Privacy Policy

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include names, addresses, email addresses, and phone numbers.

This Personal Information is obtained through:

• Contact, enquiry and beta sign-up forms on our website (www.accesseachday.com)
• Email and telephone correspondence
• Our mailing list provider, if you accept storage on our website (see Section 6)
• Third-party platforms we use to run our business, such as email and form providers

Content created inside our apps, such as photos of clothing, is not collected by us at all. It stays on your device and in your own private iCloud. See Section 2.

We don’t guarantee the website links or policies of authorised third parties.

We collect your Personal Information for the primary purpose of providing our services to you, communicating with you, and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

Our iPad apps are designed so that we collect nothing from the people who use them. This section applies to Access Closet and to Access Closet: Go, our app for young children.

• The apps contain no analytics of any kind, first or third party. We cannot see how you use them.
• The apps contain no advertising and no advertising SDKs.
• The apps have no accounts and no sign-in, and they never send data to us or to any third party.
• Everything you create in the apps (photos of clothing, names, outfits, weekly plans and settings) is stored on your device and, if iCloud is turned on, in your own private iCloud database attached to your Apple ID.
• We have no ability to read, access or export that content. It is visible only to you.

The apps are built entirely with Apple’s own frameworks and include no third-party code. This matches the App Store privacy label for our apps: Data Not Collected.

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

• For the primary purpose for which it was obtained
• For a secondary purpose that is directly related to the primary purpose
• With your consent; or where required or authorised by law

To provide certain features, Access Closet and Access Closet: Go may request access to the following functions on your device:

• Camera: to allow you to take photographs of your clothing to add to your digital closet
• Photo Library: to allow you to choose existing images from your device

These permissions are optional. If you decline them, you can still use the rest of the app. You can manage or revoke permissions at any time through your device’s Settings.

We only access your camera or photo library when you actively choose to use those features. We do not access, store, or transmit any images without your action.

Both of our apps let you add photographs and images (for example, to your digital closet). By adding content to an app, you confirm that:

• You are the owner of, or have the legal right to use, any images or photographs you upload
• The content does not infringe the intellectual property rights, privacy rights, or any other rights of any third party
• Your content is stored only on your device and in your personal iCloud. It is not transmitted to Access Each Day.

Access Each Day is not responsible for any content added by users. You are solely responsible for ensuring that any photographs or images you add comply with applicable copyright laws, including the Copyright Act 1968 (Cth). Because content never reaches our servers, we cannot view or moderate it.

Our website (www.accesseachday.com) does not use analytics or advertising cookies. We do not run Google Analytics, we do not use an advertising pixel, and we do not track how you move around the site or across other sites.

The only storage we use on the website is:

• Mailing list provider (Kit): if you accept, Kit stores a single identifier on your device so its signup form can recognise returning subscribers.
• Your choice: we store your accept or decline decision on your device so we do not ask you again.

When you first visit, we ask before any of this is stored. If you decline, nothing from Kit is loaded and no identifier is created. You can still join our mailing list by emailing us instead. You can clear these at any time through your browser settings.

In the course of providing our services, your Personal Information may be disclosed to or stored by third-party service providers located overseas. Under APP 8 of the Privacy Act, we are required to take reasonable steps to ensure these recipients handle your information in accordance with the APPs.

The third-party services we use that may store or process data outside Australia include:

• Google Forms (Google LLC, USA): online forms and data collection
• Gmail (Google LLC, USA): email correspondence
• Kit, formerly ConvertKit (ConvertKit LLC, USA): email marketing and subscriber management
• Apple iCloud (Apple Inc., USA): app data storage on your personal iCloud account (see Section 8)

Each of these providers operates under privacy frameworks that provide protections comparable to Australian privacy law. We encourage you to review the privacy policies of these services for further information.

By using our website and apps, you consent to your Personal Information being disclosed to these overseas recipients in accordance with this Policy.

If iCloud is turned on for your device, Access Closet and Access Closet: Go store the content you create (photos of clothing, item names, outfits, weekly plans and settings) in a private database inside your own iCloud account. This is provided by Apple and is tied to your Apple ID, not to any account with us.

Your content may also be included in your device’s iCloud Backup, which is a separate Apple feature you control in Settings. In both cases the data sits in your personal iCloud, not on servers belonging to Access Each Day.

Access Each Day does not access, control, or store this iCloud data. It remains private to you and is governed by Apple’s Privacy Policy, which can be found at apple.com/legal/privacy.

Apple’s servers may be located outside Australia. This is a function of Apple’s infrastructure and is not within our control. We encourage you to review Apple’s privacy settings and policy to understand how your data is managed.

If you do not wish to use iCloud, you can turn off iCloud sync and iCloud Backup for either app in your device’s Settings. The apps continue to work with everything stored only on that device.

Access Closet: Go is made for young children to use together with a parent, guardian or support person. We take children’s privacy seriously and have designed our apps so there is nothing for us to collect:

• We do not collect any personal information from children (or from anyone) through our apps.
• Our apps contain no third-party analytics, no advertising, no accounts, no chat and no external links a child can follow.
• All content is created by the family and stays on the family's device and in their own private iCloud. We never receive it.

Our website is intended for adults. We do not knowingly collect Personal Information from children through the website. If we become aware that Personal Information has been collected from a child without appropriate parental consent, we will delete that information promptly.

If you believe a child has provided Personal Information to us, please contact us at support@accesseachday.com.

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

We may share your Personal Information with trusted third-party service providers who assist us in operating our website and apps and delivering our services. These parties are required to maintain the confidentiality of your information and are prohibited from using it for any other purpose.

Your Personal Information may be disclosed in a number of circumstances including the following:

• Third parties where you consent to the use or disclosure
• Service providers who assist us in operating our business (under confidentiality obligations)
• Overseas service providers as described in Section 7
• Where required or authorised by law

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

We are subject to the Notifiable Data Breaches (NDB) scheme under the Privacy Act 1988 (Cth). In the event of an eligible data breach — that is, a breach that is likely to result in serious harm to any individual whose information is involved — we will:

• Assess the breach as quickly as possible
• Notify the Office of the Australian Information Commissioner (OAIC)
• Notify affected individuals as soon as practicable

Notification will include a description of the breach, the type of information involved, and the steps we are taking in response. We will also take all reasonable steps to contain the breach and prevent further unauthorised access.

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

Access Each Day will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information we may require identification from you before releasing the requested information.

You may request deletion of your Personal Information at any time. Here is how deletion works across the different areas of our service:

• App data and content: remove individual photos in the app's Settings, or delete Access Closet or Access Closet: Go from your device to remove everything stored locally.
• iCloud data and backups: if iCloud is on, you can remove an app's stored data and backup via Settings > [Your Name] > iCloud > Manage Storage on your device.
• Email and marketing lists: to be removed from our mailing list, email us at support@accesseachday.com and we will remove your details promptly.

Please note that we may be required to retain certain information for legal or regulatory purposes (such as transaction records) even after you request deletion. We will inform you if this applies.

Access Each Day does not currently use automated decision-making processes or artificial intelligence to make decisions that would significantly affect your rights or interests.

If we introduce automated decision-making features in the future, we will update this Policy accordingly and, where required by law, notify you and provide you with an opportunity to request human review of any automated decision.

It is important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

This Policy may change from time to time and is available on our website at www.accesseachday.com. We encourage you to review this Policy periodically to stay informed about how we are protecting your information.

If you have any queries or complaints about our Privacy Policy please contact us at:

Access Each Day PTY LTD

ABN: 22 699 372 560

Email: support@accesseachday.com

Website: www.accesseachday.com

If you are not satisfied with our response to your complaint, you may contact the Office of the Australian Information Commissioner (OAIC):

Website: www.oaic.gov.au — Phone: 1300 363 992