Privacy Policy — Dementia Smart Care

1. Introduction

Demetia Smart Care (“we“, “us“, “our“) operates the Dementia Smart Care mobile application (the “App“), available on Android and iOS. This Privacy Policy explains how we collect, use, store, disclose, and protect personal information — including health information — when you use the App, whether as a Patient, a Caregiver/Family Member, or another authorised user.

We are committed to handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Because the App is designed for people living with Alzheimer’s disease and dementia, we apply extra care around consent, sensitive information, and data shared with family members and carers.

By using the App, you (or your authorised representative, where you have a legal guardian or substitute decision-maker) agree to the practices described in this Policy.

2. Who This Policy Applies To

Where a Patient is unable to give informed consent because of cognitive impairment, consent is obtained from, and this Policy is provided to, their authorised representative (e.g. a family member holding Power of Attorney, an appointed guardian, or next of kin acting in the Patient’s best interests) at account setup. The specific screens, questions, and records used to capture this consent are set out in the Consent-Capture Flow document accompanying this Policy.

3. Information We Collect

3.1. Information provided by the Patient or Caregiver

Category

Examples

Identity information

Name, date of birth, address, photograph

Health information (sensitive)

Blood group, allergies, medical conditions, GP/specialist details, medication names and schedule, mood check-in entries, sleep patterns

Emergency & family information

Emergency contact names and numbers, family member names, relationships, photographs, voice recordings

Location information

GPS location (for “Find My Way” and emergency location sharing)

Usage & preference information

Daily routine and appointment data, music/playlist preferences, app interaction history

Voice data

Voice commands, voice messages recorded by family members

Account information

Login credentials, device identifiers, subscription/billing details

3.2 Information collected automatically

3.3 Information from third parties

We do not knowingly collect more information than is necessary to provide the features described in the App (data minimisation).

4. How We Collect Information

We collect information:

5. How We Use Your Information

We use personal and health information to:

We do not use Patient health information for advertising, and we do not sell personal information to third parties.

6. Sensitive Information — Additional Protections

Health information, and any information revealing a diagnosis, medical condition, or disability, is treated as “sensitive information” under APP 3. We only collect sensitive information:

We apply additional access controls to sensitive information within our systems, and staff access is limited to what is necessary for support and safety purposes.

7. Who We Share Information With

We may disclose personal information to:

We do not share Patient health or location information with any third party for marketing purposes.

8. Overseas Disclosure

Some of our service providers may store or process information on servers located outside Australia. Where this occurs, we take reasonable steps to ensure that overseas recipients handle personal information consistently with the Australian Privacy Principles, including through contractual data protection obligations.

9. Data Storage & Security

We store personal information on secure servers and apply technical and organisational measures to protect it, including:

No system can guarantee absolute security. If we become aware of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches (NDB) scheme.

10. Data Retention & Deletion

We retain personal and health information only for as long as necessary to provide the App’s services, or as required by law. Specifically:

Caregivers/Family Members can request deletion of specific data (e.g. a photo, voice recording, or the full account) at any time through [in-app setting].

11. Access, Correction & Complaints

You (or the Patient’s authorised representative) may:

To do any of the above, contact our Privacy Officer at:

Privacy Officer [Company name] Email: [privacy@yourcompany.com] Phone: [phone number] Address: [postal address]

We will respond to requests within a reasonable period, generally within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

12. Children's Privacy

The App is designed for adult Patients living with Alzheimer’s disease or dementia, and adult Caregivers/Family Members. It is not intended for use by children, although a child’s name, photo, or voice message may be stored as part of a Patient’s Family Recognition or Memory Book profile, uploaded and managed by an adult Caregiver.

13. Cookies & Analytics

The App may use analytics tools such as [e.g. Firebase Analytics / Crashlytics] to understand app performance and diagnose technical issues. These tools may collect device identifiers and usage data but do not access health information stored in the App.

14. Changes to This Policy

We may update this Privacy Policy from time to time, including to reflect changes in the App’s features, our service providers, or the law. We will notify account holders of material changes via in-app notification or email before they take effect, and the “Last updated” date at the top of this Policy will be revised.

15. Contact Us

If you have questions about this Privacy Policy or how your information is handled, contact:

Dementia Smart Care Email: [info@dementiasmartcare.com.au]