that person going forward.

(b) third‑party service providers who assist us in operating, hosting, supporting and improving the App (for example cloud hosting providers, analytics services, push notification services and customer support tools)

(c) professional advisers (such as lawyers, auditors and insurers) where reasonably necessary for our business

(d) regulators, law enforcement bodies or other authorities where required or authorised by law, or where we reasonably believe disclosure is necessary to protect life, health or safety;

(e) third‑party service providers engaged to assist in operating, hosting, supporting and improving the App (for example cloud hosting and data storage providers, analytics and crash‑reporting services, push notification services and customer support tools).

These providers may collect or receive certain technical information from a user’s device, such as device identifiers, IP address, operating system, App version and usage information, in order to provide their services.

6.2 We do not sell your personal information.

6.3 Where we use third‑party service providers, we seek to ensure that they handle personal information in a manner consistent with this Policy and applicable privacy laws.

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7. OVERSEAS DISCLOSURE

7.1 Some service providers or systems used in connection with the App may be located outside Australia or may store or process data in multiple countries.

7.2 As a result, personal information may be transferred to, or stored in, jurisdictions outside Australia that may have different data protection laws.

7.3 Where reasonably practicable, steps will be taken to ensure that any overseas recipient does not breach applicable privacy principles in relation to personal information. Such steps may include use of providers subject to comparable privacy regimes, contractual safeguards and limiting the information disclosed to what is reasonably necessary.

7.4 By using the App, the user consents to such overseas disclosures as described in this Privacy Policy.

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8. DATA STORAGE AND SECURITY

8.1 We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps may include technical, administrative and physical safeguards such as encryption in transit, access controls, audit logging and secure development practices.

8.2 Despite these measures, no system is completely secure. We cannot guarantee the security of the App, your device or any transmission of data. You use the App at your own risk.

8.3 You are responsible for:

(a) keeping your device secure and up‑to‑date

(b) maintaining the confidentiality of your login details

(c) promptly notifying us if you become aware of any unauthorised access to your account.

8.4 In the event of a data breach involving personal information, the breach will be assessed and managed in accordance with applicable Notifiable Data Breaches requirements under the Privacy Act. Where required, affected individuals and the Office of the Australian Information Commissioner will be notified of an eligible data breach, and reasonable steps will be taken to minimise any risk of harm.

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9. ACCESS, CORRECTION AND ACCOUNT MANAGEMENT

9.1 Where required by law, you may request access to personal information we hold about you and request that it be corrected if it is inaccurate, out‑of‑date, incomplete or misleading.

9.2 You can often access or update much of your information directly within the App. Where this is not possible, you may contact us using the details provided in the App or on any associated website.

9.3 We may require you to verify your identity before providing access or making corrections.

9.4 In some circumstances, we may refuse your request where permitted or required by law. If we do so, we will tell you why.

9.5 If you close your account, we may continue to retain certain information where required by law, for legitimate business purposes or in de‑identified form.

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10. CHILDREN AND CAPACITY

10.1 The App is intended to be used by, or in relation to, adults and older persons with cognitive impairment, often with the involvement of carers.

10.2 Where a patient has impaired decision‑making capacity, we rely on the representations of carers or substitute decision‑makers that they are authorised to provide consent and manage the patient’s use of the App.

10.3 If we become aware that personal information has been collected from a person who lacks capacity and without appropriate authority, we may take steps to delete or restrict access to that information.

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11. MARKETING COMMUNICATIONS

11.1 We may use your contact details to send you communications about the App, updates, features or related services.

11.2 You may opt out of non‑essential marketing communications at any time by following the unsubscribe instructions in the communication or by contacting us. Certain service or transactional communications (for example changes to this Policy or critical App notices) are not optional.

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12. FEATURE‑SPECIFIC NOTICES AND CONSENT

12.1 Consent will be sought where required by law before health information, sensitive information or location data is collected or used, or before certain features are enabled.

12.2 Certain features of the App (for example SOS flows, safe‑zone/geofencing features, cognitive or mood analytics, or any future features involving biometric or facial analysis) may be subject to additional notices, terms or consent screens.

12.3 We will present clear, feature‑specific information and obtain your express consent before activating any feature that involves:

(a) collection or processing of biometric information (including facial recognition, where applicable);

(b) new types of health information;

(c) sharing information in new ways (for example with additional categories of recipients).

12.4 In practice, consent may be obtained through in App consent screens, device permission prompts (for example for location) and feature specific explanations before a feature is turned on. Consent to a particular feature may be withdrawn at any time via in App settings (where available), by changing device permissions or by contacting Recallia. If consent is withdrawn, the relevant feature may be limited or may not function as intended.

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13. COMPLAINTS AND CONTACT

13.1 If you have questions about this Privacy Policy or wish to make a privacy‑related complaint, please contact us using the contact details provided in the App or on any associated website.

13.2 We will acknowledge receipt of your complaint and will aim to investigate and respond within a reasonable time. If you are not satisfied with our response, you may have the right to lodge a complaint with the Office of the Australian Information Commissioner or another relevant regulator.

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14. CHANGES TO THIS PRIVACY POLICY

14.1 We may update this Privacy Policy from time to time to reflect changes to the App, our practices or legal requirements.

14.2 The updated Privacy Policy will be made available within the App or on any associated website and will take effect when published.

14.3 By continuing to use the App after any change to this Privacy Policy, you are taken to have accepted the updated Policy.