overedby Callixo Technologies
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Privacy Policy

Callixo Technologies Pty Ltd · ABN 85 696 368 153 · Last updated 24 August 2026

This policy describes what Covered actually does today. Covered is operated by Callixo Technologies Pty Ltd (ABN 85 696 368 153). It holds records about a childcare service, its educators and its compliance evidence. It does not hold records about individual children. Where a capability is not part of this release, this policy says that rather than describing it as something we already do.

1.What Covered holds, and what it does not

A childcare service enters these records; Covered does not collect them from anywhere else.

  • Educator and staff records: name, contact details, date of birth where a qualification or check rule depends on it, employment dates, qualifications, first aid and CPR currency, and working-with-children check details.
  • Compliance evidence: certificates and other documents uploaded by the service, the text read out of them, and the compliance status derived from them.
  • Operational records: rosters, room-level counts and ratios, observations recorded against a room, and the tasks and deadlines the service is tracking.
  • Account records: the users who can sign in, what they did, and when. Every change is written to the activity log.
  • Not held: records about an individual child. There is no child name, date of birth, medical or allergy detail, incident report about a child, or family contact detail in this release. Child-level features are not part of it and we set no date for them.
  • Also not held: tax file numbers, card payment details, and court or custody documents. Covered does not ask for them and has no field for them.

2.Australian Privacy Principles

Covered is bound by the 13 Australian Privacy Principles in the Privacy Act 1988 (Cth). The principles that carry a specific commitment on our side are set out below.

PrincipleWhat we do
APP 1
Open and transparent management
This policy is published at https://app.coveredapp.com.au/privacy and is available from inside the application. It describes what the platform does today, and says so plainly where something is not done today.
APP 2
Anonymity and pseudonymity
Covered cannot be used anonymously: an account belongs to a named person at a registered service. Text sent for AI analysis is not pseudonymised, and section 4 explains what protects it instead.
APP 3
Collection
We collect only what compliance management needs. Educator records are entered by the service, not gathered from third parties.
APP 5
Notification
Services using Covered are required to make this policy available to the educators whose records they enter.
APP 6
Use and disclosure
Data is used to run the service the organisation signed up for. It is never sold, and never shared for marketing. The only disclosures are to the providers in section 5, and to anyone the law compels us to tell.
APP 8
Cross-border disclosure
Customer records are stored in the Sydney region (ap-southeast-2), and document reading, personal-detail redaction and AI analysis run on Amazon Web Services in that region under Australia-geography model routing. Some things we run are operated from outside Australia, and none of them carries customer records: the operator dashboards and build logs of our web hosting provider, the support and operator plane of our database provider, our build pipeline, and the automated review of our own source code. None of them touches a customer database or a stored document.
APP 11
Security
Set out in full in section 3, including the parts of the design that are a second layer rather than the control we rely on.
APP 12
Access
You can ask for a copy of your personal information by writing to privacy@callixo.com.au. We answer within 30 days. There is no self-service portal for educators or families in this release, so a request comes to us or to the service that entered the record.
APP 13
Correction
A correction can be requested the same way. Where a record is corrected, the previous value stays in the activity log so the history of the record remains honest.

3.How the data is protected

  • In transit: TLS for every connection, from the browser to the application and from the application to each provider.
  • At rest: AES-256 platform encryption on the database, the document store and the cache. On top of that, Covered applies its own AES-256-GCM field encryption to educator phone and mobile numbers and to working-with-children check numbers.
  • Separation between services: reads and writes are scoped to the organisation making the request in the application layer, and a build check fails a query written without that scope. A small documented set of older queries is allowed through that check while it is closed out. Database row policies are declared on every tenant table as a second layer; they are not the control the platform currently relies on, and turning them into the enforced control is planned work.
  • Access control: role-based permissions inside each organisation, sessions that expire, and lockout after repeated failed sign-ins.
  • Activity log: changes to the records we audit are written to an append-only log, covering an enumerated set of tables at the database level and the rest through the application as the change is made. The product has no path that edits or deletes an entry, and each entry is hash-chained to the one before it, so an inserted, altered or removed entry breaks the chain and is detectable. Reads of sensitive fields are recorded separately. We do not claim to log every read of every field.
  • If something goes wrong: we hold a written breach-response plan, treat any exposure of personal information as a critical incident, and assess a suspected eligible data breach under the Notifiable Data Breaches scheme against an internal target of 7 days, and in every case inside the 30 days the scheme allows.

4.How Covered uses AI

  • Where the models run: on Amazon Bedrock in the Sydney region (ap-southeast-2), using Australia-geography inference profiles, which route only to Australian regions. Model inputs and outputs are not used to train any model, are not shared with the model provider, and the provider holds no key or account through which it could reach them.
  • Documents: a document you upload is read in Sydney: the text is read digitally where the file carries a text layer, and by Amazon Textract optical character recognition where it is a scan. The text then passes through Amazon Comprehend, which replaces personal details with placeholders, before any of it reaches a model. The file itself is never sent to a model, and the placeholders are resolved back to real values only inside our own systems.
  • Questions and summaries: text typed into the app, and the compliance summaries we generate, are sent to the model as written. They are not pseudonymised. What protects them is that a call reads only the data of the organisation that made it, which is enforced in the application layer and checked on every build.
  • What we keep: a record of every AI call, including which analysis ran, which model answered, and when. The stored output of an analysis is kept for the period shown in section 7.
  • What it is for: AI output is advice to a qualified human, never a compliance decision. The service remains responsible for its own obligations.

5.Providers who handle data for us

This is the complete list. A provider marked as not in use holds nothing: the integration exists in our code and is switched off, so there is no data flowing to it.

ProviderStatus and regionWhat they handle
Amazon Web Services
In use
Sydney (ap-southeast-2)
Hosting, the document store, document reading and personal-detail redaction, AI inference and text embedding, malware scanning of uploads, notification email, caching, and operational logs and metrics. All of it in the Sydney region.
Supabase
In use
Sydney (ap-southeast-2)
The PostgreSQL database and the sign-in service that authenticates users. Stored data stays in the Sydney region.
Vercel
In use
Sydney (syd1) for page rendering; global edge for public assets
Renders the web application. Pages that read service data render in Sydney. Public assets such as fonts and scripts are served from a global network and carry no records. Vercel operates its own dashboards and build logs from the United States.
PostHog (self-hosted by Callixo)
In use only where switched on
Sydney
Product analytics and session replay, self-hosted by Callixo in Sydney. It is off unless it has been switched on for a service. Where it is on, recordings stay on the Sydney instance, password fields are masked, and a browser Do Not Track signal is honoured.
Stripe
Not in use today
Not applicable while unused
Card payments. Covered charges nothing in this release, so there is no billing data to send.
Twilio
Not in use today
Not applicable while unused
Text-message delivery. Notifications go out by email only, so no phone number is sent for delivery.
NQAITS and ACECQA programmatic interfaces
Not available today, no date set
Not applicable while unavailable
A direct machine connection to the national registers. Covered has none. Regulatory details are entered and verified by the service, and we set no date for changing that.

6.Cookies, analytics and session recording

Covered sets a small number of cookies: two that keep you signed in, one that tells the application whether you are signed in, and, where product analytics have been switched on for a service, PostHog's own cookie. There are no advertising cookies and no third-party marketing or ad trackers anywhere in the product.

Product analytics and session replay are available through a PostHog instance that Callixo hosts itself in Sydney. They are off unless switched on for a service. Where they are on, a recording of what a signed-in user saw on screen may be captured, password fields are masked, the recording stays on the Sydney instance, and a browser Do Not Track signal is honoured. Nothing about analytics is shared with an advertising network.

7.How long data is kept

DataHow longNotes
Educator records7 years after the record is deleted in CoveredOur own retention choice, for employment and taxation record-keeping. Some records carry a shorter regulatory minimum; we keep them longer, not shorter.
Compliance records, including working-with-children check records7 years after the record is deleted in CoveredKept as the evidence trail a regulator or an assessor may ask us to produce.
Room observations and daily operational records7 years after the record is deleted in CoveredRoom-level records. They name educators and rooms, never a child.
Uploaded documentsKept until deleted; there is no automatic deletion of a document todayUploaded documents are retained. Deleting the record a document was filed against detaches the document from that record rather than deleting it, and nothing removes a stored document on a schedule today. Removal is carried out on request.
Rejected document uploadsQuarantined and queued for removal as soon as the upload is rejectedWhen an upload is rejected, the stored copies are quarantined and queued for removal across the upload, scanning and document stores. Where a copy cannot be removed automatically it is flagged to an administrator and stays until that is done.
Working copies made while reading a documentDeleted as the read finishes, and in any case within 1 dayReading a scanned document needs a short-lived copy inside our own Sydney storage. It is deleted when the read finishes, and a storage rule expires anything left behind.
Stored results of AI compliance analyses90 daysThe stored output of an analysis. The record that the analysis happened stays in the activity log after the output is gone.
Activity logKept permanently, and hash-chained so tampering is detectableAppend-only by design: the product has no path that edits or deletes an entry, and each entry is hash-chained to the one before it, so tampering with the log is detectable.
Records about an individual childNot collected, so nothing is held or retainedCovered holds no records about an individual child in this release, so there is nothing to retain. If per-child records are ever added, the retention schedule for them will be published before they are.

How the schedule is enforced, stated exactly. These windows are our policy. A weekly job identifies records that have passed their window and deletes them, without anyone having to ask. Uploaded documents are the exception described in the table above: they are retained rather than deleted on that schedule. Deleting a record in the application removes it from every screen and every report immediately.

The longest windows in the table are our own choice. The education and care regulations set shorter minimums for some of these records; we keep them longer for employment and taxation record-keeping reasons, and we would rather say that than claim a regulation requires it.

8.Your rights

If your personal information is held in Covered, you can:

  • Ask for a copy of the personal information we hold about you.
  • Ask for a correction where something is wrong.
  • Ask for your information to be deleted, as far as our retention obligations allow.
  • If you are an organisation owner, ask for an export of your organisation. It is produced from the application on request, as an archive of machine-readable JSON files, one per record type, with a manifest of what it contains. There is no download button for it in this release.
  • Complain to us, and to the Office of the Australian Information Commissioner if our answer does not satisfy you.

9.Changes to this policy

We may update this policy. The current version is always published at https://app.coveredapp.com.au/privacy with the date it was last updated, and the same version is available from inside the application. Where a change materially affects how we handle personal information, we will email the account owner of each organisation using Covered before it takes effect.

10.Contact

Privacy enquiries

For privacy enquiries, access requests, corrections or complaints, email privacy@callixo.com.au.

Callixo Technologies Pty Ltd · ABN 85 696 368 153 · Australia

If our answer does not satisfy you, you can complain to the Office of the Australian Information Commissioner at www.oaic.gov.au.

Callixo Technologies Pty Ltd · Covered
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