Last updated: October 2026

Tubely Privacy Policy

Plain English Summary

Tubely helps families coordinate tube feeding care. We collect the minimum health information needed to do this, and it is stored in Australia. Your information is encrypted when it travels and when it is stored. We never sell your data. We never share it with advertisers. Only people you invite into a care circle, and anyone you deliberately send a time-limited link to, 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 diagnoses, 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.

ABN:: 25 696 877 406
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 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. Anyone the primary carer chooses can be invited — a grandparent, a support worker, a teacher, a nurse, a friend. Each member is recorded as one of four kinds (parent, carer, clinician or school staff) together with a short title the primary carer can write in, such as “Family member”, “Dietitian” or “Respite worker”

Patient Health Information:

Patient name and date of birth
Tube type, chosen from a fixed list (nasogastric, nasojejunal, orogastric, transpyloric, PEG, RIG, low-profile button, AMT Mini ONE, gastrojejunal or jejunostomy), the French gauge of the tube, and balloon fill volume
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, positioning, and flush protocols
Medication schedules including medication name, dose, route, frequency, timing, and prescriber name
Daily logs including feeds completed, flushes, vomiting episodes, stool output, urine output, hydration, sleep, medications given, weight and height (which together form a growth record), temperature, pain, seizures, and free-text notes
Equipment and consumables you choose to track, and their stock levels
Reminders you set, and whether each one was completed or skipped. That history is cleared when the reminder is edited.
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
When you accept the carer responsibilities agreement: which version you saw, which items you ticked, which person's care circle it was for, and when

3.2 Information Collected Automatically

Tubely does not track when you sign in or out, or how recently you were active, and the care circle is not shown any of that. Inside a care circle, a few things are recorded so that a mistake can be found and put right:

Shifts. If you are a member of someone else's care circle, whatever your role, you start a shift when you begin caring for that person and end it when you stop. We record who, which person, when you started and when you ended (as you told the app; we do not check it), and any note you choose to leave for the next carer. The person's primary carer can see these records and can end a shift. The next carer sees only your most recent note, for 48 hours.

Choosing a person. If you look after two or more people in Tubely, or are a carer in someone else's circle, you choose who you are caring for when the app opens. We record who chose whom, when, and from which screen. Only the person's primary carer can see this record.

Plan reads. When a member of someone else's care circle reads that person's feeding plan, we record which version they read and when, so the app can tell them if it has changed since. Only they can see this record.

The rest of what you did is the care log itself: the feeds, medications and observations you chose to enter, with your name and the time against each. If you delete an entry, it stays in the record, marked as deleted with who deleted it, when and why, and is left out of totals and summaries.

One thing sits outside our control. Supabase Auth, the sign-in service that runs inside our database, keeps the time of each account's last sign-in and, for each active sign-in session, the description your browser or device sends of itself (for example, that it is an iPhone on a particular iOS version) and the internet address it connected from. That is how the sign-in service works, and we cannot switch it off. A session's details go when the session ends or when you delete your account. We do not look at them, and nothing in Tubely is built on them.

We do not collect an app version number. Tubely does not use any analytics, product-tracking or crash-reporting service. There is no such tool in the application. If we ever add one, we will name it in section 7, tell you before it starts, and it will never receive health information.

3.3 Information You Enter About Other People

Some of what you put into Tubely is about someone other than you and the person you care for: an emergency contact's name and phone number, the name of a hospital, dietitian or GP, the prescriber on a medication, and the name and email address of anyone you invite into a care circle.

We hold that information because you entered it, and we use it only to show it back to the care circle. We do not contact those people, market to them, or use their details for anything else. Because we have no relationship with them, we rely on you to enter only what is genuinely needed for the care of the person you are caring for, and to have a reasonable basis for entering it — an emergency contact expects to be contactable in an emergency; a support worker's mobile number is not yours to circulate more widely than that.

If you are named in a Tubely record and you want to know what is held about you, or want it removed, email support@tubely.com.au. We will find it and act on it, and we will tell the primary carer that we have.

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.
Device identifiers or advertising IDs	No functional purpose. Not collected or tracked. The device description held with a sign-in session (section 3.2) is a general browser and operating system string, not a unique identifier.
Browsing history	No tracking of pages visited outside of Tubely. No analytics that track individual user behaviour.
IP addresses (not stored with your records)	None of Tubely’s own tables store your IP address, and it is never attached to a patient record. It is held in two places we should be straight about: the sign-in service inside our database records the address of each active session, for the life of that session (section 3.2); and our hosting providers, Supabase and Vercel, keep IP addresses in their infrastructure logs for a period for security and abuse prevention, as any web host does. We do not use any of this to build a profile of you.
Diagnoses	A diagnosis is the single most sensitive thing that could be written about a person here, and coordinating a feed does not require one: what a relief carer needs is the tube, the plan, the allergies and who to ring. There is no field for a diagnosis anywhere in Tubely, free-text or otherwise, and the database column was removed rather than left unused, so this cannot be turned on by accident.
Patient photographs	No patient photos are collected, stored, or uploaded. There is no field for one: the database column was removed rather than left unused, so this cannot be turned on by accident. Excluding images reduces breach severity and protects patient identity.
Push notification tokens	Reminders are scheduled on your own phone and fire from it. Nothing about a reminder — the person’s name, the medication, the time — is sent to Apple, Google, or any push notification service, because no push service is used.
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 fix faults and improve the application, using the technical information in section 3.2 and anything you tell us when you report a problem. We do not analyse your health data to do it.
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.

7. Who We Share Your Information With

7.1 Care Circle Members

The primary purpose of Tubely is to share care information within a care circle. When you (as the primary carer) invite a team member to your patient's care circle, that team member will be able to see the information you have chosen to share, subject to the permission level you assigned:

View Only: can see the feeding plan, medications, and logs but cannot create entries or edit records.
Can Log: can see all information and create log entries (e.g. record a completed feed) but cannot edit the feeding plan or patient profile.
Full Edit: can see everything, and can create and edit the feeding plan, medications, equipment, reminders and log entries. Only the person who created the patient's record — the primary carer — can change the patient's own profile, or add and remove members of the care circle.

You control who is in the care circle at all times. You can remove any team member or change their permission level at any time, with immediate effect.

Everyone in the care circle can see the person's profile, which shows their name and date of birth together, and any log entry someone deleted, with who deleted it and why. As the primary carer you can also see when each carer started and ended a shift with the person, any handover note they left, and that they accepted the carer responsibilities agreement.

If you are in someone else's care circle: what you can see is another person's health information, shared with you so that you can help care for them. Use it only for that. When you leave a circle, or are removed from one, your access ends immediately — but anything you took out of Tubely while you had access, such as a handover you printed or a screenshot, is yours to destroy, because we cannot reach it. If you are a clinician, this does not displace your own professional record-keeping obligations, which continue to apply to your own records.

7.2 Handover Summary Recipients

When you generate a handover summary and share it via a link, the recipient of that link can view the summary without creating a Tubely account. These links are protected by cryptographically random tokens and expire after a period you choose when you create them, up to a maximum of 72 hours. You can revoke any shared link at any time, with immediate effect.

Every access is counted, and the count is shown to you. Access is also written to the audit log, at most once per hour per link, so that a nurse reopening the same handover across a shift appears as one access rather than twenty. A handover link can be forwarded by whoever you send it to, so send it only to people who need it.

7.3 Shared Feeding Plan Recipients

You can also share a single feeding plan by link — for a clinic, a school, or a respite service. That link is protected by a cryptographically random token, needs no Tubely account, and stops working 30 days after you switch sharing on. Switching sharing off ends it immediately; switching it on again issues a fresh link, with a fresh 30 days.

A shared plan shows the person’s name, the plan’s title and dates, the formula, volumes, rates and daily totals, the feeding method, the flush protocol, the dietitian’s name, and any notes written on the plan. It does not include the medications or positioning recorded on the plan, or anything else from the record. As with a handover, anyone the recipient forwards the link to can also open it. Switch sharing off when the person no longer needs it: every time you switch it on, you get a new link, and the old one stays dead.

7.4 Service Providers

We use the following third-party service providers to operate Tubely:

Provider	Purpose	Data Processed	Location
Supabase	Database hosting and authentication	All application data (encrypted at rest and in transit), and the sign-in records described in section 3.2.	The database and its backups are in Sydney, Australia (ap-southeast-2). Supabase support staff, some of whom are outside Australia, may look at system metadata logs if we raise a support request; support tickets, billing records and cached static files may also be handled outside Australia.
Vercel	Builds, renders and serves the application	Health information is processed in memory each time a page is rendered, and is not stored by Vercel. Vercel keeps request logs — which page was asked for, when, and whether it succeeded, not what was on it — and the logs of each build. Application code and static assets are served from a global network; those files contain no health data.	Page rendering: Sydney, Australia (syd1). Builds, build logs, request logs and our encrypted configuration settings: United States. The check that runs before every page to confirm you are signed in runs on Vercel’s global network, not only in Sydney; it reads your sign-in cookie and nothing else.
Apple (App Store)	iOS app distribution and subscription billing	For subscribers, the anonymous transaction identifier Apple issues for the purchase. Tubely never receives your card details. No health data. Apple is not used for notifications — reminders are scheduled on your own device.	United States

7.5 Legal Requirements

We may disclose your personal information if required to do so by law, regulation, legal process, or enforceable government request. We will notify you of such a request unless prohibited by law from doing so. We will challenge requests that we believe are overbroad, unlawful, or inappropriate.

7.6 De-identified Aggregate Data

In the future, we may share de-identified, aggregate, population-level data for clinical research, health economics studies, or public health purposes. This data will never identify any individual patient, user, or family. This type of data sharing will only occur with your explicit, separate, opt-in consent, and will be subject to ethics committee review. We will never share aggregate data with advertisers.

7.7 No Other Sharing

We do not share your personal information with any other third party not listed in this section. If this changes in the future, we will update this policy and notify you at least 30 days before any new sharing arrangement takes effect.

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), and its backups are kept there too. This means your health data is subject to Australian data sovereignty protections and does not leave Australian territory for storage purposes. Two things around the database can: if we raise a support request, Supabase staff outside Australia may look at system metadata logs to investigate it; and support tickets, billing records and cached static files may be handled outside Australia.

Pages are rendered by Vercel, which means health information is briefly processed in memory by Vercel's servers each time you open a screen. Vercel does not store it. We run those servers in Vercel's Sydney region, so that this processing takes place in Australia.

If you open Tubely while you are overseas, your connection first reaches a Vercel server near you and is then passed to our servers in Sydney. Your information stays encrypted the whole way and is not stored along the route. The app's code is built on Vercel servers in the United States; that step involves our code only, never your information.

Some of what surrounds that rendering happens in the United States, and you should know what. Vercel builds the application there and keeps the build logs there. Its request logs — which record which page was asked for, when, and whether it succeeded, but not what the page contained — are stored there. Our configuration settings are held there, encrypted. And the short check that runs before every page to confirm you are signed in runs on Vercel's global network rather than only in Sydney; it reads your sign-in cookie and nothing else.

Vercel and Apple are United States companies, and using them is an overseas disclosure for the purposes of Australian Privacy Principle 8. We remain accountable to you for how they handle your information. Apple receives no health information at all — only the anonymous transaction identifier for a subscription.

8.2 How Your Data Is Protected

Encryption in transit: All data transmitted between your device and our servers, and between our servers and the database, is encrypted using HTTPS (TLS 1.2 or higher).
Encryption at rest: All data in our database, including its backups, is encrypted at rest with AES-256, as Supabase documents.
Password security: Passwords are stored only as a one-way hash using a strong, industry-standard algorithm. We cannot read your password.
Row Level Security: Our database implements Row Level Security (RLS): every query a signed-in user makes is filtered inside the database itself, so a person can only reach the records of patients whose care circle they are in. The one deliberate exception is a shared handover or feeding-plan link, which is read through a separate path that checks the link’s token, expiry and revocation instead of a login, and returns only the one record that link is for.
Access controls: Role-based permissions ensure that team members see only the information appropriate to their role and permission level.
Device lock: In the iPhone app you can require Face ID, Touch ID or your device passcode to reopen Tubely, with a short grace period so that stepping out of the app mid-feed does not lock you out of it.
Signing out: Signing out clears all locally cached data and every scheduled reminder from the device, so a handed-back phone keeps nothing.
Computers: On a computer, Tubely asks who you are caring for again after 30 minutes without use, and signs you out after 4 hours without use. Tubely does not save pages on a computer for offline use; offline use is in the iPhone app only. Do not leave Tubely open on a shared computer while you are away from it.
Reminder notifications: A reminder shows its title and notes as written, including on the phone's lock screen, where anyone who can see the phone can read it. You can hide notification previews on a locked phone in iPhone Settings, under Notifications, Show Previews.
Shared link security: Handover links (maximum 72 hours) and shared feeding plan links (30 days) use cryptographically random tokens, expire automatically, and can be revoked at any time with immediate effect.
Security headers: The application sets Strict-Transport-Security, X-Content-Type-Options, X-Frame-Options, Referrer-Policy and Permissions-Policy on every response.

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 email address are erased, your access to every care circle is revoked, and the sign-in itself — the address, the password and the record of your sessions — is deleted outright: the moment you confirm, with no waiting period and without asking us. Your email address is released, so you can sign up again from scratch later if you want to. If you are the primary carer for someone, their record and everything in it is deleted at the same moment. One thing survives: an empty account row holding no name, email or contact details. It exists only so that entries you logged in other people’s records do not break. There is no login attached to it and it identifies nobody.
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.
Shifts	Kept with the person’s record, and deleted with it.	If you delete your account, the shifts you recorded stay in the record, attributed to a deleted user, as your care entries do.
Deleted log entries	Kept with the person’s record, and deleted with it.	An entry someone deletes is marked as deleted, with who deleted it, when and why, and stays. It is not counted in totals or summaries.
Reminder history	Until the reminder is edited.	Whether each reminder was completed, skipped or missed is kept until someone edits that reminder, which clears its history. Doses marked as done also appear in the care log, which keeps them.
Plan reads	While the plan exists.	Which version of a feeding plan a carer last read, and a copy of its care details as they were, so the app can show what has changed. Erased with the plan, the person’s record, or the carer’s account.
Handover summaries	Link stops working at the expiry you chose (default 48 hours, maximum 72 hours). Permanently deleted at the next daily clean-up after that.	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 that it was opened is kept separately in the audit log.
Shared feeding plan links	30 days, or until you switch sharing off.	The link stops working. The plan itself is not deleted — it is still your record, and it stays in the app.
Consent records	Retained.	A record that you consented, when, and to which version of this policy, including any carer responsibilities agreement you accepted. Kept for as long as we may need to be able to demonstrate it, and erased with your account if you delete it. It contains no health information.
Audit logs	Retained for the life of the patient record, and deleted with it.	Records who created, changed or deleted a patient’s profile, feeding plans, medications, log entries, equipment, handovers and care-circle membership, and when — and, separately, when a shared handover link was opened, at most once per hour per link. Each time someone chooses which person they are caring for, that is recorded too. Reminders are not audited, and other screen views inside the app are not logged. Kept because it is the evidence that access to a child’s record was appropriate.
If the person at the centre of a care circle dies	Nothing is deleted automatically, and nothing runs on a timer.	Their record stays exactly as it is, and the primary carer decides what happens to it and when. This is not a decision to be made in the first week, and we will not make it for you. When you are ready, deleting the record removes it and everything in it permanently. If you would like a copy to keep first, email support@tubely.com.au and we will send it at no cost. If you would rather simply stop paying, cancel the subscription — nothing is deleted when a subscription ends. If you were not the primary carer and the record needs dealing with because they have themselves died or cannot act, email us; we will ask for evidence of your authority before acting on a request about someone else’s record.

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 inaccurate information by editing it in the app, if your permission level allows, or by asking the primary carer. If you cannot get it corrected that way, email support@tubely.com.au and we will help.
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: A record for a child (any person under 18 years of age) may only be created by a parent, legal guardian, or a person with legal authority to make decisions about the child's care. Other people add information about the child only because that person invited them into the care circle.
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.

11.1 As the person you care for gets older

Tubely is set up by a parent, guardian or authorised carer, and for a young child that is the whole picture. It does not stay that way.

Once the person at the centre of a care circle is old enough to understand what is recorded about them and to decide who sees it, that decision is theirs — not ours, and not automatically their parent's. In practice this arrives somewhere in the mid-teens and depends on the individual, not on a birthday. From that point we expect the primary carer to involve them in who is in the care circle, and to remove anyone they do not want reading their record.

If a young person, or an adult who is the subject of a record, contacts us at support@tubely.com.au, we will tell them what is held about them, give them a copy, and act on a request to correct it. Where they want the record closed or a person removed and the primary carer disagrees, we will not take sides in a family dispute: we will say what we hold, explain the options, and if we cannot resolve it we will tell both parties they can raise it with the Office of the Australian Information Commissioner.

Where more than one person has parental responsibility and they disagree about the record, Tubely cannot decide that. The account and the record stay with the person who created them until a court order, or a written agreement between the parties, tells us otherwise.

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, and the pages that show it are rendered by servers we run in Sydney. Some of the processing around that — builds, logs, configuration, and the sign-in check — happens in the United States; section 8.1 says exactly what. Vercel and Apple are United States companies, so we treat their involvement as an overseas disclosure and remain accountable for it under section 16C. Apple receives no health information.
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 by editing it in the app if your permission level allows, by asking the primary carer, or by emailing us.

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: If personal information we hold is lost, or accessed or disclosed without authorisation, and we suspect that it is likely to result in serious harm, we will assess it within 30 days as Part IIIC of the Privacy Act 1988 requires. If it is an eligible data breach we will notify the Office of the Australian Information Commissioner and every affected individual by email to the address on the account, telling you what happened, what information was involved, and what to do about it. Email is the channel to rely on; we will also put a notice in the app if we are able to. This applies whether the breach happened inside Tubely or at one of the providers named in section 7.

If you think something has gone wrong at your end — a handover link sent to the wrong person, a shared password, a lost phone with Tubely on it — email support@tubely.com.au. You can revoke a shared link and remove a care circle member yourself, immediately, and we would much rather hear about it early than not at all.

13. Where Tubely Is Offered

Tubely is not offered in Europe. This includes the European Union, the European Economic Area, the United Kingdom and Switzerland. The app is not available on App Store storefronts in those countries.

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.

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.

15. Cookies and Tracking Technologies

Tubely uses only the first-party cookies needed to keep you signed in: the session cookies set by Supabase Auth. The public pages, including this one, set no cookies at all. Protection against cross-site request forgery is done by checking where a request came from, not with a cookie.

We do not use third-party tracking cookies, advertising cookies, social media tracking pixels, or any other non-essential cookies or tracking technologies. We do not participate in cross-site tracking or interest-based advertising.

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.
Where we are able to, also show a notice inside 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.