Privacy Policy

This Privacy Policy applies to all personal information collected by The Violet Initiative Ltd (ACN 143 224 293) and Twilight Labs Pty Ltd (ACN 669 153 539) (“Violet”, “we”, “us” or “our”) via the websites www.violet.org.au, www.violetcares.com, and www.meetviolet.ai including through the Care Compass, or in conversation with our Violet Guides (the “Platform” and “Services”).

1. What information do we collect?

The kind of Personal Information we collect depends on how you use the Platform and Services. It may include:

Login or appointment details such as your name, email address, location (state or postcode), IP address, and whether you are a Registered User or acting as a Carer for someone else (including their preferred name and relationship to you).
Information you choose to share during a Violet Guide session. These sessions are private and confidential. We keep case notes for the duration of your relationship with your Guide and record sessions for quality and feedback purposes only.
Information entered into the Care Compass, including identification details, contact information, names and details of key people in your life, and your care preferences and wishes for the later chapters of life. The Platform does not request medical records, however some questions relate to general wellbeing and, as such, health information is collected should you choose to share it.
Donation information, if applicable, processed securely via our third-party partner GiveEasy (see GiveEasy’s Terms & Conditions).

We collect only the information reasonably necessary to deliver and improve our Services.

2. Types of information

Under the Privacy Act 1988 (Cth):

Personal Information is 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.

We do not collect or use government-related identifiers (e.g. Medicare numbers) except where legally required.

3. How we collect your Personal Information

(a) We collect Personal Information when you input, upload, or discuss data via the Platform, a Violet Guide, or any other communication with us.
(b) We may collect cookies to understand Platform use and customise your experience (these do not generally identify you).
(c) Where practicable, we collect information directly from you. Where a family member or caregiver provides information on your behalf, we will take steps to ensure accuracy and obtain confirmation from you where possible.
(d) If we receive personal information that we did not solicit and determine it is not reasonably necessary for our functions, we will destroy or de-identify it as soon as practicable.
(e) Where practicable, individuals may choose to engage with Violet anonymously or using a pseudonym (for example, when browsing publicly available resources).
(f) The Platform allows users to input details about other individuals — such as nominated decision-makers, healthcare providers, or family members involved in a person’s care. When you provide this information, you confirm that you are authorised to do so and, where practicable, that those individuals have been informed of or have consented to their information being provided to Violet for care-planning or coordination purposes.

In cases where a Care Compass is completed on behalf of another person, we require completion of an Attestation confirming that the person to whom the information relates has reviewed and approved its contents, or that you are legally authorised to act on their behalf.

(g) A carer, family member, or legally authorised representative may prepare a Care Compass on behalf of another individual.

Where the person on whose behalf the information is provided has decision-making capacity, the carer must confirm that the individual has reviewed and approved the content before submission.
Where the individual lacks decision-making capacity (for example, due to dementia or other cognitive impairment), the carer must confirm that they are 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 evidence of that authority.

All such entries are recorded as proxy submissions, stored securely, and handled in accordance with this Privacy Policy. Violet maintains an auditable record of the attestation and authority type declared by the user and reviews such records periodically to ensure ongoing compliance.

If no formal authority exists, carers may still use the Platform to document care information for family-planning purposes only, and Violet will treat that information as the carer’s own rather than as the personal information of the person lacking capacity.

Individuals whose information is entered into the Platform by another person may contact Violet at any time to request access, correction, or removal of their information, in accordance with the Australian Privacy Principles.

4. Purpose of collection

(a) We collect Personal Information to provide you with the best service experience possible via the Platform, for data analytics, and to communicate with you about developments in our business.

(b) We customarily only disclose Personal Information to our trusted service providers who assist us in operating the Platform, maintaining our systems, supporting our Guides, or delivering related services. From time to time, authorised maintenance and support personnel may access your Personal Information in the normal course of their duties.

All third-party providers engaged by Violet are bound by written agreements that require them to:

use Personal 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.

All Personal Information collected and stored as part of the Violet Guided Support Program — including case notes, session recordings, and communications with Violet Guides — is hosted and managed entirely within Australia. This data is not transferred or stored overseas under any circumstances.

Personal Information collected in connection with the Care Compass feature may be hosted or processed by secure service providers outside Australia. In such cases, Twilight Labs takes 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.

(c) 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.

(d) By using our Platform, you consent to the receipt of direct marketing material. We will only use your Personal 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).

5. Security, access, and correction

(a) We store your Personal Information securely and protect it from unauthorised access, misuse, modification or disclosure through physical, electronic, and administrative safeguards.
When we no longer require Personal Information, we will destroy, anonymise, or de-identify it, unless retention is required by law.

(b) Under the Australian Privacy Principles, you have the right to:
(i) obtain access to the Personal Information we hold about you (APP 12); and
(ii) request correction of any inaccurate or incomplete information (APP 13).

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.

6. Complaint procedure

If you have a complaint about how we handle your Personal Information, please contact Twilight Lab’s Privacy Officer via the details below. 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 (OAIC).

7. Contact us

For all privacy enquiries, access or correction requests, or complaints:
📧 hello@violetcares.com

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.

8. Our commitment to privacy management

We maintain internal privacy-management systems and staff training to ensure compliance with the Australian Privacy Principles.
We regularly review and update this Privacy Policy to reflect current practices and legal obligations.