Privacy Policy
‍Minikai Pty Ltd ABN 32 674 548 577

1. Introduction

‍Minikai Pty Ltd (“Minikaiˮ, “weˮ, “usˮ) is committed to protecting the privacy of all individuals whose
personal information we handle. We provide a software-as-a-service platform to aged-care and
disability providers in Australia and New Zealand. This Privacy Policy explains how we collect, use,
disclose, and protect personal information in alignment with the Privacy Act 1988 (Cth) and the
Australian Privacy Principles (APPs).
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By using Minikaiʼs services or providing personal information to us, you agree to this Privacy Policy. If
you have any questions, please contact us using the details in Section 9.

2. Definitions

Key terms used in this policy:
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Customer: An organisation or individual who has a subscription or account with Minikai to use our
services. This typically includes aged-care providers, disability service providers, or similar
entities.
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Care-Recipient: An individual receiving care or services from a Customer, whose personal
information may be entered into the Minikai platform by the Customer (for example, a patient or
client of the provider).
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Personal Information: Any information or opinion about an identified individual, or an individual
who is reasonably identifiable. This includes names, contact details, account information, and also
sensitive information such as health or disability details, as defined in the Privacy Act.
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Sensitive Information: A subset of personal information that is given a higher level of protection
under law. This mainly includes health information or details about a personʼs disabilities or care
needs.

3. Collection of Personal Information

We collect personal information only when it is reasonably necessary for our functions or activities as
a SaaS provider for aged-care and disability services. The types of personal information we collect and
how we collect it are outlined below.

3.1 Customer Information

We collect personal information about our Customers and their authorised users (for example,
employees or contractors of the Customer who use Minikai). This information typically includes:
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- Contact details of the Customerʼs staff who use or administer our Services (name, work email,
phone number, etc.).
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- Account login credentials (such as username and password) for the Minikai platform.
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- Billing information needed for invoicing or subscription management. (Note: We do not store credit
card details; payments are handled by a secure provider.)

3.2 Care-Recipient Information

Our platform may be used by Customers to store and manage personal information about Care-
Recipients. This information is typically entered by the Customer, and can include:
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- Personal details of Care-Recipients (such as name, date of birth, contact information, and
emergency contacts).
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- Health and disability-related information and records necessary to provide proper care (e.g.
medical history, care plans, and care notes). This may include sensitive information like medical
conditions, medications, and related care history.
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Minikai collects and handles this information on behalf of our Customers as part of providing our
service. We understand that Care-Recipient data is highly sensitive, and we treat it with strict
confidentiality and strong security measures.

3.3 How We Collect Personal Information

We collect personal information in several ways:

- Directly from Customers: When a Customer signs up for our Services or uses the Minikai platform,
they provide us with Customer and Care-Recipient information (for instance, by entering data or
contacting us for support).
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- From Care-Recipients or their representatives: In some cases, a Care-Recipient (or their family
member/guardian) may provide information directly (for example, by filling out a form linked to our
system). In these cases, we collect that information on behalf of the Customer.
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- Automatically through use of the Service: When Customers use our platform, we automatically
collect certain technical data (usage logs, device information, IP addresses) to maintain
performance and security. This data is generally not used to identify individuals and is analysed
only as overall trends.

- From third-party integrations: If Customers connect other software or systems with Minikai, we
handle that information according to this Policy.

3.4 Unsolicited Personal Information

If we receive personal information that we did not request and that is not needed for our services, we
will securely delete or de-identify it, as long as it is lawful and reasonable for us to do so.

3.5 Anonymity and Pseudonymity

Where practical, individuals have the option to interact with us anonymously or under a pseudonym
(for example, when making a general inquiry). However, because of the nature of our Services, we
usually need certain personal details (like names and contact information) to effectively provide
support or services.

3.6 Cookies & Similar Technologies

‍We use cookies and similar technologies to enhance and secure your experience with our website and
platform. Cookies are small data files placed on your device when you visit our site. The types of
cookies we may use include:

- Session Cookies: Temporary cookies that are essential for running our site and allowing you to
stay logged in. They are deleted when you close your browser.
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- Preference Cookies: Cookies that remember your preferences and settings (e.g., language or
layout choices) to personalise your experience.
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- Analytics Cookies: Cookies that help us understand how users interact with our platform. They
collect information like which pages are visited and any errors encountered, which we use to
improve our Services.

You can disable or block cookies through your browser settings at any time. However, some parts of
our site or platform may not function properly if cookies are disabled, especially those needed for login
or core features. Importantly, we do not store any sensitive personal information or health data in
cookies. We may use third-party analytics services that utilise cookies or similar tools to gather usage
statistics, and we only allow them to collect non-identifiable, non-sensitive information (no personal
care records or sensitive details).

4. Disclosure of Personal Information

Minikai does not sell personal information to anyone. We only disclose personal information outside of
Minikai in a few circumstances, such as:
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- Service Providers (Sub-processors): We use trusted third-party companies to support our
business operations (for example, cloud hosting and customer support tools). These providers may
handle personal information on our behalf but only for our purposes and under our instructions.
They are bound by confidentiality and required to comply with privacy standards equivalent to
ours.
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- Legal or Safety Requirements: We may disclose personal information when required by law,
regulation, or court order. We may also do so to cooperate with law enforcement or regulator authorities,
or if disclosure is necessary to prevent a serious threat to a personʼs health or safety.

- Business Transactions: If we undergo a business transaction like a merger, acquisition, or sale of
part or all of our company, personal information may be transferred to the relevant parties as part
of that process. In such cases, we will ensure that any recipients of the information agree to
protect it in line with this Policy and applicable law.
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Outside of these circumstances, Minikai will not disclose your personal information to any third party
unless you have been informed or we have your permission.

5. How We Use Personal Information

We use the personal information we collect to operate and improve our Services, to communicate with
you, and to fulfil our legal obligations. Key purposes include:
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- Providing and Improving Services: To set up and manage Customer accounts, authenticate users,
and deliver our platformʼs core features. We also analyse service usage (in an aggregated way) to
improve our platform and develop new features.
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- Communicating and Support: To communicate with Customers (and if needed, Care-Recipients or
their guardians) about service updates and to provide support (responding to inquiries, fixing
issues, etc.).
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- Compliance and Protection: To comply with any legal obligations we have (such as health record-
keeping requirements) and to enforce our terms of service. We also use information as necessary
to detect and prevent fraud or misuse of our platform.
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- Marketing (Opt-in): We may use Customer contact information to send updates about new
features or services relevant to our platform (you can opt out of these communications at any
time). (We do not use Care-Recipient personal information for marketing purposes.)

6. Data Security

We implement a range of security measures to protect personal information from misuse, loss, or
unauthorised access. These measures include encryption of data (both when sent over the internet
and when stored on our servers), strict internal access controls (so only staff with a genuine need can
access information), and regular security testing of our systems. While no method of electronic
storage or transmission is completely secure, we continuously improve our safeguards to meet
industry best practices.

7. Data Sovereignty and Retention

Minikai stores personal information on secure servers located in Australia. We will not transfer
identifiable Customer or Care-Recipient data to other countries unless it is necessary and we have put
appropriate protections in place.
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We retain Customer and Care-Recipient personal data only for as long as the Customerʼs subscription
is active or as otherwise directed by the Customer, unless a longer retention period is required by law.
When a Customer leaves Minikai, we will delete or return the personal information associated with their
account as instructed, subject to any legal requirements to retain certain record.

If a specialised service provider located overseas is ever needed to assist us (for example, providing
after-hours technical support), we will seek the Customerʼs consent before allowing any access to
personal information. In such cases, we will ensure the provider is bound by contractual terms that
require compliance with privacy safeguards equivalent to the APPs.

8. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our services or legal
obligations. If we make a significant change, we will notify Customers (for example, by email or via a
notice in our application). The “Last updatedˮ date at the end of this Policy shows when it was most
recently revised. We encourage you to check back periodically to review any updates.

9. Contact, Your Rights & Complaints

You have certain rights regarding your personal information, and we are here to help you exercise
them. These include:
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Access: You can request a copy of the personal information we hold about you. We will provide it
unless legal exceptions apply.
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Correction: You can ask us to correct or update any personal information that you believe is
inaccurate, out-of-date, or incomplete. We will promptly correct the information where possible.
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Object to Processing: You may object to specific uses of your personal information, such as using
your data for direct marketing. We will consider and respect such requests as much as possible.
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Withdraw Consent: If we are processing your personal information based on consent, you can
withdraw that consent at any time and we will stop that specific processing.
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Data Portability: You can request a copy of personal data you have provided to us in a structured,
commonly used, machine-readable format. We will provide this when it is technically feasible and
reasonable.
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If you have any questions, want to exercise your rights, or wish to make a complaint, please contact
our Privacy Officer. You can reach us by email at privacy@minikai.com. We typically respond within
30 days. If you are not satisfied with our response, you can escalate your concern to the OAIC in
Australia or the Privacy Commissioner in New Zealand.
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Last updated: May 2025

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