Download the supplied legal document
Neume Privacy Policy
Last updated: 14 October 2026
Provider: Neume Pty Ltd ABN 70 702 185 840 (Neume)
INTRODUCTION
Neume Pty Ltd ABN 70 702 185 840 (Neume, we, us or our) operates the Neume care coordination platform. This policy explains how we collect, hold, use and disclose personal information, including health information and other sensitive information.
We comply with the Privacy Act 1988 (Cth), the Australian Privacy Principles and applicable State and Territory health-privacy laws. This policy applies to Account holders, Care Recipients, invited Care Team Members, Care Card recipients, website visitors, early-access enquirers and people who contact us.
Neume is a communication and record-management platform. It is not a medical record system, clinical decision support or an emergency service.
INFORMATION WE COLLECT
For Account holders, we may collect your name, email address, password credentials held through our authentication provider, optional telephone number and profile image, role, Care Group memberships, notification preferences, device push token, support communications, and optional self-reported worker-screening or provider details. Neume does not verify self-reported credentials unless we expressly say otherwise.
For Care Recipients, we may collect names, preferred names, suburb, photograph, date of birth, sex, gender, conditions, medical history, mobility information, cardiac devices, advance-care-directive summaries, medications, medical contacts, Medicare number where a user chooses to record it, and other health information entered by the Care Team.
Care Data may include handover notes, corrections, messages, photographs, documents, shifts, tasks, checklists, acknowledgements, audit events, consent or authority records, and Care Card sharing and view events.
We do not intentionally collect precise location tracking or NDIS participant or plan numbers. We do not use Care Data to train artificial-intelligence models. The controlled pilot is free and no payment details are collected. No payment provider has been selected; this policy will be updated to describe payment processing before paid Subscriptions are offered.
Support and privacy records may include correspondence, complaint details, incident reports, identity or authority documents provided for verification, and our record of how a request or incident was handled.
We may collect the name, role and contact details of health professionals, nominees, guardians, family members and other third parties where that information is entered for the Care Recipient's care or is necessary to verify authority.
For website early-access enquiries, we collect names, email addresses, user types, marketing-consent preferences and campaign-attribution information supplied or generated when the form is used. We use this information to respond, administer early access and understand which campaigns generated enquiries. Promotional emails are sent in accordance with the preferences recorded, with an unsubscribe option. Please do not submit health information through the early-access form.
SENSITIVE INFORMATION AND CONSENT
Health information and some other Care Data are sensitive information. We collect sensitive information only with the individual's express consent or where collection is otherwise permitted or required by law.
A Care Recipient may provide consent personally. Where they cannot provide valid consent for the relevant decision, a guardian, attorney, administrator, person responsible or other representative may act only where their actual authority and applicable law permit. Care Group administration, providing care and next-of-kin status do not by themselves establish that authority. We may ask for evidence and assess its scope.
If you enter or upload sensitive information about another person, you must have their express consent covering the upload, storage and intended sharing, or lawful authority covering those actions. Consent must be informed, voluntary, current and specific to the relevant collection and sharing.
This process includes medical and wound photographs. Photograph-specific declarations cover taking the photograph, its care purpose, uploading and storage, and sharing with people permitted to view the associated note. We record the declaration or consent wording and version, the Account, Care Recipient, relevant action or record, audience and timestamp. A declaration records the user's claim; it does not create authority. Records are retained under the retention provisions below.
Consent can be withdrawn for future handling by contacting us or using available controls. Withdrawal does not undo a disclosure already made, remove information that another person has copied, or require us to erase information that we must or are permitted to retain.
HOW WE COLLECT INFORMATION
We collect information directly when a person creates an Account, uses Neume, contacts us, makes a privacy request or provides information through the Platform.
Most Care Recipient information is entered by another person, such as a family member, care worker, administrator or authorised representative. We may therefore collect a Care Recipient's information indirectly. The person entering it must give the Care Recipient the relevant collection notice or otherwise ensure they are aware of this policy, unless an exception applies.
We also collect limited technical and security information generated when Neume is used, including authentication events, device push tokens, access and audit records, and Care Card view timestamps. A Care Card view record does not identify the viewer.
We may receive information from payment providers, app stores, identity or email providers and security services, such as payment status, subscription status, delivery events and suspected fraud or security alerts. We do not receive full payment-card details.
If we receive unsolicited personal information, we assess whether we could lawfully have collected it. If not, we take reasonable steps to destroy or de-identify it unless retaining it is required or authorised by law.
COLLECTION NOTICES
This policy gives general information about our practices. We also provide shorter collection notices at relevant points, including Account signup, website early-access enquiries, Care Group creation, invitations, sensitive-information entry and Care Card sharing.
A collection notice may identify the information being collected, why it is needed, the consequences if it is not provided, usual disclosures, overseas recipients, and how to access, correct or complain about the information.
Where Care Recipient information is entered by another person, the person entering it must take reasonable steps to ensure the Care Recipient or their authorised representative receives the applicable notice, unless doing so would be unlawful or an exception applies.
WHY WE COLLECT AND USE INFORMATION
We collect and use personal information to create and secure Accounts; operate Care Groups; provide messaging, scheduling, task, record-management and Care Card functions; enforce permissions; respond to website enquiries; support users; respond to access, correction, export, deletion and privacy requests; investigate incidents; maintain consent and authority records; diagnose faults and improve the reliability and usability of requested functions; and comply with law. We do not use identifiable Care Data for unrelated product development, advertising, profiling or AI training.
We may use information for a directly related secondary purpose that the individual would reasonably expect, with consent, or where another legal exception applies. We do not sell personal information or use Care Data for targeted advertising.
Notifications are routed automatically according to user roles, permissions and notification preferences. Neume does not make automated decisions that have legal or similarly significant effects on individuals.
We may create aggregated or de-identified information for security, capacity planning, reliability and service improvement where there is no reasonable likelihood that an individual can be re-identified.
We do not use health information for direct marketing. We may send service messages necessary to operate an Account or Subscription. Optional promotional messages will include an unsubscribe method where required.
ANONYMITY AND PSEUDONYMS
You may contact us anonymously or using a pseudonym where lawful and practicable. Anonymity is generally not practicable for an Account, Care Group, access request, correction request or incident report because we need to authenticate users, allocate permissions and protect Care Data.
CARE GROUP ACCESS AND DISCLOSURE
Care Data is disclosed within a Care Group according to the Owner's and administrators' permissions and the Platform's role settings. Different members may see different information. Owners and administrators are responsible for granting only necessary access and removing access when a person's involvement ends.
Removing a Care Team Member prevents future access but may leave their name and historical contributions in the Care Recipient's record. Some role-scoped messages may still form part of the Care Recipient's personal information and may be relevant to an access request.
We may disclose personal information to service providers that support hosting, authentication, storage, email, app distribution, push notifications, support, professional advice, payments and security. We require service providers to handle information only for the agreed purpose and with appropriate safeguards.
We may also disclose information with consent, to an authorised representative or treating provider, to respond to a serious threat where permitted by law, to investigate suspected unlawful activity, to establish or defend legal claims, or where required or authorised by law.
Care Team Members are independent users, not Neume personnel. Their handling of information outside the Platform may be subject to their own privacy, professional, employment or contractual obligations. Neume does not control a recipient's independent records after an authorised disclosure.
Access is logged where the Platform supports logging. Audit records may be restricted to Neume personnel or authorised administrators where broader disclosure would create a security or privacy risk.
CARE CARDS
An authorised active Care Team Member can generate a login-free Care Card link or QR code containing selected emergency-relevant information. It may show the Care Recipient's name, date of birth, sex, conditions, emergency notes, medications, medical contacts and medical facts selected for the card. It does not show Medicare numbers, behaviour notes or blood type.
A Care Card is a bearer link. Anyone who obtains it can view the card while it is active. It expires after 24 hours and any active Care Team Member can revoke it. Revocation prevents new requests but cannot recall information already viewed, copied, photographed, printed or saved, and may not remove a page already open until it is refreshed.
Neume records the time of each successful Care Card view and may show the Care Team a view count and last-viewed time. We do not record the viewer's identity in the Care Card view event.
The static Care Card webpage is served by Netlify. Under the current design, the access token remains in the browser URL fragment and health information is requested directly from our database service. Netlify receives ordinary webpage request metadata but not the Care Card token or health information. We do not place analytics on the Care Card page.
OVERSEAS DISCLOSURE
Production Care Data is stored through Supabase in Sydney, Australia (ap-southeast-2). Operational Microsoft 365 / Exchange Online mailboxes are configured in Australia. Some suppliers are based in the United States and may process information or provide support from overseas. Storage in Australia does not necessarily prevent overseas access by supplier personnel or subprocessors.
Supplier processing and support locations depend on the service and configured arrangements. Likely overseas disclosures include the United States. We review applicable supplier and subprocessor arrangements and update this policy with additional likely countries where practicable. Website enquiry information and operational correspondence may be handled by the relevant email, hosting and administration providers; this does not mean every supplier receives production Care Data.
Current suppliers are Supabase for authentication, database, storage and backend functions; Netlify for the public website and static Emergency Care Card viewer; Resend for website signup emails; GoDaddy for domain and business-email administration; Microsoft 365 / Exchange Online supplied through GoDaddy for operational mailboxes; Expo / EAS for app build and distribution infrastructure; Apple for App Store, TestFlight and related services; and Google for Google Play and related services. GitHub is used for source-code hosting and is not intended to receive production Care Data. No payment provider is used during the free pilot.
Before disclosing personal information overseas, we take reasonable steps required by applicable privacy law to protect it. We do not ask individuals to waive the protections of Australian Privacy Principle 8 as a condition of using Neume.
Overseas personnel of a supplier may access information for support, security or maintenance even where the information is stored in Australia. Supplier locations and subprocessors can change, so we review material changes and update this policy or our supplier information where appropriate.
STORAGE AND SECURITY
We take reasonable technical and organisational steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure.
Current safeguards include database-enforced access controls, private storage, transport encryption, password hashing, signed authentication tokens, optional multi-factor authentication, optional device PIN controls, short-lived file links, audit logging, and linked correction records for locked care notes.
No online service is completely secure. If you suspect a privacy or security incident, including a Care Card sent to the wrong person, revoke access where possible and contact security@neume.com.au promptly.
Access to production information is limited according to role and operational need. We use authentication, audit and incident-response processes and review supplier security information appropriate to the nature and sensitivity of the data.
Information may be held in production systems, private object storage, encrypted or protected backups, operational mailboxes and restricted incident or legal files. A device PIN is stored only on the device as a salted hash under the current design.
DATA QUALITY AND CORRECTION
Users are responsible for keeping information they enter accurate, complete, current and relevant. Neume does not verify clinical information or self-reported credentials.
Some care records are locked after a short editing period to preserve history. A correction may be recorded as a signed, linked correction note rather than overwriting the original. This preserves the original and makes the correction visible.
If we do not agree to amend an original record, you may ask us to associate a statement with it where required by law. We take reasonable steps to notify relevant previous recipients of a correction where required and practicable.
GOVERNMENT IDENTIFIERS
A user may choose to record a Medicare number as a sensitive medical fact. We do not use a Medicare number, NDIS number or another government identifier as Neume's own Account identifier, and we do not disclose a government identifier unless required or authorised by law or reasonably necessary for a permitted verification or care purpose.
Medicare numbers are excluded from Care Cards under the current design.
RETENTION AND DELETION
We retain personal information only for as long as it is reasonably needed for the purpose for which it may lawfully be used, or as required or permitted by law. Retention depends on the type of information, the Care Recipient's age, applicable health-records laws, the date of the last relevant care activity, and any complaint, incident, dispute or legal hold.
While the legal characterisation of a particular Care Group may affect minimum retention periods, we do not treat Care Data as permanently exempt from deletion. We will apply applicable Commonwealth, State and Territory requirements, including any mandatory health-record retention period that binds Neume or the relevant record.
Care Card view events are ordinarily kept for 12 months after the link expires or is revoked, unless an incident, complaint or legal hold requires longer. Account credentials, contact details, push tokens and optional profile data are deleted or de-identified when an Account is deleted unless needed for security, legal or record-integrity purposes.
Deleting an Account does not necessarily delete a Care Recipient's record. A limited name record may remain to identify authorship, and Care Data may remain with the Care Group. A solely owned Care Group may be archived and active Care Cards revoked.
When information is due for deletion, we take reasonable steps to securely destroy or permanently de-identify it. Deleted information may remain in protected backups until those backups expire, and restoration processes must prevent intentionally deleted records from returning to active use.
Consent records, ownership claims, audit events and incident assessments may be kept longer than ordinary Account data where reasonably necessary to demonstrate authority, respond to a complaint or comply with legal and regulatory obligations.
Identity documents supplied for a privacy request are ordinarily destroyed after verification is recorded unless retention is required for an unresolved complaint, suspected fraud, legal claim or applicable law.
Archiving a Care Group prevents ordinary active use but is not deletion. We review archived information under applicable retention requirements and legal holds. Care Recipient record destruction or permanent de-identification is carried out through a controlled manual process when lawful and required; archiving alone does not satisfy that process.
ACCESS AND CORRECTION REQUESTS
During the controlled pilot, access, correction, export and Care Recipient record-deletion requests are handled manually. Contact privacy@neume.com.au. We verify identity and authority, assess applicable privacy and retention requirements, and provide secure access or an available export format where appropriate. Account deletion is available in the app; it is distinct from deletion of the Care Recipient's record.
We aim to respond within 30 days. If we refuse access or correction, we will give written reasons where required and explain available complaint options. Access may be limited where an exception applies, including where disclosure would unreasonably affect another person's privacy or create a serious threat.
A Care Recipient's access rights are not limited to information visible through their current app permissions. We assess requests against applicable privacy and health-records law.
We may provide access by secure electronic copy, in-app access, inspection or another reasonable method. We may redact another person's information where necessary and permitted.
We do not charge for making a request. We may charge a reasonable access cost only where permitted by law and after giving an estimate.
An authorised representative may make a request, but we may require evidence of identity, authority and the Care Recipient's wishes before responding.
ACCOUNT HOLDERS AND MINORS
The controlled pilot is restricted to adult Account holders and adult Care Recipients, aged 18 or over. Minor logins and minor Care Recipient records are not supported during the pilot. Any later expansion to minors will require revised notices and appropriate consent, authority, privacy and safeguarding arrangements.
Where a Care Recipient lacks decision-making capacity, we consider the authority of any guardian, attorney, administrator, nominee, person responsible or other representative under the law that applies. Next-of-kin status alone does not always create legal authority.
PRIVACY INCIDENTS
We investigate suspected loss, unauthorised access or disclosure and take steps to contain and assess the incident. Where the Privacy Act's Notifiable Data Breaches scheme or another law requires notification, we notify affected individuals and the relevant regulator.
Our assessment considers the kind and sensitivity of information, who may have obtained it, the security protections in place, likely harm and remedial action. We may contact users for information needed to complete the assessment.
If a Care Card is misdirected, revoke the link immediately and contact the Owner and security@neume.com.au promptly. Support and security reports are handled through the monitored operational mailbox; submitting a report does not mean a person has read it immediately.
TRANSFER OR CLOSURE OF NEUME
If the Neume business is sold, restructured or closed, personal information may be transferred to a successor or service provider where permitted by law and subject to appropriate privacy protections. We will give any notice required by applicable health-records law.
If no successor will hold the information, we will arrange access, transfer, archiving, destruction or de-identification in accordance with applicable law and the retention requirements affecting the relevant records.
COMPLAINTS
Contact our Privacy Officer at privacy@neume.com.au. Explain the issue and the outcome you seek. We will acknowledge and investigate the complaint and aim to respond within 30 days.
If you are not satisfied, you may complain to the Office of the Australian Information Commissioner at oaic.gov.au. If Victorian health information is involved, you may also contact the Victorian Health Complaints Commissioner at hcc.vic.gov.au. Other State or Territory health-privacy regulators may also have jurisdiction.
CHANGES TO THIS POLICY
We may update this policy to reflect changes in law, suppliers, security practices or Platform features. We will publish the current version and its effective date and give reasonable notice of material changes where practicable.
CONTACT
Privacy Officer
Email: privacy@neume.com.au
Business location: Victoria, Australia.
Contact privacy@neume.com.au for privacy requests, complaints or to arrange postal correspondence.