Rostera Privacy Policy

1. About this policy

1.1. This privacy policy explains how OneOtium Pty Ltd (ACN 699 521 278) (ABN 37 699 521 278) (Rostera, we, us or our) collects, holds, uses and discloses personal information in connection with the Rostera mobile application and the Rostera website at rosteraapp.com (together, the App).

1.2. This policy applies to individual Users of the App.

1.3. We are committed to handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

1.4. This policy should be read together with our User Terms and Conditions, and forms part of them.

1.5. Capitalised terms used but not defined in this policy have the meaning given to them in our User Terms and Conditions, including App, App Store, Crew, Crew Creator, Estimate, Shift Times, Subscription, Uploaded Documents, User Account and User Content.

2. What personal information we collect

2.1. From Users, we collect:

• (a) identity and contact information, including your name and email address, which you provide when you create a User Account;
• (b) your self-declared confirmation that you are 18 years or older;
• (c) the rosters and Shift Times you record, including any label or description you attach to a shift;
• (d) the pay rates, penalties, loadings and allowances you enter, and the Estimates generated from them;
• (e) your continuing professional development logbook entries, and your registration and credential records;
• (f) your Crew membership, being which Crews you belong to and the Shift Times you share through them;
• (g) your journal entries;
• (h) your Uploaded Documents, including certificates, qualifications, registrations, tickets and payslips, and the file metadata associated with them, such as file name, file type, file size and upload date;
• (i) questions you ask the shift estimator feature, and the outputs generated in response (see clause 5);
• (j) technical and usage information from your device (see clause 9);
• (k) your Subscription and entitlement information, which we receive from our subscription management provider and the App Store (see clause 10); and
• (l) any information you provide to us directly, including in a support request.

2.2. Some information you choose to record in the App may be sensitive information under the Privacy Act 1988 (Cth). The categories most likely to be sensitive are:

• (a) a registration, credential or professional development record that identifies you as a member of a professional association, where that association is one whose membership is treated as sensitive information. Not every credential record is sensitive. A generic ticket, licence or course certificate usually is not;
• (b) a journal entry, shift label or logbook entry in which you choose to record information about your own health, or about any other sensitive matter; and
• (c) the contents of an Uploaded Document, where the document itself records sensitive information.

2.3. Recording sensitive information in the App is entirely voluntary. You can use every feature of the App without doing so, and we ask you not to. In particular, you should not record health information in the journal, and you should redact anything you do not need before uploading a document.

2.4. Where you do choose to record sensitive information, we collect and hold it only because it is reasonably necessary to provide the feature you are using - that is, to display your own records back to you and to remind you of an expiry date. By choosing to record that information in the App, you consent to us collecting and holding it for that purpose. We do not use sensitive information for any secondary purpose, we do not use it for marketing, and we do not disclose it other than as set out in clauses 10 and 11.

2.5. We recognise that, despite the instructions in this policy and in our User Terms and Conditions, a User may in practice record health information or other sensitive information in a journal entry, a shift label, a logbook entry, a support request, a question to the shift estimator feature, or an Uploaded Document. Where that happens, we treat that information as personal information, and as sensitive information where it is, and we handle it in accordance with this policy. Our instructions to you do not reduce our own obligations.

2.6. We do not require you to provide payment card details. Subscriptions are sold and billed by the App Store, and we do not receive or store your payment card details.

2.7. We do not require your tax file number, your bank account details, or any health information, and we ask you not to record them in the App. See clauses 7 and 8.

3. How we collect personal information

3.1. We collect personal information directly from you, including when you create a User Account, record information in the App, upload a document, use the shift estimator feature, join or create a Crew, or contact our support team.

3.2. We collect technical and usage information automatically from your device when you use the App.

3.3. We collect personal information from a third party, including our subscription management provider and the App Store, in connection with your Subscription and entitlement status.

3.4. If you join a Crew, we collect the Shift Times that other members of that Crew have chosen to share, and those other members receive the Shift Times you have chosen to share. See clause 6.

4. How we use your personal information

4.1. We use personal information to:

• (a) provide, operate, secure and improve the App;
• (b) create and manage your User Account;
• (c) confirm that you meet the minimum age requirement;
• (d) record and display your rosters, Shift Times, logbook entries, credential records, Uploaded Documents and journal entries;
• (e) generate Estimates from the information you enter, including through the shift estimator feature;
• (f) operate the Crew function and share Shift Times between members of a Crew;
• (g) manage your Subscription, including confirming your Subscription status and free trial eligibility;
• (h) provide customer support and respond to your enquiries;
• (i) send you operational notifications about your shifts, credentials and Subscription;
• (j) send you marketing communications, where you have consented (see clause 12); and
• (k) comply with our legal obligations, and manage any legal claim or dispute.

4.2. We do not use your personal information for any purpose that is not set out in this policy, unless you consent or we are required or authorised by law to do so.

5. Estimates, automated processing and artificial intelligence

5.1. When the App calculates an Estimate of your pay or superannuation from the rates and shift details you have entered, it does so by applying the rules you have set up. That calculation does not involve artificial intelligence and does not send your information to any additional provider beyond our platform and hosting provider.

5.2. The App also includes a shift estimator feature, which allows you to ask a question about the estimated effect of working additional or different shifts. That feature uses artificial intelligence services, and clauses 5.3 to 5.10 apply to it.

5.3. When you use the shift estimator feature, we send the text of your question and the shift and pay information needed to answer it. We do not send your name, your email address, your journal entries, your credential records or the contents of any Uploaded Document.

5.4. Your question and the response are processed through our platform provider, Base44, which may use its own subprocessors to supply that service. See clause 11.

5.5. That processing occurs in the United States. See clause 11.

5.6. The shift estimator feature is optional. You can use every other feature of the App without using it, and you do not need to use it to record shifts, generate an ordinary Estimate, maintain your logbook, or share Shift Times with a Crew.

5.7. No output of the shift estimator feature is reviewed by a person before it is given to you.

5.8. An Estimate is a guide only. It is not a decision about you.

5.9. No Estimate, and no automated feature of the App, determines your employment status, your roster allocation, your remuneration or entitlements, your registration or credential status, or your eligibility for anything.

6. Crews and shift sharing

6.1. The App includes a Crew function, which allows you to share your Shift Times with other Users. If you join a Crew, the Shift Times you record are disclosed to every other member of that Crew, and you can see theirs.

6.2. Only Shift Times are shared through a Crew. Your pay inputs, Estimates, logbook entries, credential records, Uploaded Documents and journal entries are not shared through a Crew.

6.3. You can leave a Crew at any time, and the Crew Creator can delete the Crew. How you join, leave and delete a Crew is set out in our User Terms and Conditions.

6.4. We cannot control how another member of a Crew uses, copies, records or discloses information you share through a Crew, and we are not responsible for their conduct. This does not limit our own obligations under this policy or the Privacy Act 1988 (Cth).

7. Journal

7.1. Journal entries are not visible to other Users through the App, and are not shared through a Crew. They are nevertheless stored and processed by us and by our service providers as necessary to host, secure, back up and provide the App.

7.2. The journal is not a health record. You must not record health information, any other sensitive information, or information about any other identifiable person, including any patient, client, colleague or customer, in the journal.

8. Documents you upload

8.1. The App allows you to upload documents to support your records, including certificates, qualifications, registrations, tickets and payslips.

8.2. When you upload a document we store the document, the file metadata associated with it, and any details you enter about it, so that we can display it back to you. We do not read your documents for our own purposes, and we do not verify or check them against any external register.

8.3. We may apply automated processes to an Uploaded Document so that the App works and stays secure. These may include:

• (a) scanning the file for malicious code;
• (b) generating a preview image or thumbnail;
• (c) extracting text so that you can find a document by searching; and
• (d) recording technical information about the file.

8.4. Those processes are automated. No person at Rostera reads your documents.

8.5. We do not send the contents of an Uploaded Document to the shift estimator feature or to any other artificial intelligence service. The shift estimator feature described in clause 5 is the only feature of the App that uses artificial intelligence.

8.6. Uploaded Documents are included in the backups taken by our hosting provider. See clause 14 for how long backups are held.

8.7. A payslip or similar document may contain your tax file number or your bank account details. We do not require that information and we ask you to remove or redact it before uploading. We do not use or disclose a government related identifier, including a tax file number, as an identifier for you, and we do not extract, index or otherwise process it.

8.8. If we become aware that a document containing a tax file number, bank account details, or the personal information of another individual has been uploaded, we may quarantine or delete that document, and we may ask you to upload a redacted version. You can also delete an Uploaded Document yourself at any time, and you should do so if you realise you have uploaded something you did not intend to.

8.9. You should not upload a document containing the personal information of another individual unless that individual has consented, or you are otherwise entitled to provide it to us. See clause 18.

9. Analytics, cookies and notifications

9.1. We collect technical and usage information through the App and the platform that hosts it, so that we can understand how the App is used and identify faults. That information may include:

• (a) your device type and operating system version;
• (b) the version of the App you are using;
• (c) a device or installation identifier;
• (d) the features you use and when you use them; and
• (e) the details of any error or crash.

9.2. Where we engage a separate analytics or crash reporting provider, we name that provider in clause 10.1.

9.3. Our website uses cookies that are strictly necessary for the site to function and to keep it secure, and may use cookies that measure how the site is used. You can block or delete cookies through your browser settings, although the site may not work properly if you block strictly necessary cookies. We do not use cookies to build a profile of you or to serve you advertising.

9.4. We may send you notifications about your upcoming shifts, expiring credentials, security matters and your Subscription. These are necessary to operate the App and are not marketing.

9.5. We may also send you push notifications that are marketing, where you have consented. See clause 12.

9.6. You can manage or disable push notifications through your device settings. Disabling push notifications does not unsubscribe you from marketing emails. To stop marketing emails, see clause 12.

10. Disclosure of personal information

10.1. We disclose personal information to the following service providers, who help us operate the App:

• (a) Base44, our platform and hosting provider, which hosts the App, stores your User Content including your Uploaded Documents and journal entries, and provides the artificial intelligence services used by the shift estimator feature (see clause 5.4);
• (b) RevenueCat, our subscription management provider. RevenueCat receives information about your Subscription, which may include a transaction or purchase identifier, a product identifier, your entitlement and free trial eligibility status, purchase and renewal dates, an anonymous or App-generated user identifier, and technical information about your device and App version; and
• (c) Apple and Google, through the relevant App Store, which process Subscription purchases as merchant of record and provide us with the resulting purchase and entitlement information.

10.2. We remain responsible for the personal information we disclose to a service provider. Before engaging a provider we take reasonable steps to satisfy ourselves that it maintains security practices appropriate to the kind of information involved. We disclose only the information the provider needs in order to perform its function, we limit who within Rostera can access provider systems, and we review our providers from time to time. We also monitor the security notices each provider publishes.

10.3. We currently engage each of these providers on that provider's standard terms of service, which include that provider's own security, confidentiality and data handling commitments. We will update this policy if that changes.

10.4. We do not disclose personal information to any other third party, except:

• (a) to another User, where you choose to share Shift Times through a Crew;
• (b) as required or authorised by law;
• (c) to a professional adviser, to the extent reasonably necessary; or
• (d) in connection with a sale, merger or restructure of our business.

10.5. We do not sell personal information to any third party.

11. Overseas disclosure

11.1. Our platform and hosting provider, Base44, stores and processes information on servers located in the United States. Our subscription management provider, RevenueCat, and the App Store operators, Apple and Google, are also located in, or process information in, the United States and may process information in other countries in which they operate.

11.2. This means your personal information, including your Shift Times, pay inputs, logbook entries, credential records, journal entries, Uploaded Documents and any question you ask the shift estimator feature, is stored and processed outside Australia.

11.3. Each of these providers may engage its own subprocessors, which may be located in other countries. We are not always told the identity or location of a provider's subprocessors in advance.

11.4. Before engaging an overseas provider we take reasonable steps to satisfy ourselves that it maintains appropriate security practices, we disclose only the information the provider needs, and we review our providers from time to time.

11.5. We will update this policy if we change provider, or if a provider changes the location of its processing.

11.6. The United States has data protection laws that differ from, and may be less comprehensive than, the Australian Privacy Principles.

11.7. An overseas recipient may not be subject to the Privacy Act 1988 (Cth), and you may have limited ability to enforce Australian privacy rights directly against that recipient.

11.8. By creating a User Account and using the App, you consent to your personal information being disclosed to the overseas recipients described in this clause on that basis.

12. Direct marketing

12.1. We may send you information about Rostera and the App, including new features and offers, by email or push notification. We do so only where you have consented, which you may give when you create your User Account or at any later time.

12.2. We record your marketing preferences against your User Account.

12.3. Every marketing email we send contains a clear and functional unsubscribe link. Using it does not require you to log in, pay anything, or provide any additional personal information.

12.4. You can also unsubscribe by contacting us using the details in clause 20, or by changing your marketing preferences in the App.

12.5. We will action an unsubscribe request within five working days of receiving it, and in any event within the time required by the Spam Act 2003 (Cth).

12.6. Unsubscribing from marketing does not stop us sending you messages that are necessary to operate the App, such as a message about your Subscription, an expiring credential, a security notice, or a change to this policy or to our User Terms and Conditions.

12.7. Disabling push notifications in your device settings stops push notifications only. It does not unsubscribe you from marketing emails. To stop marketing emails you must use the unsubscribe link or change your marketing preferences in the App.

13. Data security

13.1. We take reasonable steps to protect the personal information we hold from misuse, interference, loss, and unauthorised access, modification or disclosure.

13.2. Those steps include:

• (a) encryption of information in transit and, where supported by our hosting provider, at rest;
• (b) access controls and authentication on your User Account;
• (c) limiting internal access to the minimum necessary;
• (d) logging and monitoring of access to our systems;
• (e) regular backups;
• (f) due diligence in selecting our service providers;
• (g) confidentiality obligations on anyone who works for us; and
• (h) a process for identifying and responding to vulnerabilities and incidents.

13.3. No method of electronic storage or transmission is completely secure. While we take reasonable steps to protect your personal information, we cannot guarantee its absolute security.

13.4. If we become aware of unauthorised access to, or unauthorised disclosure or loss of, personal information we hold, we will assess the incident promptly. Where an eligible data breach is likely to result in serious harm to you and remedial action has not prevented that risk, we will notify you and the Office of the Australian Information Commissioner as required under the Notifiable Data Breaches scheme.

13.5. Where we notify you, we will do so by email or by in-App notice.

13.6. Depending on the incident, we may also take remedial steps such as resetting credentials, requiring you to sign in again, disabling a Crew link or code, quarantining affected content, or temporarily suspending access to a feature.

14. Data retention and deletion

14.1. We retain personal information for as long as your User Account remains active, and as reasonably necessary to provide the App to you.

14.2. You may delete your User Account at any time using the account deletion function within the App.

14.3. If you delete your User Account, your account and User Content are immediately removed from the App and are no longer visible or accessible to you or to any other User.

14.4. We retain a copy for 30 days, so that an account deleted in error can be restored and so that we can respond to any dispute arising immediately before deletion. After 30 days that copy is deleted from our active systems.

14.5. You can ask us to delete that copy sooner by contacting us using the details in clause 20.

14.6. Backup copies are retained for a limited period and are overwritten on a rolling cycle. We do not restore deleted data from a backup other than to recover from a system failure.

14.7. We retain information beyond those periods only where we are required to retain it by law, or where we reasonably need it to resolve a dispute or enforce our agreements. Where we do, we retain only what is necessary for that purpose, and we delete or de-identify it once the purpose has passed.

14.8. Technical and usage information collected by our analytics and crash reporting tools is retained in accordance with the retention periods applied by the relevant provider, and is not linked to your User Account after deletion.

14.9. Our subscription management provider and the App Store retain records of your purchases under their own policies. We cannot delete those records. You should contact the relevant App Store about them.

14.10. Deleting your User Account removes your Shift Times from the Crew view in other members' accounts. It does not recall any copy, screenshot or record another member has already taken outside the App, and we cannot retrieve or delete anything held outside the App.

14.11. Deletion cannot be reversed after the 30 day period. You should keep your own copies of anything important to you, including any Uploaded Document, before you delete your User Account.

14.12. You can also ask us for a copy of your information before you delete your User Account. See clause 15.

14.13. Deleting your User Account does not cancel your Subscription. You must cancel your Subscription separately through your App Store account.

15. Access and correction

15.1. Most of the personal information we hold about you is visible to you, and able to be corrected by you, within the App.

15.2. You may also request access to, or correction of, the personal information we hold about you by emailing info@rostera.com.au with the subject line "Privacy request". Please tell us what information you are asking for and what you would like us to do.

15.3. We may need to verify your identity before we act on a request. We will usually do this by asking you to make the request from the email address registered to your User Account, or by asking you to confirm details already associated with your account. We will not ask you to provide identity documents unless it is necessary.

15.4. Where we give you access, we will do so in the form you ask for if it is reasonable and practicable to do so, which may include sending you a copy of your records.

15.5. We will respond to your request within a reasonable time, and we aim to do so within 30 days. We do not charge a fee for making a request. If giving access would involve significant time or expense, we may charge a reasonable amount to cover our costs, and we will tell you what it is before we incur it.

15.6. There may be circumstances in which we are permitted by law to refuse a request. If we refuse, we will tell you why in writing, and how you can complain.

16. Complaints

16.1. If you have a question or complaint about how we handle personal information, please contact us at info@rostera.com.au with the subject line "Privacy complaint". Privacy complaints are handled by our director.

16.2. We record each privacy complaint we receive, along with how it was resolved, and we review those records so that we can identify and fix any recurring problem.

16.3. We will acknowledge your complaint promptly, investigate it, and aim to respond within 30 days.

16.4. If you are not satisfied with our response, or if we have not responded within a reasonable time, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au, by telephone on 1300 363 992, or by post to GPO Box 5288, Sydney NSW 2001. The OAIC will generally expect you to have given us an opportunity to respond first.

17. Minimum age

17.1. You must be at least 18 years old to create a User Account or use the App, as set out in our User Terms and Conditions. The App is not intended for use by children, and we do not knowingly collect personal information from anyone under 18.

17.2. If we become aware that a person under 18 has created a User Account, we will suspend that account, contact the registered email address, and close and delete the account and the personal information collected through it unless we are satisfied the User meets the minimum age. We will delete any personal information already collected from that User within a reasonable time, except to the extent we are required to retain it by law.

17.3. If you believe a person under 18 has provided us with personal information, please contact us using the details in clause 20.

18. Personal information you provide to us about others

18.1. You should not record another person's information in the App. In particular, you should not record the name, contact details or any other identifying information of a patient, client, colleague, customer or any other individual in:

• (a) a shift label or roster entry;
• (b) a journal entry;
• (c) a logbook or credential record;
• (d) a question you ask the shift estimator feature;
• (e) a support request; or
• (f) an Uploaded Document.

18.2. If you do provide us with personal information about another individual, you must ensure that individual is aware of this policy and that you are otherwise entitled to provide us with their personal information.

18.3. If another person's personal information is recorded in the App, we hold it as personal information and handle it in accordance with this policy and the Privacy Act 1988 (Cth). Your failure to tell that person, or to obtain their consent, does not reduce our obligations. We may delete or quarantine information about another individual that should not have been recorded.

19. Changes to this policy

19.1. We may update this policy from time to time. Each updated version is published within the App and on our website with a new effective date.

19.2. Where a change is material, including a change to what we collect, how we use it, or who we disclose it to, we will notify you before it takes effect by in-App notice or by email to the address recorded on your User Account.

19.3. We will not apply a change retrospectively to personal information we have already collected in a way that is inconsistent with the Privacy Act 1988 (Cth).

19.4. Where a change requires your consent, including a change that would involve using your information for a new purpose or disclosing it to a new category of recipient, we will seek your consent before doing so.

20. Contact us

20.1. If you have any question about this policy or how we handle personal information, please contact us at info@rostera.com.au or through the App.

Effective date: 25 September 2026