App Privacy Policy

Privacy at a glance

• Blissiree Pty Ltd is based in Perth, Western Australia and operates an emotional wellbeing app focused on nervous system and emotional regulation.
• Depending on the features you use, information you choose to provide may include wellbeing-related information that can be sensitive or health information under applicable privacy law.
• We collect only information reasonably necessary for the App and use sensitive or health information only with consent or as otherwise permitted by law.
• You may have rights to access, correct, delete, restrict, object to, or receive a copy of your information, depending on where you live and the law that applies.

1. About this Privacy Policy

This Privacy Policy explains how Blissiree Pty Ltd ("Blissiree", "we", "us" or "our") collects, holds, uses, discloses, protects and otherwise handles personal information in connection with the Blissiree emotional wellbeing application (the "App"), our website, customer support, communications, and related services (collectively, the "Services").

Blissiree is an Australian company based in Perth, Western Australia. Our privacy practices are designed with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) in mind. If you access the Services from another country, additional privacy laws may apply to you, including laws in the European Economic Area (EEA), the United Kingdom, California or other jurisdictions.

This Privacy Policy applies only to information handled by Blissiree. It does not govern the independent privacy practices of Apple, Google, payment processors, social networks, third-party websites, or other services that you choose to use with the App.

2. Who We Are and How to Contact Us

The entity responsible for personal information handled under this Privacy Policy is:

3. Information We May Collect

The information we collect depends on which Services and features you use. We aim to minimise collection and not request information that is not reasonably necessary for the relevant function or activity.

3.1 Account, profile and contact information

• name, display name or username;
• email address, telephone number or other contact information;
• password or authentication information in protected form;
• age or date-of-birth information where needed to apply age restrictions; and
• account settings, preferences, language, time zone and communication choices.

3.2 Wellbeing, emotional and potentially sensitive information

Because the App is designed for emotional wellbeing, nervous system regulation and emotional regulation, information you voluntarily enter or generate through the App may reveal information about your physical, psychological or emotional health. Under Australian privacy law, some of this information may be "health information" and "sensitive information".

• responses to wellbeing, mood, stress, regulation or self-reflection questions;
• journal entries, notes, check-ins, reflections, goals or self-reported experiences;
• information about symptoms, emotions, stressors, coping strategies or wellbeing patterns that you choose to provide;
• content you submit when communicating with support or using interactive features; and
• information generated from your use of App features, where that information can reasonably be linked to you and relates to your wellbeing.

We will seek consent for the collection of sensitive or health information where consent is required by law. You should provide only information that you are comfortable sharing and that is relevant to your use of the Services.

3.3 App usage, device and technical information

• device type, operating system, app version, language and general technical configuration;
• IP address and approximate location derived from IP address, where available;
• device or advertising identifiers where permitted and enabled;
• log data, session information, feature interactions and timestamps;
• diagnostic, crash, performance and error information; and
• analytics information about how the App or website is used.

3.4 Purchases and subscriptions

If paid subscriptions, in-app purchases or other transactions are offered, payments may be processed by an app store or third-party payment provider. Blissiree may receive information such as purchase status, subscription type, transaction identifier, renewal status and limited billing information. We generally do not receive or store your full payment-card number when payment is processed entirely by a third party.

3.5 Communications and support

If you contact us, we may collect your contact details, the content of your message, attachments you choose to provide, support history, feedback, survey responses and information reasonably necessary to respond to your request.

3.6 Device permissions and integrations

Certain optional App features may request access to device functions or third-party integrations, such as notifications, microphone, camera, photo library, health or fitness data, or other services. We will request permission through your device or the relevant service before accessing information that requires permission. You can usually change these permissions in your device settings. The App must be updated before launch to identify which permissions and integrations are actually used.

3.7 Information about other people

Please do not provide personal or sensitive information about another person unless you have a lawful basis and any consent required to do so. If you provide information about another person, you are responsible for ensuring that you are authorised to provide it.

4. How We Collect Information

We may collect personal information:

• directly from you when you create an account, enter information, use features, make choices, complete assessments or contact us;
• automatically from your device or browser when you use the Services, subject to your settings and applicable consent requirements;
• from app stores, payment providers, authentication providers or other services you choose to connect;
• from service providers that help us operate, secure, analyse or support the Services; and
• from publicly available sources or other lawful sources where reasonably necessary and permitted by law.

Where practicable and lawful, you may be able to interact with some parts of the Services without identifying yourself or by using a pseudonym. Some functions may require identification to create an account, secure your data, process a payment, provide a requested service or comply with law.

5. Why We Use Personal Information

We may collect, hold, use and disclose personal information for the following purposes, as relevant to the Services you use:

• to create, authenticate, administer and secure your account;
• to provide App features, content, exercises, tools and services you request;
• to personalise or improve your experience, where permitted and appropriate;
• to remember preferences and maintain continuity across sessions;
• to process subscriptions, purchases and account entitlements;
• to provide customer support and respond to questions, feedback or complaints;
• to communicate important service, security, privacy or account information;
• to analyse performance, diagnose errors, prevent fraud, misuse or security incidents, and maintain the Services;
• to improve and develop the Services using aggregated, de-identified or appropriately protected information where practicable;
• to comply with legal obligations, lawful requests and the enforcement or defence of legal rights; and
• for other purposes that are disclosed to you and for which we obtain consent where required.

5.1 Sensitive and health information

We will only collect sensitive or health information where the collection is reasonably necessary for our functions or activities and where you consent, unless an exception under applicable law allows or requires the collection. We do not use sensitive wellbeing information for unrelated advertising purposes unless a lawful basis and any consent required by law are in place.

5.2 EEA and UK legal bases

If the EU General Data Protection Regulation (GDPR) or UK GDPR applies to our processing, we rely on one or more lawful bases depending on the activity, including performance of a contract, consent (including explicit consent where required for special-category data), compliance with legal obligations, and legitimate interests where those interests are not overridden by your rights and interests. Where we rely on consent, you may withdraw it at any time for future processing.

6. Personalisation, Analytics and Automated Features

The Services may use rules, algorithms or automated tools to organise content, remember preferences, identify usage patterns, recommend features or personalise the experience. Whether and how these tools use personal information will depend on the final App design.

Unless we clearly tell you otherwise, Blissiree does not intend App personalisation to make decisions that produce legal effects or similarly significant effects about you. If we introduce automated decision-making that significantly affects a person’s rights or interests, we will update this Privacy Policy and provide any notices, explanations, safeguards or choices required by applicable law.

7. When We May Disclose Personal Information

We do not disclose personal information except as reasonably necessary for the purposes described in this Privacy Policy, with your consent, or as permitted or required by law. Depending on our final technology stack, recipients may include:

• cloud hosting, database, storage and content-delivery providers;
• analytics, diagnostics, crash-reporting and security providers;
• communications, email, push-notification and customer-support providers;
• payment processors and app stores where subscriptions or purchases are offered;
• professional advisers such as accountants, auditors, insurers and legal advisers;
• law enforcement, regulators, courts or government authorities where disclosure is lawfully required or permitted;
• a purchaser, investor, successor or adviser involved in a proposed or completed corporate transaction, subject to appropriate confidentiality and legal safeguards; and
• other recipients you direct us to disclose information to or for which you provide consent.

Service providers are expected to handle personal information only for authorised purposes and under appropriate contractual, confidentiality, security and privacy requirements, where applicable.

8. Overseas Disclosures and International Transfers

Blissiree is based in Australia but the App is intended for an international audience. Some service providers may store or process personal information outside Australia. This may occur when cloud hosting, analytics, customer support, communications, app-store, security or other technology providers operate internationally.

Before publication, Blissiree should confirm the locations of its principal service providers and complete the following field where practicable: likely overseas recipient locations include [INSERT COUNTRIES/REGIONS AFTER CONFIRMING PROVIDERS].

Where Australian Privacy Principle 8 applies, we will take reasonable steps required by law in relation to cross-border disclosures. Where the GDPR or UK GDPR applies to a restricted international transfer, we will use a lawful transfer mechanism where required, such as an adequacy decision, contractual safeguards or another permitted mechanism.

9. Cookies, SDKs, Analytics and Similar Technologies

Our website and App may use cookies, software development kits (SDKs), local storage, pixels or similar technologies for functions such as login, security, preferences, analytics, crash reporting, performance measurement and communications. The exact technologies used must be confirmed before launch.

Where required by applicable law, we will request consent before using non-essential tracking technologies. You may also be able to control certain technologies through device settings, browser settings, in-app privacy settings, or an applicable consent-management tool.

10. Marketing Communications

We may send marketing or promotional communications where permitted by law and consistent with your choices. You can opt out of marketing emails by using the unsubscribe mechanism in the communication or by contacting us. You may be able to disable promotional push notifications in your device settings. Even if you opt out of marketing, we may still send non-promotional communications that are necessary for your account, transactions, security, legal notices or requested services.

11. Data Retention and Deletion

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, to provide the Services, meet legal, accounting or compliance obligations, resolve disputes, protect users and the Services, and enforce agreements. Retention periods may vary depending on the type of information and why it is held.

When personal information is no longer required and we are not legally required to retain it, we will take reasonable steps to delete it, destroy it or de-identify it, subject to backup cycles, technical limitations and lawful retention requirements. If the App provides an account-deletion function, the final policy should describe the process and any retention exceptions.

12. Security of Personal Information

We take reasonable technical and organisational measures designed to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure. Measures may include access controls, authentication, encryption in transit and/or at rest where appropriate, secure development practices, logging, backups, vendor due diligence, staff access restrictions and incident-response procedures.

No internet, mobile or storage system can be guaranteed to be completely secure. You are responsible for protecting your account credentials and should contact us promptly if you believe your account or information has been compromised.

13. Data Breaches and Security Incidents

If we become aware of a suspected data breach or security incident, we will assess and respond to it in accordance with applicable law.

Where the Australian Notifiable Data Breaches scheme applies and an eligible data breach is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required. We will also comply with applicable notification obligations in other jurisdictions.

14. Your Privacy Rights and Choices

Your rights depend on where you live and which privacy law applies. We may need to verify your identity before acting on certain requests. We will not discriminate against you for exercising a privacy right that applicable law gives you.

14.1 Australia

Subject to the Privacy Act and applicable exceptions, you may request access to personal information we hold about you and ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading. You may also make a privacy complaint using the contact details in Section 19.

We will respond to access, correction and complaint requests within the time required by applicable law and, where no fixed period applies, within a reasonable period. If we refuse a request, we will provide reasons where required and explain available complaint mechanisms.

14.2 EEA and United Kingdom

Where the GDPR or UK GDPR applies, and subject to legal conditions and exceptions, you may have rights to:

• be informed about how your personal data is processed;
• access your personal data;
• correct inaccurate or incomplete personal data;
• request erasure of personal data;
• restrict processing;
• receive certain personal data in a portable format;
• object to certain processing, including direct marketing;
• withdraw consent at any time where processing is based on consent; and
• seek safeguards relating to certain solely automated decisions that significantly affect you.

You may also have the right to lodge a complaint with the data-protection authority in the country where you live, work, or where you believe an infringement occurred.

14.3 California and other jurisdictions

Privacy laws in California and other jurisdictions may provide additional rights if the relevant law applies to Blissiree and to your information. These may include rights to know or access information, request correction or deletion, receive information about disclosures, opt out of certain uses or disclosures, limit certain uses of sensitive personal information, or appeal a decision on a privacy request. Blissiree will provide any additional notices and request mechanisms that are legally required based on the jurisdictions in which the App is actively offered and the thresholds that apply.

14.4 How to exercise your rights

To make a privacy request, contact us at conciergesupport@blissiree.com. Please describe the request and the account or email address involved.

We may request reasonable information to verify your identity and authority. If you use an authorised agent where permitted, we may request evidence of the agent’s authority and may still need to verify your identity directly.

15. Children and Young People

Blissiree must confirm the minimum age for the App before launch. The public version of this Privacy Policy should state the actual age requirement and any parental-consent process.

Until that decision is confirmed, the Services should not knowingly collect sensitive wellbeing information from a child in circumstances where valid consent or other legal requirements have not been satisfied. If we learn that personal information from a child has been collected contrary to applicable law or our stated age requirements, we will take reasonable steps to delete or otherwise lawfully address the information.

If the App is intended to be used by children or teenagers, Blissiree should implement age-appropriate privacy information, consent and safeguarding measures before launch and review any jurisdiction-specific requirements that apply to young users.

16. De-identified and Aggregated Information

We may create aggregated or de-identified information for analytics, safety, research, reporting, service improvement or business planning where permitted by law.

We will take reasonable steps appropriate to the context to reduce the risk that de-identified information can be re-identified. If information can reasonably be linked back to an identifiable individual, we will continue to treat it as personal information as required by applicable law.

17. Third-Party Services and Links

The Services may contain links to or integrations with third-party websites, app stores, platforms or services. Those third parties may collect information independently and operate under their own privacy notices and terms. We encourage you to review their privacy practices before providing information to them. Blissiree is not responsible for an independent third party’s privacy practices except to the extent applicable law provides otherwise.

18. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to the App, our information-handling practices, service providers, legal requirements or other operational needs. We will update the "Last updated" date and provide additional notice where required by law or where changes are material. Where consent is required for a new use of sensitive information, we will seek that consent before the new use.

19. Contact, Questions and Privacy Complaints

For privacy questions, access or correction requests, withdrawal of consent, or complaints, contact:

We will review privacy complaints and respond within a reasonable period. If you are in Australia and are not satisfied with our response, you may be entitled to complain to the Office of the Australian Information Commissioner (OAIC). Information about making a privacy complaint is available at www.oaic.gov.au.

If you are in another jurisdiction, you may also have the right to contact your local privacy or data-protection regulator where applicable.