This Privacy Policy applies to all personal information collected by The Violet Initiative Ltd (ACN 143 224 293) (“Violet”, “we”, “us” or “our”) via the websites www.violet.org.au and www.violetcares.com including through the Care Compass, or in conversation with our Violet Guides or in connection with your use and access to our platform and/or our services however provided (the “Platform” and “Services”).
The purpose of this Privacy Policy is to inform you about how we process your personal information. The Privacy Policy may be varied from time to time. You should check our website and the Platform regularly to take notice of any changes we may have made to the Privacy Policy.
1. What information do we collect?
The Privacy Act 1998 (Cth) (“Privacy Act”) defines types of information, including Personal Information and Sensitive Information. This Privacy Policy applies to the collection of your Personal Information and/or Sensitive Information.
Under the Act, Personal Information defined as information about an identifiable individual, whether true or not, and whether recorded or not.
Sensitive Information includes information such as an individual’s health, ethnicity, religious beliefs, or membership of professional bodies.
Sensitive Information is used only:
(a) for the primary purpose for which it was obtained;
(b) for a directly related secondary purpose; or
(c) with your consent or as required or authorised by law.
For the purposes of this Privacy Policy ‘Information’ refers to Personal Information and Sensitive Information, as the case may be.
The kind of Information we collect depends on how you use the Platform and Services. It may include:
name, date of birth, profession and personal contact details including email and/or phone number;
your location (state or postcode) and whether you are a Registered User or acting as a Carer for someone else (including their preferred name and relationship to you).
Payment details;
IP address and the date and time of your access to our Platform or Services;
Communications from you including survey responses, testimonials, feedback or complaints;
Details about your family members or persons close to you, your care preferences, your preferences for the later chapters of life;
Case notes and session recordings;
General health and wellness information which you provide to us;
Information about your donation and charity preferences and select organisations; and/or
any information you choose to share with us, either directly or when using our Services or Platform. This includes when you are using Violet Guides or Care Compass.
We collect only the information reasonably necessary to deliver and improve the Platform and our Services.
We do not collect or use government-related identifiers (e.g. Medicare numbers).
2. How we collect your Information
We collect Information from you as follows:
We collect Information when you input, upload, or discuss data via the Platform, a Violet Guide, or any other communication with us;
We may collect cookies to understand Platform use and customise your experience (these do not generally identify you);
Where practicable, we collect information directly from you; and
Where practicable, individuals may choose to engage with Violet anonymously or using a pseudonym (for example, when browsing publicly available resources). However, in order to obtain the benefit of the Services and/or the Platform you may still be required to provide us with some Information.
We collect your Information from third parties as follows:
In some cases, we may collect your Information which is provided by persons who are not you.
When authorised by you, a family member or caregiver provide Personal Information to us on your behalf. We will take reasonable steps to ensure accuracy and obtain confirmation from you where possible.
In instances where you provide us information about other persons:
If you are a carer, family member, or legally authorised representative and provide us with information on behalf of another individula, in cases where the person on whose behalf the information is provided has decision-making capacity, it is your responsibility to obtain the consent of the person whose information you are providing to us and confirm that the individual has reviewed and approved the content before providing to us; and
In cases where the person whose before the information is being provided does not have decision-making capacity (for example, due to dementia or other cognitive impairment), it is your responsibility to provide us with documentation confirming that must you are authorised to provide us that information by your appointment as an Enduring Guardian, Health Attorney, or otherwise legally authorised (as defined under relevant state or territory laws) to act for that person. Violet may request reasonable documentation to establish your authority.
If you provide us with information, including Information, about another person, such as nominated decision-makers, healthcare providers, or family members involved in a person’s care, you acknowledge and agree that you are authorised to do so and where practicable, that those individuals have been fully informed of or have expressly consented to their information being provided to us. You agree that you are responsible for the information you provide to us, whether it is about you or another person.
In cases where information is provided to us by or on behalf of another person, we may require completion of a written Attestation confirming that the person to whom the information relates has reviewed and approved its contents, and/or that you are legally authorised to act on their behalf.
You acknowledge that we will maintain an auditable record of the attestation and/or written authority declarations and we may require you to provide us with updated attestations and declarations periodically to ensure ongoing compliance. You further acknowledge that if you do not provide us with these documents, we reserve the right to restrict your access to the Services and/or Platform.
3. Why we collect your information
We collect your Information to provide you with our Services and the Platform and to continuously improve our Services and the Platform.
We may also use your Information for data analytics, and to communicate with you about developments in our business.
We may share your Information (i) with our group companies (including any parent, subsidiaries and affiliates), (ii) with our business partners, but only as necessary to provide the service to you or to fulfil our legitimate business interests and/or (iii) If you give us permission to do so.
(b) We customarily disclose Information to our trusted service providers who assist us in operating the Platform, maintaining our systems, , or providing you with the Services. From time to time, authorised maintenance and support personnel may access your Information in the normal course of their duties.
We use our best endeavours to ensure that all third-party providers engaged by us are bound by written agreements that require them to:
use Information only for the specific purpose for which it is shared;
maintain privacy, confidentiality, and security standards equivalent to those required under the Australian Privacy Principles; and
implement appropriate safeguards to protect against unauthorised access, misuse, or disclosure.
We may also share de-identified or aggregated data with our service providers and enterprise partners for purposes such as improving our services, research, analytics, developing insights, and enhancing the support and product experience we provide. This information does not identify you personally and is managed in accordance with the Australian Privacy Principles.
By using our Platform, you consent to the receipt of direct marketing material. We will only use your Information for this purpose if we collected such information directly from you, and if it is material of a type you would reasonably expect to receive from us. We do not use Sensitive Information in direct marketing activities. Our marketing materials include a simple means to opt out (such as an unsubscribe link).
By providing your survey responses, testimonials, feedback or complaints, you grant to us a royalty-free, worldwide, irrevocable, perpetual license to use and incorporate into our website, the Platform and/or our Services any general suggestions, enhancement requests, testimonials, recommendations or other feedback provided by you.
4. Security, access, and correction
We process the majority of Information on our servers in Australia, and you consent to your personal information being processed and stored in that location.
Please be aware that some Information which we collect in connection with some of our Services (i.e. Care Compass), may be hosted on servers located overseas [MR: confirm other locations if known]. We will take reasonable steps to ensure that overseas recipients handle personal information in accordance with the standards required by the Australian Privacy Principles, including contractual and technical safeguards.
You acknowledge that if you request us to transfer your Information to an overseas recipient, the overseas recipient may have laws which are different and potentially not as protective as the laws of your own country. In the circumstances, we do not require the overseas recipients to comply with the Australian Privacy Act 1988 (Cth) and we will not be liable for any mishandling of your information in such circumstances.
The Australian Privacy Principles (APPs):
permit you to obtain access to the Information we hold about you in certain circumstances (APP 12); and
allow you to request correction of any inaccurate or incomplete information subject to certain exceptions (APP 13).
Where you would like to obtain such access, please contact us in writing on the contact details set out at the bottom of this Privacy Policy.
To protect your privacy and security, we take reasonable steps (such as requesting a secure password meeting the minimum number requirements) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from us at all times.
We also require all users of our Platform and/or Services to implement two factor authentication. [MR: confirm]
We will take appropriate security measures to protect against unauthorised access to or unauthorised alteration, disclosure or destruction of your personal information. These measures may include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures [MR: please confirm your current security measures and practices] to guard against unauthorised access to systems where we store personal information.
We do not warrant that these security measures will prevent any unauthorised access to or unauthorised alteration, disclosure or destruction of the data. We disclaim all liability in relation to any unauthorised access, alteration, disclosure or destruction of data that is outside our reasonable control.
We take reasonable steps to ensure the information we hold is accurate, up-to-date, complete, and relevant to the purposes for which it is used.
You have the right to request access to your personal information and to request that we correct any inaccurate personal information. You may also have the right under applicable data protection laws to request the deletion of your personal information or in some circumstances, to restrict or object to the processing of your personal information. If you would like to request such access, correction, deletion or restriction, please contact us as set out below.
Your personal information will not be disclosed to recipients outside Australia unless you expressly request us to do so. If you request us to transfer your personal information to an overseas recipient, the overseas recipient may have laws which are different and potentially not as protective as the laws of your own country. In the circumstances, we do not require the overseas recipients to comply with the Australian Privacy Act 1988 (Cth) and we will not be liable for any mishandling of your information in such circumstances.
5. Sale of Business
If we, or any of our group companies, merge with, or is acquired by, another business, sells all or a portion of its assets, or undergoes reorganisation, financing or change of control, your personal information may be disclosed to our advisers and any prospective purchaser’s adviser and may be among the assets transferred/sold to an acquirer. However, your personal information will always remain subject to this Privacy Policy.
6. Contact Us and Feedback
For all privacy enquiries, access or correction requests, or complaints:
📧 [email protected]
If you are not satisfied with our response, you may lodge a complaint directly with the Office of the Australian Information Commissioner at www.oaic.gov.au.
If you have a complaint about how we handle your Information, please contact our Privacy Officer via the email address set out in this Clause 5. We may request further information to clarify your concerns. If your complaint is well-founded, we will work with you to resolve it.
If you remain dissatisfied, you may refer the matter to the Office of the Australian Information Commissioner.[MR: optional to include a link to the OAIC website]
7. Governing Law
This Privacy Policy and any contract to which they apply shall be governed by the laws of New South Wales and are subject to the jurisdiction of the courts of New South Wales.
This Privacy Policy was last updated on [insert] February 2026.