DELTARA TECHNOLOGIES

Privacy Policy

Version 1.0 · Last Updated: 1 June 2026

Introduction

Deltara Technologies Pty Ltd (ACN 698 205 293) (we, us, our) conducts business in Australia via our application (Application). We are a digital health and wellness Application designed to support individuals managing addiction and behavioural change.

We take our privacy obligations seriously and take care to protect the personal information of our users. We are bound by the Privacy Act 1988 (Cth) (Act) and where appropriate, the Australian Privacy Principles contained therein (APPs).

This Privacy Policy describes how we manage personal information in accordance with our obligations under the Act. It explains what personal information we collect, why we collect it, how we use and disclose it, how we store and protect it, and how you can access and correct your personal information or make a complaint.

What information do we collect?

In order to provide you with our services and Application, we collect personal, sensitive and heath information about you if you:

  • visit our Application;

  • set up an account with us;

  • join our WhatsApp group;

  • contact us with a query or complaint;

  • respond to surveys or enter any promotions we run; or

  • make direct contact with us by telephone, in writing, audio-visual link or via our Application.

Personal Information

The personal information we collect may vary depending on the nature of your interaction with us, but may include:

  • contact information and identification such as your name, gender, date of birth, telephone number(s), email address(es), residential and/or business address(es) and demographic information;

  • sensitive information such as your racial or ethnic origin, sexual preferences, orientation or practices, religious beliefs or affiliations, philosophical beliefs;

  • information collected from marketing campaigns, product research, customer surveys, your interactions with us including via social media;

  • information you communicate directly with us by the Application (including but not limited to the intake questionnaire), SMS, messaging service, telephone, audio-visual link or in writing;

  • information collected through our Application including your IP address, browser type, application version, session duration, frequency of use, features accessed, information inputted to the Application, interaction patterns and cookies; and

  • any other relevant information, including sensitive information, that you provide to us at any time.

You have a right not to provide information that can identify you. However, if all or part of the personal information that we request from you is not provided, then we may not be able to provide you with certain services or functionalities of the Application.

Please note that we do not collect or store any credit card or payment details. Payment for subscriptions and any other product or services are handled via a secure third party payment gateway.

Health Information

Health information is a sub-set of personal information. The health information we collect may vary depending on the nature of your interaction with us, but may include:

  • Personal information that is information or an opinion about your physical, mental or psychological health, a disability, express wishes about the future provision of health services, a health service provided or to be provided to you;

  • Other personal information collected to provide, or in providing, a health service.

How will we use your information?

We collect, hold, use and disclose personal information for the following purposes:

Providing Services

  • providing you with our services and Application;

  • communicating with you;

  • to notify you of further products or services that we can offer you from time to time; and

  • to track activity on our Application.

Legal and Regulatory Compliance

  • complying with our obligations under the Privacy Act and other applicable legislation;

  • complying with our professional and ethical obligations; and

  • responding to requests or directions from courts, tribunals, regulatory bodies and government agencies.

Business Operations

  • internal administration, management and planning;

  • hosting, processing or improving our services or Application;

  • quality assurance, auditing and risk management;

  • staff training and professional development;

  • business development, marketing and communications (see below).

Other Purposes

  • any other purpose for which you have given your consent; and

  • any directly related purpose that you would reasonably expect or which is permitted under the Act or the Heath Records Act 2001 (VIC).

Personalisation Data

We use artificial intelligence to personalise your experience. The AI companion within the Application learns from your usage patterns, responses and progress data to provide more relevant and effective services over time. This personalisation is based entirely on your own in-Application activity and may be used to train and improve our services or Application.

If you do not wish to use AI, please contact us.

Disclosing your information to third parties

We may disclose personal information to:

  • our third party service providers and other suppliers where it is necessary or desirable to enable us to provide our services and Application, including but not limited to suppliers and/or installers of third party hardware;

  • third parties with whom you have authorised us to share your information;

  • those who work for us (whether as an employee or a contractor);

  • our officers and related bodies corporate;

  • any relevant government authority, where we reasonably believe that such disclosure is necessary;

  • any entity with which we merge (or proposed to merge) or by which we are acquired (or proposed to be acquired);

  • any entity involved in the transfer or sale of all or part of our business or assets; and

  • any other person where required or permitted by any law.

Where we disclose personal information to third parties, who help us conduct our business, we will take all reasonable steps to ensure that such third parties comply with the Act.

Cross-Border Disclosure

In order to provide the services, Application or for other business management purposes we disclose personal information to third parties located outside Australia. Countries in which our overseas recipients may be located include the USA.

Before disclosing personal information to an overseas recipient, we take reasonable steps to ensure that the recipient does not breach the APPs in relation to that information. These steps may include entering into contractual arrangements with the recipient that require it to handle your personal information in accordance with the APPs, or satisfying ourselves that the recipient is subject to laws or a binding scheme that provides substantially similar protection to the APPs.

Information about other people

If you provide personal information to us about a third party (such as your partner, family member, friend or colleague) we will treat any personal information we received in accordance with this Privacy Policy.

If you think that someone else may have provided personal information about you to us, then you can contact us as set out below.

Security of information

We take the security of your personal information seriously. An appropriate level of technical and organisational measures has been implemented on our Application and in our business operations to ensure the appropriate level of security of personal information and to protect personal information against unauthorised or unlawful processing, accidental loss, destruction or disclosure.

We will take reasonable steps to destroy personal information or ensure it is de identified if we no longer need the information for any purpose for which it may be used or disclosed.

Direct Marketing

We use your personal information to notify you of products or services that we can offer you from time to time. We do not sell, license or, in any other way, distribute your personal information to any other company for the purpose of direct marketing.

You may opt out of receiving any publications, newsletter, or other marketing product we send you at any time.

Changes to this Privacy Policy

From time to time, we may amend our Privacy Policy and will publish the amended policy on the Application.

Your right to access your personal information

Requesting Access

You have the right to access your personal information.

You will need to prove your identity before we can grant you access. Note that access may be denied if one of the exceptions set out in the Act applies.

We will respond to your request within a reasonable period. We will provide access in the manner you request where it is reasonable and practicable to do so. We may charge a reasonable fee for providing access to cover our costs in locating and providing the information, but we will not charge you for making the request.

When we may Refuse Access

In limited circumstances, we may refuse to provide access to personal information. These circumstances include where:

  • providing access would pose a serious threat to the life, health or safety of any individual or to public health or safety;

  • providing access would have an unreasonable impact on the privacy of other individuals;

  • the request is frivolous or vexatious;

  • the information relates to existing or anticipated legal proceedings and would not be accessible through the discovery process;

  • providing access would reveal our intentions in negotiations with you in a way that would prejudice those negotiations;

  • providing access would be unlawful;

  • denying access is required or authorised by law;

  • providing access would be likely to prejudice an investigation of possible unlawful activity;

  • we have reason to suspect unlawful activity or serious misconduct and providing access would prejudice our ability to take appropriate action; or

  • providing access would prejudice enforcement-related activities conducted by or on behalf of an enforcement body.

If we refuse access, we will provide you with a written notice setting out the reasons for the refusal (to the extent it is reasonable to do so) and the mechanisms available to you to make a complaint.

Requesting Correction

You may request that we correct personal information we hold about you if you believe it is inaccurate, out of date, incomplete, irrelevant or misleading. We will respond to your request within a reasonable period. There is no charge for requesting a correction or for us to make the correction.

If we refuse to correct your personal information, we will provide you with a written notice setting out the reasons for the refusal and the complaint mechanisms available to you. If you request it, we will take reasonable steps to attach a statement to the information noting that you believe it to be inaccurate, out of date, incomplete, irrelevant or misleading.

Cookies and Analytics

Requesting Access

When you visit our Application, we may collect information about your visit, including:

  • your IP address and browser type;

  • the services you access and the time spent on each page;

  • the website from which you were referred to our Application; and

  • information collected through cookies and similar technologies.

We use cookies to improve your experience on our Application, to analyse the Application traffic and to understand how visitors use our Application. You can manage your cookie preferences through your device or Application settings. Disabling cookies may affect your ability to use certain features of our Application.

Notifiable Data Breach Response

If we become aware of a data breach involving your personal information that is likely to result in serious harm, we will comply with our obligations in accordance with the Act, as well as any applicable obligations that arise from the Notifiable Data Breaches Scheme.

How to contact us

If you would like any further information or have any comments or complaints about our Privacy Policy or the way we have handled your personal information or any other aspect of our Application or service, please contact us at:

Email: [email protected]

Address: Suite 54, 11 Wilson Street, South Yarra VIC 3141

If, after contacting us, you are dissatisfied with the way we have responded to a complaint you have made to us about the way we have handled your personal information you can contact the Office of the Australian Information Commissioner (OAIC) via https://www.oaic.gov.au/privacy/privacy-complaints or 1300 363 992 Further information is available on the OAIC’s website at https://www.oaic.gov.au/.

If, after contacting us, you are dissatisfied with the way we have responded to a complaint you have made to us about the way we have handled your health information you can contact the Health Complaints Commissioner via https://hcc.vic.gov.au/make-complaint or 1300 582 113. Further information is available at the Health Complaints Commissioner website at https://hcc.vic.gov.au/.

Version 1.0

Last Updated: 1 June 2026

Addendum A | GDPR

1. Application

This Addendum applies where:

  • you are located in the European Union;

  • we provide (or offer to provide) you with goods and services within the European Union; or

  • we otherwise process your Personal Data within the European Union.

(where one or more of the above apply, a GDPR Individual).

For the avoidance of doubt, if you are not a GDPR Individual, this Addendum does not apply to the collection or use of your personal information or Personal Data.

2. Additional definitions

In this Addendum:

ePrivacy Directive means Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy, as amended from time to time.

GDPR means the General Data Protection Regulation (EU) 2016/679.

Personal Data means:

  • personal information (as described in this Privacy Policy); and

  • any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

3. Commitment to compliance

We are committed to complying with the GDPR and ePrivacy Directive in respect of Personal Data.

4. Data handling

As outlined in this Privacy Policy, we take reasonable measures to help protect your Personal Data from unauthorized access, use, or disclosure. We securely store your Personal Data at datacentres located within Australia and USA.

We will only keep your Personal Data for so long as is necessary to fulfil the purposes for which it was collected (as described above, and in particular the “How will we use your information?” section of this Privacy Policy) or as otherwise permitted under the GDPR (Permitted Purposes).

We take reasonable measures to minimise the Personal Data which we collect, and strive to only collect Personal Data which is adequate, relevant and limited to what is necessary for the Permitted Purposes.

Where we transfer your Personal Data outside of the European Union, we will ensure that appropriate safeguards are put in place.

5. Your Rights

We wish to ensure that you are fully aware of your data protection rights under the GPDR.

Right to access: You have the right to seek confirmation as to whether your Personal Data is being processed, and certain other information in relation to any such processing. You have the right to request a copy of your Personal Data. We may charge you a reasonable fee for this service.

Right to rectification: You have the right to request that we correct any Personal Data you believe is inaccurate. You also have the right to request that we complete any Personal Data you believe is incomplete.

Right to erasure: You have the right to request that we erase your Personal Data, subject to certain limitations.

Right to restrict processing: Under certain circumstances, you have the right to request that we restrict the processing of your Personal Data. Please be aware that, where our services (or particular aspects, features or functionality of the services and Application) depend or otherwise rely on the ability to process your Personal Data, such aspects may become unavailable or be of otherwise limited availability and functionality as a result of any such request.

Right to object to processing: Under certain circumstances, you have the right to object to processing of your Personal Data. As with the above, exercise of this right may result in certain services becoming unavailable or otherwise limited availability or functionality of the Application.

Right to data portability: Where technically feasible to do so, you have the right to request that we transfer your Personal Data to another controller.

If you wish to exercise any of the above rights (or other rights under the GDPR), please contact us as outlined in the “How to Contact Us” section of this Privacy Policy. We will endeavour to respond to any such correspondence within one month.

6. Cookies

We use a standard technology called ‘cookies’ in our Application. Cookies are small text files placed on your mobile device or computer by our Application which automatically collect information about you without you providing that information to us directly.

We use cookies in a number of ways to improve your experience of our Application and the services.

Most browsers are set by default to accept cookies. However, if you do not wish to receive any cookies you may set your browser to either prompt you whether you wish to accept cookies on a particular site, or by default reject cookies. Please be aware that rejecting cookies (whether essential or non essential) may mean that some or all aspects of the services or Application may become unavailable or not function as a result.

The kinds of cookies we use are as follows:

Essential: These cookies are essential for you to access or use the Application. These include cookies used for authentication and security purposes.

Functionality: These cookies allow us to remember choices you have made in the past, for example your settings preferences.

Statistics: These cookies collect information about how you use the Application, for example what information you’ve accessed and statistics generated from that information. None of this information can be used to identify you. It is all aggregated and, therefore, anonymized. We may share anonymised statistics with our third party partners.

© 2026 Deltara Technologies Pty Ltd. All Rights Reserved.