Last updated 10 October 2025
 

Circletalk Australia Pty Ltd T/A CircleTalk (ABN 22 640 201 994) (we, us or our) is committed to protecting your privacy. This policy explains how we collect, use and protect your personal information. It applies to all personal information we handle, whether we collect it through our app, website, in person, or through other means.

1. Quick overview

• We collect information you provide to us and information we gather when we interact with you

• We use this information to provide our services and improve your experience

• We protect your information using secure systems and processes

• You have rights regarding your personal information, including access and correction rights

2. Information we collect
 

We may collect your personal information and, where relevant, the personal information of your dependent (meaning any person (child or adult) for whom you are the legal representative or guardian). When you use our app, we will collect the personal information you enter into it.
 

Basic identifying and contact details

• Name (optional, you may use an alias or nickname)

• Phone number
   

Service related information                    

• Payment and transaction details for subscriptions you've purchased from us

• Your preferences for our services and your marketing preferences

• Feedback and survey responses
   

Digital information

• App user ID and anonymous RevenueCat ID

• Device identifiers and device information

• IP address and general location information derived from your IP address

• Search and browsing behaviour (on our website)

• App and website usage patterns

• Cookie preferences
   

Professional information
 

• Employment history

• Professional experience

• Professional registrations
   

Sensitive Information
 

We handle sensitive information with extra care and protection, and we only collect this information with your consent or when legally permitted. This includes:
 

Health information

• Disability information including support needs and preferences for sensory, environmental, and communication accommodations/accessibility requirements

• Medication and prescription information (not visible by your supporters) 
   

3. How we collect personal information

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• Directly from you when you: when you fill out information on our app, interact with us, contact us, submit forms.

• Automatically when you: use our app or technologies, visit our website, interact with our online services.

• From third parties: your parent or guardian, participants and their carers (if you use our app as a supporter), service providers, business partners, public sources, government organisations and organisations or people authorised by you.
   

4. Why we collect, hold, use and disclose personal information
 

We collect and use your personal information to run our business and provide our services as set out below.
 

Business operations

• To manage our relationship with you as a user of our app

• To deliver our services

• To handle your inquiries, support requests, and communications

• To maintain accurate records for billing and administration

• To verify your identity when required or permitted by law
   

Communication and support

• To respond to your questions and support requests

• To communicate important updates about our services

• To handle inquiries made through our website or platforms

• To manage your participation in surveys, feedback sessions, or events
   

Service improvement

• To conduct analytics and market research

• To improve our business operations and services

• To develop and enhance our applications and platforms

• To understand how our services are used
   

Marketing and promotions

• To send you promotional information about our services and events

• To inform you about products or services that may interest you

• To manage your marketing preferences

• To run competitions, promotions, and special offers

• To provide additional benefits to our customers
   

Legal and compliance

• To comply with our legal obligations

• To respond to court orders or legal processes

• To maintain required business records

• To fulfill regulatory requirements or reporting obligations

• To protect our legal rights and interests or as authorised by law
   

5. Our disclosures of personal information to third parties
 

We may disclose personal information to:

Your Care Team

People you invite to view your information as trusted supporters, which may include:

• Family members

• Allied Health Professionals

• Educators and specialist schools

• Your employer, supervisor or other members of your workplace

• Job coaches and training providers

• Community program facilitators and coordinators

• Housing providers
   

Service providers

• IT service and backend software providers, including Firebase

• Data storage providers

• Web hosting and server providers

• Payment processors

• Marketing and advertising providers

• Analytics providers

• Subscription management platforms, including RevenueCat
   

Professional advisers

• Bankers

• Auditors

• Insurers and insurance brokers

• Legal advisers

• The NDIA, your support coordinator, your plan manager, and other health care professionals or persons/entities as necessary to provide our services
   

Business partners

• Our existing or potential agents

• Our business partners or contractors
   

Corporate transactions

If we merge with or are acquired by another company, or sell our business assets:

• Your information may be disclosed to our advisers

• Your information may be disclosed to the potential purchaser's advisers

• Your information may be included in the transferred assets
   

Legal and regulatory bodies

• Courts and tribunals

• Regulatory authorities including as required for reporting obligations

• Law enforcement officers
   

Other parties

• Emergency services when necessary

• Any other parties as required or permitted by law
   

6. Overseas disclosure
 

Storage and access

We store your personal information in Australia. However, your information may be accessed from or transferred to locations outside Australia in these circumstances:

• When our service providers are located overseas

• When we work with overseas business partners

• When using cloud-based services or data storage solutions
   

Our approach to overseas disclosure

Before disclosing your personal information overseas, we take reasonable steps to ensure that the recipient treats your information in accordance with applicable law by only sending what is necessary, requiring recipients to protect your information through contractual agreements which require the recipient to comply with the privacy standards in applicable law or through other mechanisms that provide comparable safeguards and by monitoring how recipients handle your information.
 

7. Your privacy rights and choices

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Providing information
 

You can choose whether to provide personal information to us, however, if you don't provide certain information, we may not be able to provide some services. Let us know if you don’t want to provide information and we will let you know when information is required versus optional.

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Access to your information

You can request access to the personal information we hold about you and we will respond to your request within a reasonable time. We may charge a reasonable administrative fee for providing access and if we cannot provide access, we will explain why and explore alternative ways to share relevant information.

Correction rights

You can ask us to correct any information that is inaccurate, out of date, incomplete, irrelevant or misleading and we will take reasonable steps to correct your information promptly. If we cannot make the correction, we will explain why and discuss alternatives. You can ask us to add a statement to your information noting your requested correction.

Marketing communications

You can opt-out of receiving marketing communications at any time. Each marketing communication will include an unsubscribe option. You can change your marketing preferences by contacting us. We will process your request as soon as practicable.

How to contact us about your rights or to make a complaint and what happens next

Step 1: Contact our privacy officer

• Name: Privacy Officer

• Email:  info@circletalk.com.au

• Phone: +61 03 8201 7320

• Post: PO Box 956, Croydon, VIC 3136

What to include:

Your full name, contact details, clear details about your request or complaint, and any relevant dates or reference numbers.

Step 2: Our response

We will:

• Verify your identity before processing your request

• Investigate thoroughly (for complaints) or process your request (for rights)

• Respond to you in writing within reasonable timeframes

• Explain what actions we will take and keep you updated on progress

• Not charge you for making a request (except for reasonable access fees if applicable)

• Help you understand and exercise your rights

Step 3: If you're not satisfied (complaints only)

If you're not satisfied with our response to your complaint, you can contact external bodies:

• Australian residents: Office of the Australian Information Commissioner (Phone: 1300 363 992, Website: www.oaic.gov.au)

• New Zealand residents: Office of the New Zealand Privacy Commissioner

This is the same process whether you want to access your information, correct mistakes, change marketing preferences, or make a complaint about our privacy practices.
 

8. Protecting your information

We use multiple layers of security to protect your information.
 

Technical safeguards

• Enterprise-grade encryption for data storage and transmission

• Regular security testing and monitoring

• Automated threat detection systems
   

Operational security

• Staff training on security and privacy

• Strict access controls based on job requirements

• Regular security audits and incident response procedures testing
   

Physical security

• Secure premises with controlled access

• Secure disposal of physical documents

• Equipment security protocols
   

Public information

Please note that any information you choose to share publicly on online platforms (such as comments or reviews) can be accessed and used by others. We cannot control or protect information that you make publicly available.

9. How long we keep your information

We keep your personal information only as long as we need it for the purposes we collected it, or as required by law. When we no longer need it, we securely destroy or de-identify it.

10. Cookies and Analytics
 

What We Use

We use cookies, tracking pixels, and similar technologies on our website and in our emails to improve your experience and our services.
 

Cookies

• Small text files stored on your device

• Help remember your preferences

• Enable certain website functions

• Make your interactions with our website more efficient
   

Tracking Pixels

• Tiny, invisible images in web pages and emails

• Help us understand how you interact with our content

• Allow us to measure email engagement

• Enable more relevant content delivery
   

How we use these technologies
 

Essential Functions

• Remember your login status

• Maintain your session security

• Store your preferences

• Enable core website features
   

Analytics and Performance

• Understand how our website is used

• Measure page views and traffic

• Analyse user navigation patterns

• Identify areas for improvement
   

Personalisation

• Remember your preferences

• Tailor content to your interests

• Improve your browsing experience

• Provide relevant recommendations
   

Your control
 

You can manage these technologies by:

• Adjusting your browser settings to block or delete cookies

• Using privacy-focused browser extensions

• Configuring your email client to block images

• Using our cookie preference settings

Note: Blocking all cookies may affect website functionality and your user experience.
 

11. When you sign in with another account (like Facebook or Google)
 

What we collect

When you use single sign-on to connect with us, we'll receive personal information from that provider based on your privacy settings with them. This may include your name, phone number and other details you've chosen to share.
 

How we use it
 

We use this information to create your profile on our platform and give you access to our services.
 

Your rights

If you connected through Facebook, you can ask us to delete the personal information we received from Facebook. To do this, email us at our email below and tell us what information you'd like deleted. If we can't delete certain information, we'll explain why.
 

12. Amendments

We may update this policy at any time by posting the revised version on our website. We recommend that you review our website regularly to stay current with any policy changes.
 

© LegalVision ILP Pty Ltd

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