Privacy Policy
1. Who this policy is about
Kygra Care ("we", "us") is operated by Graeme Weatherill, sole trader, ABN 47 022 872 945 (active from 15 July 2026), trading as Kygra Care (business name registered with ASIC 15 July 2026, reference 1-ZY12LMN).
This policy covers the Kygra Care invoicing app (web and installed PWA) and applies to:
- Workers — the NDIS support workers who hold an account (e.g. Kym, Dale, and future users)
- Participants — the NDIS participants named in a worker's client records, who don't hold an account themselves but whose details a worker enters
- Visitors — anyone who reads our public pages without logging in. We collect very little about you and never identify you individually (see section 2, "Visits to our public pages")
Participants and this policy — who is responsible for what. A worker enters participant information into their own account as part of running their own NDIS support business. For that information, Kygra Care acts as a processor on the worker's instructions — we hold and process it to provide the service, but the worker remains responsible for having whatever consent or notice they need from their own participants under their own service agreements and obligations (including the NDIS Code of Conduct). If a participant wants to see, correct, or have deleted information a worker has recorded about them, that request should go to the worker who holds the account, since they control that record; Kygra Care can help the worker action it but isn't the right first point of contact for a participant directly.
2. What we collect
Worker account information
- Name, email address, password (stored as a bcrypt hash, never in plain text)
- Provider details entered in Settings: ABN, business address, phone, BSB and bank account number (used only to print on invoices you generate)
Your network address (IP address)
- When you register, and when you accept these terms, we record the network address your device was using at that moment, together with your browser type and the date and time. This is kept as evidence of who agreed to what and when, which is the reason the acceptance record exists at all.
- The same is recorded against security events on your account, such as a successful password reset, so an unexpected change can be investigated.
- Network addresses are also held briefly in memory to limit how many login, registration and calculator attempts can come from one connection in a short period. That short-term use protects the service against abuse and is not written to the database.
- We do not use your network address to work out where you live, to build a profile, or for advertising.
Client (participant) information, entered by the worker
- Name, address, NDIS number
- Participant email address and phone number, where entered (used to send the participant documents such as a service agreement)
- The name, relationship, and email address of the participant's representative or nominee, where they have one
- Plan manager name and email, where applicable
- Support category and the per-item rates agreed for that client
Service agreement records
- Where a worker generates a service agreement for a client, we store the agreement's own details (the participant's goals, support frequency, and agreement dates the worker enters), and a record of when it was emailed, to whom, and the email provider's delivery reference. Each time an agreement is emailed, we also keep a saved snapshot of the version that was sent (the participant and provider details, and the supports and prices as they stood at that moment), so that an exact copy of what the participant received can be reproduced later. We do not keep the emailed PDF file itself; the copy is regenerated from the saved snapshot.
- When you use "Clean up my text" on the goals or support-frequency fields, we also check the wording for language that may not suit a document the participant reads, and show you what we changed or flagged before you use it. If wording is flagged and you choose to email the agreement anyway, we keep a short record that you did so — which field, the type of flag, the date, and a one-way fingerprint of the text — but not the wording itself.
Shift and invoice records
- Dates, times, support item codes, and any notes entered against a shift
- Generated invoices and their issue/lock history
- When an invoice is issued, we keep a saved copy of it exactly as issued (the participant and provider details, and every line, rate and total as they stood at that moment), so that the invoice a plan manager received can be reproduced later even after rates or contact details change. We do not keep the PDF file itself; the copy is regenerated from the saved record. This is the same approach used for service agreements above, and holds no information beyond what is already listed here.
Voice input
- If you use voice entry, your browser records a short audio clip (capped at up to 2 minutes, depending on what you're recording) that is sent to Deepgram for transcription (see section 3) and then discarded once transcribed — Kygra Care does not store the audio after transcription.
We do not collect information about participants directly — everything about a participant comes from what the worker enters, on the worker's own account.
Feedback you send us
- If you send feedback through the in-app feedback button, we store the message you write, an optional category you pick (for example: bug, idea, question), which page you were on when you opened it, and the date and time. Sending feedback is optional — we only collect this if you choose to write to us. Please don't include a participant's personal details in a feedback message; it isn't the place for them.
Visits to our public pages
- Most public pages (the home page and other marketing pages you can read without logging in) count visits using Cloudflare Web Analytics, so we can tell whether anyone is finding the site and which pages they read. It records the page address, the site you arrived from, your browser type, and the country your visit came from. It sets no cookie, does not follow you across other websites, and does not build a profile of you — we see counts, not people, and cannot tell who you are from it.
- This runs on public pages only. It is not present anywhere inside the app, or on the login, registration, password-reset or email-verification pages. Nothing about your account, your clients, your shifts or your invoices is ever seen by Cloudflare Web Analytics.
- The public NDIS shift-rate calculator is counted like any other public page, including a result page. Because the counting records the page address, and a result page's address carries the shift details you checked (support type and level, date, times and price region), those details are included in that count. They do not name you, a participant or an organisation, they are not linked to any account, and nothing in them shows whether the check describes real work or a trial run. Counting continues to set no cookie and to build no profile of you.
Public NDIS shift-rate calculator
- The calculator receives the support type and level, shift date and times, state or territory, and an optional support-location postcode that you enter. It does not ask for a participant or worker name, NDIS number, account details or notes.
- An entered postcode is used once to choose the NDIS National, Remote or Very Remote price column. Kygra Care does not save it in the database or include it in the result URL. The shared result URL contains the remaining shift inputs and the derived price region so the server can recalculate the answer. Kygra Care keeps no calculator history.
- Calculator pages are counted by Cloudflare Web Analytics the same way as every other public page, as described under "Visits to our public pages" above, which means a result page's web address and the shift details it carries are included in that count. Kygra Care's own application request logging is switched off across the whole app, so Kygra Care does not create a second copy of the result URL in its own logs. Render still receives each request as the hosting provider and may include the requested URL in its platform HTTP logs where that feature applies. Those logs follow Render's plan-dependent retention, currently 7 days on Hobby, 14 days on Pro and 30 days on Scale or Enterprise plans (checked 2 August 2026). The raw postcode is submitted in the request body, never the shared URL.
Cookies
- Kygra Care sets one cookie: a signed session cookie that keeps you logged in and holds short-lived in-progress data (e.g. a shift you're partway through entering). It is strictly necessary for the app to function — we do not use advertising or tracking cookies, our public-page visit counting (above) is cookieless, and no consent banner is needed under Australian privacy law. The cookie is cleared when you log out.
3. Third parties who process data on our behalf
Kygra Care uses these outside services to run the app. None of them are permitted to use your data for their own purposes — they process it only to provide the service to us.
| Service | What it processes | Where |
|---|---|---|
| Anthropic (Claude API) | Text you type or dictate — shift descriptions, progress notes, and service-agreement details such as the participant's goals and how often you provide support — to parse it into structured shift data, tidy it into clear wording, and (for service-agreement text) check it reads respectfully and suggest wording suitable for a document the participant reads | United States |
| Deepgram (transcription) | Voice recordings, to transcribe to text. Recordings are capped at up to 2 minutes per clip and are not stored by Kygra Care after transcription. | United States |
| Render (hosting) | All account, client, shift and invoice data in the app's database; transient public-calculator inputs, including an optional postcode in the submitted request and the non-identifying shift inputs in a shared result URL. Kygra Care does not save public calculator checks, but Render may retain platform HTTP request logs for its plan-dependent log-retention period. | Singapore |
| Backblaze B2 (database backups) | A daily backup copy of the whole app database, so your records can be recovered if the hosting is lost: all account, client, shift and invoice data, including participant details, shift notes and invoices. The copy is stored in a private bucket, not readable by anyone on the public internet, and Backblaze encrypts it while it is stored. How long each copy is kept is in section 6. | Netherlands |
| Resend (email) | Invoice PDFs and email addresses, sent when you email an invoice from the app. Also used for account security emails — email verification, password reset links, a confirmation when your password changes, and confirming a change to your login email address. Also carries any feedback you choose to send us, and a notice to our own support inbox with your name and email address when you first verify a new account, so we know someone has joined. | United States |
| Stripe (payments) | If you subscribe to Kygra Care Plus: your name, email address, and payment details, to process your subscription. Kygra Care never sees or stores your card number — Stripe collects it directly. | United States |
| Cloudflare (public-page visit counting) | Visits to public pages only: the page address, the site you arrived from, your browser type, and the country the visit came from. Cookieless, no cross-site tracking, and no individual identification. This includes the public shift-rate calculator in full, so a result page's address and the shift details it carries (support type and level, date, times, price region) are counted too — details that name nobody and are tied to no account. Not present on any logged-in screen, or the login, registration, password-reset or email-verification pages, so it never sees account or participant data. | United States |
Sending data to Anthropic, Backblaze, Cloudflare, Deepgram, Render, Resend, and Stripe all count as overseas disclosures under the Privacy Act, since none of them are in Australia.
We do not sell, rent, or otherwise trade personal information to anyone.
4. Why we collect and use this information
- To provide the invoicing service you've signed up for: recording shifts, calculating rates, generating and issuing invoices
- To operate your account: login, session security, email verification, password reset, and confirming email address changes
- To send invoices by email, where you use that feature
- To improve the parsing accuracy of the voice/text entry feature over time
- To help you write service-agreement wording that is clear and respectful of the participant, by checking the text and flagging language that may not suit a document the participant reads
- To receive, understand, and respond to feedback you choose to send us
- To count visits to our public pages, so we can tell whether people are finding the site and which pages are worth keeping. This is aggregate counting of anonymous visits, not tracking of individuals, and it does not run inside the app
- To calculate the dated NDIS maximum price for the public shift details you enter, without creating an account or saved calculator history
- To run and support the service as its operator: we can see account status, account security events (such as when an account verified its email address or requested a password reset), setup and activity dates (when an account added its first participant record, set up a rate, created a service agreement, logged a shift, or issued an invoice), how many of each of those an account has, and subscription/billing status across accounts, so we can operate the service, provide support, understand where new accounts get stuck, and manage billing. This uses account, setup and usage status only — counts and dates — not the participant details inside a worker's records (no participant names, NDIS numbers, shift categories, notes, or invoice amounts).
We don't use your data for advertising, and we don't build profiles of participants for any purpose beyond the invoice you're generating.
5. Sensitive information
Some of what a worker enters (support category, notes, the fact someone receives NDIS-funded supports at all) can reveal information about a participant's disability. We treat this as sensitive information under the Privacy Act: it's collected only because it's necessary to generate an accurate invoice, it isn't used for any other purpose, and it isn't disclosed beyond the third-party processors listed in section 3.
State-based health records law (for example, the NSW Health Records and Information Privacy Act, or Victoria's Health Records Act) may also apply to this information in addition to the federal Privacy Act, depending on where a worker or participant is based. See section 10 for the open question on which of these applies to Kygra Care.
6. How long we keep information
- Invoice history is kept for approximately 5 years after a worker's account becomes inactive, matching standard record-keeping practice for tax and business records.
- If you close your account, ask us to delete your data sooner and we will, except where we're required to keep invoice/tax records for the retention period above.
- Feedback you send us is kept only while it's useful for improving the app. It isn't invoice or tax data, so the 5-year period above doesn't apply to it, and you can ask us to delete it at any time.
- Public calculator checks and postcodes are not saved in Kygra Care's database or application request logs. Render may retain its platform HTTP request logs for the plan-dependent period described in section 2, and Cloudflare holds the visit counts described in sections 2 and 3.
- Database backups (the Backblaze row in section 3) are not kept indefinitely. A copy is taken each day and deleted automatically after about 31 days. The copy taken on the first of each month is kept longer, for about 5 years, to match the invoice record-keeping period above, and is then deleted automatically as well. Deleting something in the app removes it from the live service straight away, but a copy of it stays in whichever backups were already taken until those backups reach the ages above and are deleted. The same applies if you ask us to delete your data under section 8: we action it on the live service immediately and the backup copies then age out on this schedule.
7. Security
- Passwords are hashed (bcrypt), never stored or transmitted in plain text.
- Each worker's data is isolated from every other worker's: one worker account cannot see another's clients, shifts, or invoices. This isolation is between worker accounts. As the operator we can access account, activity, and subscription/billing status across accounts to run, support, and bill the service (see section 4), but never to expose one worker's participant details (their clients, shift notes, or invoice contents) to another worker.
- Database backups are stored encrypted in a private Backblaze B2 bucket, separate from the live Render hosting. Because that bucket is in the Netherlands, the backup is an overseas disclosure in its own right. It is listed in the section 3 table with everything else, and how long each copy is kept is in section 6.
8. Access and correction
You can view and edit your own client, shift, and invoice records directly in the app at any time. To request a copy of your data, a correction, or deletion beyond what the app lets you do yourself, contact us at help@kygracare.com.au. If you are a participant rather than a worker, see section 1 above for how to raise this with your worker directly.
9. Data breaches
If we become aware of a data breach involving your information that is likely to result in serious harm, we'll notify the Office of the Australian Information Commissioner (OAIC) and affected individuals as required under the Notifiable Data Breaches scheme, and take reasonable steps to contain and address it. We'll tell you what happened, what we're doing about it, and what you can do to protect yourself, as soon as practicable.
10. Complaints
If you think we've mishandled your personal information, contact us first at help@kygracare.com.au so we can try to resolve it directly. If you're not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au, or to the NSW Information and Privacy Commission (IPC) at ipc.nsw.gov.au if your complaint concerns health information and the NSW Health Records and Information Privacy Act (HRIP Act) applies.
11. Changes to this policy
We'll update this policy as the app or our processors change, and note the date of the latest change at the top of the page users see in-app.
12. Contact
help@kygracare.com.au