Privacy Policy

1. What We Collect

We collect the following categories of personal information:

• Account information: Home account name, staff names, resident names, room numbers.
• Authentication data: Hashed passwords, hashed PINs, and salts. We never store plaintext credentials.
• Profile information: Emergency contacts and other profile details residents or staff choose to enter.
• Communications: Bulletin posts, private messages between residents and staff, staff messages, and resident messages.
• Service and operational data: Service requests, appointments, events, shift rosters, prospect pipeline records, and contact logs.
• Usage and engagement data: Game scores, leaderboards, activity timestamps, and audit logs of administrative actions.
• Technical data: IP addresses (for rate limiting and security), browser user agent strings, and error reports.

2. How We Collect Information

We collect personal information directly from users when they interact with the platform, including when staff create resident accounts, when residents use platform features, and when administrators configure facility settings. We also collect technical data automatically through server logs, error reporting, and analytics (if consented to via our cookie banner).

3. Purpose of Collection

We collect and use personal information for the following purposes:

• Providing and maintaining the Apworth platform and its features.
• Authenticating users and enforcing role-based access controls.
• Facilitating communication between residents, staff, and families.
• Processing service requests, appointments, and event management.
• Generating engagement analytics and operational reports for facility administrators.
• Maintaining audit trails for security and accountability.
• Preventing abuse, enforcing rate limits, and maintaining platform security.
• Improving the platform based on aggregated, de-identified usage patterns.

4. Data Storage and Security

Personal information is stored in Google Cloud infrastructure (Firebase/Firestore) with data centres located in Australia where available. We protect data through:

• Role-based access controls enforced at the database level (Firestore Security Rules).
• Home-level data isolation ensuring each facility can only access its own data.
• Passwords and PINs hashed with scrypt and individual random salts.
• Timing-safe comparisons to prevent credential-guessing attacks.
• Rate limiting on authentication and administrative endpoints.
• HTTPS encryption for all data in transit.
• Automatic session timeouts on shared devices.

5. Sharing and Disclosure

We do not sell, rent, or trade personal information. We may share personal information only:

• With cloud infrastructure providers (Google Cloud/Firebase) as necessary to operate the platform.
• With analytics services (Google Analytics) if a user has consented via the cookie banner.
• Where required or authorised by Australian law, regulation, or court order.
• To prevent imminent harm or protect the safety of individuals.

6. Cookies and Analytics

Apworth uses essential cookies for authentication and session management. We use Google Analytics only with explicit user consent, obtained through a cookie consent banner displayed on first visit. Users may decline analytics cookies at any time. No advertising or third-party tracking cookies are used.

7. Data Retention

Personal information is retained while a home account is active and according to automated retention windows. Our background cleanup jobs currently enforce:

• Private messages: 180 days.
• Completed service requests: 180 days.
• Resident notes, prospect notes, and prospect contact logs: 365 days.

When a home account is deleted:

• All associated data (residents, staff, messages, events, game data, audit logs) is permanently removed.
• Associated Firebase authentication accounts are deleted.
• This deletion is irreversible.

Error logs are retained for a limited period for debugging purposes and do not contain personally identifiable information beyond IP addresses.

8. Access, Correction, and Deletion

Under the Australian Privacy Principles, individuals have the right to:

• Access: Request a copy of personal information we hold about them.
• Correction: Request correction of inaccurate or incomplete personal information.
• Deletion: Request deletion of personal information, subject to any legal obligations to retain it.

Facility administrators can manage resident data directly through the platform. For requests that cannot be handled through the platform, contact us at apworthconnect@gmail.com.

9. Data Breach Response

In the event of an eligible data breach under the Notifiable Data Breaches scheme (Part IIIC of the Privacy Act 1988), we will:

• Start triage within 24 hours and complete assessment within 30 days to determine if serious harm is likely.
• Notify the Office of the Australian Information Commissioner (OAIC) if required.
• Notify affected individuals as soon as practicable with details of the breach, the type of information involved, and recommended steps.
• Take reasonable steps to contain the breach and prevent recurrence.

10. Cross-Border Disclosure

Data is processed and stored using Google Cloud infrastructure. While we preference Australian data centres, some data may be processed in other jurisdictions as part of Google Cloud's global infrastructure. Google Cloud complies with relevant data protection standards. We take reasonable steps to ensure overseas recipients handle personal information in accordance with the APPs.

11. Children's Privacy

Apworth is designed for retirement village communities and is not intended for use by children under 18. We do not knowingly collect personal information from children.

12. Changes to This Policy

We may update this policy from time to time. Material changes will be communicated through the platform or by email to facility administrators. The effective date at the top of this page indicates when the policy was last updated.

13. Complaints

If you believe we have breached the APPs or wish to make a privacy complaint, please contact us at apworthconnect@gmail.com. We will respond 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.

14. Contact

For privacy questions, data access requests, or complaints, email apworthconnect@gmail.com.