Last updated: September 2026
Tubely Privacy Policy
Plain English Summary
Tubely helps families coordinate tube feeding care. We collect the minimum health information needed to do this. We encrypt everything. We never sell your data. We never share it with advertisers. Only people you explicitly invite can see your information. You can delete your account at any time, and ask us for a copy of your data whenever you want one. We deliberately do not collect Medicare numbers, NDIS numbers, financial data, GPS location, biometric data, or uploaded documents. The detailed policy below explains everything.
1. Who We Are
Tubely is a care coordination platform for individuals who are tube fed and the teams around them. Tubely is operated by Wholefeed Pty Ltd (ABN 25 696 877 406), an Australian proprietary limited company trading as Tubely.
- Registered address:
- Adamstown NSW Australia
- Privacy contact email:
- support@tubely.com.au
- Website:
- tubely.com.au
Throughout this policy, “we”, “us”, and “our” refer to Wholefeed Pty Ltd. “Tubely” refers to the Tubely application and related services. “You” and “your” refer to the individual using the Tubely application.
2. Scope of This Policy
This privacy policy applies to all personal information collected, stored, processed, and disclosed by Tubely through the Tubely mobile application for iOS, the Tubely web application, the Tubely website, and any related services or communications.
This policy is designed to comply with the following legislation and frameworks:
- Australian Privacy Act 1988 (Cth) and the 13 Australian Privacy Principles (APPs)
- Australian state and territory Health Records Acts (where applicable)
- United Kingdom General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018
- United States state privacy laws including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and other applicable state privacy statutes
- Children's Online Privacy Protection Act (COPPA) (United States) to the extent applicable
Where the requirements of different jurisdictions conflict, we apply the highest standard of protection available.
3. Information We Collect
3.1 Information You Provide Directly
When you create an account and use Tubely, you may provide the following information:
Account Information:
- Your name and email address
- Password (stored only in hashed form, we cannot read your password)
- Your role in the care circle (parent, carer, school staff, clinician, family member, or other)
Patient Health Information:
- Patient name and date of birth
- Tube type (selected from a structured list: gastrostomy/PEG, nasogastric, nasojejunal, gastrojejunal, jejunostomy, or other)
- Formula(s) currently in use
- Known allergies
- Emergency contact names and phone numbers
- Hospital or clinic name, dietitian name, and GP name
- General notes (free-text field for care context not covered by structured fields)
Care Coordination Data:
- Feeding plans including formula, volume, rate, timing, method, and flush protocols
- Medication schedules including medication name, dose, route, frequency, and timing
- Daily logs including feeds completed, flushes, vomiting episodes, stool output, hydration, and free-text notes
- Handover summaries generated by the app
- Team member invitations and permission levels
Consent Records:
- Timestamps and records of when you provided consent for account creation, team member invitations, and data processing
3.2 Information Collected Automatically
When you use Tubely, we automatically collect limited technical information to ensure the application functions correctly and to identify and fix errors:
- Device type and operating system version (e.g. iPhone, iOS 17)
- App version number
- Anonymised usage analytics (e.g. which features are used most frequently, aggregated and not linked to individual users)
- Error and crash reports (to identify and fix bugs)
- Timestamps of account activity (login, logout, last active)
We anonymise all automatically collected data so that it cannot be used to identify any individual user.
4. Information We Deliberately Do Not Collect
Tubely has made deliberate, permanent decisions to exclude certain categories of data from the platform. This is a security architecture decision: every data field we do not collect is a field that cannot be compromised in a data breach.
| Data Type | Why It Is Excluded |
|---|---|
| Medicare numbers | Government identity number. If breached, enables identity fraud. Not needed for care coordination. |
| NDIS participant numbers | Government disability scheme identifier. If breached, enables fraudulent claims. Not needed for care coordination within the app. |
| Tax file numbers or social security numbers | Government tax identifiers. No functional purpose in Tubely. |
| Financial information | All payment processing is handled by Apple through In-App Purchase. Tubely never receives or stores your card details, and no financial data is stored in the Tubely database. |
| GPS or location data | No functional purpose in Tubely. We never request, collect, store, or log your location. |
| Biometric data | Phone-native biometrics (Face ID, fingerprint) are handled by your device operating system. No biometric data is stored in the Tubely database. |
| Free-text diagnosis fields | Only a structured dropdown is offered. Free-text diagnosis entry is excluded to prevent over-sharing of sensitive clinical details that would increase breach severity. |
| Device identifiers or advertising IDs | No functional purpose. Not collected or tracked. |
| Browsing history | No tracking of pages visited outside of Tubely. No analytics that track individual user behaviour. |
| IP addresses (identifiable) | For security logging purposes only, IP addresses are anonymised to the first two octets before storage. |
| Diagnoses (free-text) | Free-text diagnosis fields are excluded. A structured dropdown is used instead to prevent over-sharing of sensitive clinical details that would increase breach severity. |
| Patient photographs | No patient photos are collected, stored, or uploaded. Excluding images reduces breach severity and protects patient identity. |
| Uploaded files and documents | Tubely has no file upload feature. Clinic letters, referrals and scanned plans cannot be attached to a record. An uploaded document carries whatever the sender put in it — commonly a Medicare number, an NDIS number or a full clinical history — which would defeat every exclusion listed above. Feeding plans are entered as structured fields instead. |
| In-app messaging content | Tubely does not include messaging features. We solve communication through shared data and handover summaries, not chat. |
5. How We Use Your Information
We use the personal information we collect solely for the following purposes:
- Primary purpose (Care coordination): To provide the core Tubely service, including storing and displaying feeding plans, medication schedules, and care logs; enabling authorised team members to view and contribute to care records; generating handover summaries; and sending medication and feed reminders.
- Account management: To create and manage your user account, authenticate your identity, and manage your access permissions within care circles.
- Service improvement: To analyse anonymised, aggregated usage patterns to improve the Tubely application. This analysis never involves individual-level health data.
- Security and safety: To detect, prevent, and respond to security threats, fraud, and unauthorised access.
- Legal compliance: To comply with applicable laws, regulations, legal processes, or enforceable government requests.
- Communications: To send you essential service communications including account verification emails, password reset emails, data retention warnings, security notifications, and material changes to this privacy policy. We will never use your health information in marketing communications.
6. How We Do Not Use Your Information
We make the following binding commitments about how your data will never be used:
- We do not sell your personal information or health data to any third party, under any circumstances.
- We do not share your personal information or health data with advertisers.
- We do not use your health data for marketing purposes.
- We do not use your health data to build advertising profiles.
- We do not display advertisements within the Tubely application.
- We do not provide your identifiable health data to formula companies, pharmaceutical companies, or any commercial entity.
- We do not use your identifiable health data to train artificial intelligence or machine learning models without your explicit, separate, opt-in consent.
- We do not make automated decisions about your care or treatment. Tubely is a care coordination tool, not a clinical decision support system.
8. Data Storage and Security
8.1 Where Your Data Is Stored
All Tubely health data is stored on Supabase servers located in Sydney, Australia (AWS ap-southeast-2 region). This means your health data is subject to Australian data sovereignty protections and does not leave Australian territory for storage purposes.
Some supporting services (Vercel for web hosting, Apple for subscription billing, and Apple and Google for push notifications) are operated by companies headquartered in the United States. However, no identifiable health data is stored on or processed by these services.
8.2 How Your Data Is Protected
- Encryption in transit: All data transmitted between your device and our servers is encrypted using HTTPS (TLS 1.2 or higher).
- Encryption at rest: All data stored in our database is encrypted at rest using AES-256 encryption, the same standard used by banks and government agencies.
- Password security: User passwords are hashed using bcrypt before storage. We cannot read your password.
- Row Level Security: Our database implements Row Level Security (RLS), which means that every database query is automatically filtered to ensure that users can only access data for patients they are authorised team members of.
- Access controls: Role-based permissions ensure that team members see only the information appropriate to their role and permission level.
- Session management: Sessions expire after a period of inactivity (default 30 minutes). Logging out clears all locally cached data from the device.
- Handover link security: Shareable handover links use cryptographically random tokens, expire automatically (default 48 hours, maximum 7 days), can be revoked at any time by the primary carer, and log every access.
- Security headers: The application implements Strict-Transport-Security, Content-Security-Policy, X-Content-Type-Options, X-Frame-Options, and Referrer-Policy headers.
9. Data Retention
We retain your personal information only for as long as necessary to provide the Tubely service and comply with our legal obligations.
| Data Category | Retention Period | What Happens After |
|---|---|---|
| Active accounts | Duration of active life. | Data remains available while active. |
| Inactive accounts | Retained. Not deleted automatically. | An account that goes unused is not deleted on a timer, because the clinical record attached to it belongs to the person being cared for rather than to the account. You can delete your own account at any time from Settings. |
| Deleted accounts | Erased immediately. | Your name, phone number and profile details are erased and the account is permanently disabled the moment you confirm. There is no waiting period. If you are the primary carer for someone, their record is deleted at the same time. |
| Patient records | Kept for as long as the primary carer wants them. | The primary carer — whoever created the record — can delete it at any time by deleting their account, which erases the profile, feeding plans, medications, logs, reminders, equipment and handovers together. Other members of the care circle lose access at that point, because the record no longer exists. |
| Care entries in someone else’s record | Retained. | If you help care for someone but did not create their record, the entries you logged stay in it after you leave or delete your account, attributed to a deleted user. A feed you recorded is part of that person’s care history, and their family did not ask for it to be removed. |
| Handover summaries | Link expires after a set duration (default 48 hours, maximum 72 hours). Permanently deleted once it expires. | The handover and everything in it — name, date of birth, allergies, medications, feed schedule, contacts and log entries — is destroyed, and it disappears from your Handovers screen. A record that it existed, who created it, when, and each time it was opened is kept separately in the audit log. |
| Consent records | Life of account plus 7 years. | Required for legal compliance. |
| Audit logs | Retained for the life of the patient record. | Records who accessed or changed what, and when. Kept because it is the evidence that access to a child’s record was appropriate. Routine screen views are not logged; creating, changing, sharing and exporting are. |
10. Your Rights
Regardless of where you are located, Tubely provides all users with the following rights:
- Right to access: Everything Tubely holds about you and the people you care for is visible in the app itself. If you would like it in another form, email support@tubely.com.au and we will provide it within 30 days at no cost.
- Right to data portability: Email support@tubely.com.au and we will send a machine-readable copy of your account and patient data within 30 days. A self-service download is not yet built into the app.
- Right to correction: You can correct any inaccurate information at any time by editing the relevant records within the application.
- Right to deletion: You can delete your account at any time from Settings, with no waiting period and without asking us. If you are the primary carer for someone, their record is deleted with your account. If you are a member of someone else’s care circle, you can leave it at any time, and the primary carer can remove you at any time; the entries you logged stay in their record as described in section 9.
- Right to withdraw consent: You can withdraw your consent to data processing at any time by deleting your account.
- Right to restrict processing: You can request that we restrict the processing of your personal information. Contact support@tubely.com.au.
- Right to object: You can object to the processing of your personal information for any purpose other than the core Tubely service. Contact support@tubely.com.au.
- Right to complain: You have the right to lodge a complaint with the relevant supervisory authority.
11. Children's Privacy
Tubely is designed for parents, guardians, and authorised carers to manage health information about tube-fed individuals, many of whom are children. We take children's privacy extremely seriously.
- Parental consent required: Information about a child (any person under 18 years of age) may only be entered into Tubely by a parent, legal guardian, or a person with legal authority to make decisions about the child's care.
- No direct collection from children: Tubely does not knowingly collect personal information directly from children. The application is designed for use by adults.
- Minimum data collection: We collect only the minimum information about children that is necessary for care coordination.
- COPPA compliance: To the extent that COPPA applies, we rely on the exception for information collected from parents and guardians for the purpose of protecting the safety of a child.
If you believe that information about a child has been entered into Tubely without proper parental or guardian consent, please contact us immediately at support@tubely.com.au and we will delete it.
12. Additional Information for Australian Users
Tubely is operated by an Australian company and is designed to comply with the Privacy Act 1988 (Cth) and the 13 Australian Privacy Principles (APPs).
- APP 1 (Open and transparent management): This privacy policy fulfils our obligation to manage personal information in an open and transparent way.
- APP 3 (Collection): We collect only information that is reasonably necessary for the care coordination functions of Tubely.
- APP 5 (Notification): We notify you at the point of collection about what information we are collecting and why.
- APP 6 (Use and disclosure): We use personal information only for the primary purpose for which it was collected.
- APP 7 (Direct marketing): We do not use personal information for direct marketing.
- APP 8 (Cross-border disclosure): Your health data is stored in Sydney, Australia. Supporting services do not store or access identifiable health data.
- APP 11 (Security): We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access.
- APP 12 (Access): All personal information we hold about you is visible in the app. On request to support@tubely.com.au we will also provide it as a file, within 30 days and at no cost.
- APP 13 (Correction): You can correct inaccurate information at any time by editing records within the application.
Complaints: If you believe we have breached the Australian Privacy Principles, please contact us at support@tubely.com.au. If you are not satisfied with our response, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or by calling 1300 363 992.
Notifiable Data Breaches: In the event of an eligible data breach that is likely to result in serious harm, we will notify affected individuals and the OAIC in accordance with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988.
13. Additional Information for United Kingdom Users
If you are located in the United Kingdom, the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 apply to our processing of your personal data.
Data controller: Wholefeed Pty Ltd (ABN 25 696 877 406), trading as Tubely.
Lawful basis for processing:
- Explicit consent (Article 6(1)(a) and Article 9(2)(a) UK GDPR)
- Performance of a contract (Article 6(1)(b) UK GDPR)
- Legitimate interests (Article 6(1)(f) UK GDPR) for security and anonymised analytics
International transfers: Your health data is stored in Australia. We rely on the standard contractual clauses approved by the ICO as our transfer mechanism.
Complaints:You can lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.
14. Additional Information for United States Users
14.1 State Privacy Laws
California (CCPA/CPRA): If you are a California resident, you have the right to know what personal information we collect; the right to delete; the right to opt out of the sale or sharing of personal information (we do not sell or share personal information); the right to non-discrimination; and the right to limit the use of sensitive personal information.
Other state laws: We endeavour to comply with all applicable US state privacy laws. The rights described in Section 10 meet or exceed these requirements.
14.2 HIPAA Notice
Tubely is a consumer care coordination application. In its current form, Tubely is not a “covered entity” or a “business associate” as defined under HIPAA. However, we have designed Tubely's security and privacy practices to align with HIPAA's requirements for the protection of health information.
14.3 COPPA
Tubely does not collect information directly from children. All information about children is entered by a parent, legal guardian, or authorised carer.
16. Changes to This Privacy Policy
We may update this privacy policy from time to time. When we make material changes, we will:
- Notify all registered users by email at least 30 days before the changes take effect.
- Display a prominent notice within the Tubely application.
- Update the “Last updated” date at the top of this policy.
Your continued use of Tubely after the effective date of the updated policy constitutes your acceptance of the changes. If you do not agree, you may delete your account at any time.
17. Contact Us
If you have any questions, concerns, or complaints about this privacy policy, please contact us:
- Email:
- support@tubely.com.au
- Entity:
- Wholefeed Pty Ltd (ABN 25 696 877 406)
- Trading as:
- Tubely
- Country:
- Australia
We will respond to all privacy enquiries within 30 days.