Privacy Policy

Last updated: April 2026

TogetherDaily Pty Ltd (ABN 36 689 161 368) is committed to protecting the privacy of everyone who uses our platform. This Privacy Policy explains how we collect, use, store, and disclose personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), the Aged Care Act 1997 (Cth), the National Disability Insurance Scheme Act 2013 (Cth), and the NDIS Practice Standards.

By using our platform, you agree to the practices described in this policy.

1. Who We Are

TogetherDaily is a software platform designed for Australian aged care and NDIS providers. We help care organisations share updates, photos, and care documentation with authorised family members and support networks in real time.

We act as a data processor on behalf of provider organisations (our clients), who are the data controllers responsible for the personal information of the people in their care.

2. What Information We Collect

2.1 Provider and Staff Information

Name, job title, and contact details
Login credentials (email and encrypted password)
Activity logs and usage data within the platform

2.2 Family and Authorised Contact Information

Name and contact details (email, phone)
Relationship to the person in care
Communication preferences

2.3 Client (Person in Care) Information

Name, date of birth, and profile information
Care notes, daily updates, and progress records
Photos and videos shared by care staff
Health and medical information (see Section 3)
NDIS plan details or aged care assessment information where provided by the operator

2.4 Technical and Usage Data

IP addresses and device identifiers
Browser type and operating system
Pages visited, features used, and session duration
Cookies and similar tracking technologies (see Section 9)

3. Sensitive Information: Health and Medical Data

We recognise that health and medical information is among the most sensitive categories of personal data. Where our platform is used to record or share health-related information, including diagnoses, medications, behaviours, incidents, or clinical observations, we treat this as sensitive information under the Privacy Act.

We only collect, use, and disclose sensitive information:

With the consent of the individual or their authorised representative
Where required or authorised by law
Where it is necessary to provide the care or service requested

Provider organisations are responsible for obtaining appropriate consents from individuals and their families before entering sensitive information into the platform.

4. How We Use Your Information

Delivering and maintaining the TogetherDaily platform
Enabling care staff to document and share updates with authorised family members
Supporting provider compliance with aged care and NDIS reporting obligations
User authentication and account management
Providing customer support to provider organisations
Improving platform functionality using aggregated, de-identified data only
Sending service-related communications such as account notifications and policy updates
Meeting our legal and regulatory obligations

We do not sell data to any third party, use personal information for third-party marketing, or use client health data to train AI models without explicit consent.

5. How We Share Information

5.1 Within the Platform

Information is shared between authorised users only: care staff and family members granted access by the provider organisation.

5.2 Sub-processors and Service Providers

We use a limited number of third-party services bound by data processing agreements:

Supabase – database and authentication (transitioning to Australian-hosted servers)
Hostinger – web hosting infrastructure
Transactional email providers – system notifications only

5.3 Legal Requirements

We may disclose information where required by law or regulatory authority, including the Aged Care Quality and Safety Commission, the NDIS Quality and Safeguards Commission, or the OAIC.

5.4 Business Transfers

In the event of a merger or acquisition, personal information may transfer as part of the transaction. We will notify affected users before any such transfer occurs.

6. Data Storage and Security

Encrypted data transmission (TLS/HTTPS) for all platform communications
Encrypted storage of passwords and sensitive credentials
Role-based access controls: staff and families only see information they are authorised to access
Regular security assessments and vulnerability monitoring
Audit logging of data access and modifications

Australian data residency: We are committed to storing all personal data on Australian-based servers. We are currently transitioning our database infrastructure to Australian data centres. Until this transition is complete, data may be processed in the Asia-Pacific region under comparable privacy protections.

7. Data Retention

Active account data: Retained for the duration of the provider subscription
Care records and documentation: Retained for a minimum of 7 years, in line with aged care regulatory requirements
NDIS participant records: Retained in accordance with NDIS Practice Standards and applicable state and territory legislation
Inactive accounts: Data is securely deleted or anonymised within 90 days of account closure, unless a longer period is required by law

8. Your Rights

Under the Australian Privacy Act, you have the right to:

Access personal information we hold about you
Correct inaccurate or out-of-date information
Request deletion of personal information (subject to legal retention obligations)
Opt out of non-essential communications
Make a complaint about how we handle personal information

9. Cookies and Tracking

Our website uses cookies to improve your experience:

Essential cookies: Required for core website functionality
Analytics cookies: Aggregated and anonymised usage insights

We do not use advertising or cross-site tracking cookies. You can manage cookies through your browser settings.

10. Aged Care Specific Obligations

TogetherDaily is designed to support compliance with the Aged Care Quality Standards:

Standard 1 (Consumer Dignity and Choice): Families and authorised representatives can access care updates with consent
Standard 6 (Feedback and Complaints): Transparent communication channels between providers and families
Standard 8 (Organisational Governance): Audit logs and access controls support governance and accountability

Provider organisations retain full responsibility for ensuring their use of TogetherDaily complies with all applicable aged care legislation and standards.

11. NDIS Specific Obligations

For registered NDIS providers, TogetherDaily supports compliance with the NDIS Practice Standards:

Safe storage and sharing of participant information with authorised support networks
Role-based access to prevent unauthorised disclosure of participant data
Incident documentation and reporting support

NDIS providers must ensure that participants have provided informed consent for their information to be shared via the platform, consistent with the NDIS Code of Conduct and Privacy Rule.

12. Data Breach Notification

We comply with the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act. In the event of an eligible data breach likely to result in serious harm, we will:

Notify the OAIC as soon as practicable
Notify affected individuals directly where required
Take immediate steps to contain and remediate the breach

13. Children and Vulnerable Persons

Our platform may be used in contexts involving children (particularly within NDIS services) and elderly or cognitively vulnerable adults. We do not permit direct collection of information from children under 13 without verifiable parental or guardian consent. Provider organisations are responsible for ensuring appropriate consent and safeguarding procedures are in place for all clients in their care.

14. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify provider organisations via email and update the date at the top of this page. Continued use of the platform after changes take effect constitutes acceptance of the updated policy.

15. Contact Us and Complaints

TogetherDaily Pty Ltd
Email: privacy@togetherdaily.com.au
ABN: 36 689 161 368

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

Website: www.oaic.gov.au
Phone: 1300 363 992