Privacy Policy

About this policy

Cleo is operated by Cleo Digital, an Australian business based in Brisbane (“Cleo”, “we”, “us”). We make Cleo Hub, the companion app for outside school hours care (OSHC) services, the Cleo family portal, and vacation care programs. This policy explains how we handle personal information across all of them.

We handle personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. If you have a question, email programs@cleo.net.au.

Our role and your service's role

In Cleo Hub and the family portal, the OSHC service decides what information is recorded and why. We store and process that information on the service's behalf, to provide Cleo to them. Each service is responsible for having the right consents from the families and staff whose information it records, and for its own privacy policy.

If you're a parent, guardian or staff member and want to see, correct or remove information, please contact your service first. We'll help them respond. You can also contact us directly.

What we collect

• Children:name, preferred name, date of birth, gender, school, year level, whether photo permission is held, attendance and bookings, movements between areas during a session, and any notes, learning stories and photos the service records. We don't collect home addresses.
• Parents, guardians and other contacts:name, relationship to the child, phone, email, whether they can collect the child, and a login if they're invited to the family portal.
• Staff:name, email, phone, role, employment type, photo, an optional profile bio, rostered shifts, the areas and duties they're assigned during sessions, and their activity in Cleo Hub.
• Vacation care program customers: your name, role, email, service name and state, and your survey answers about your service, children and plans. Card details go directly to Stripe and never reach us.
• Website visitors:we don't use analytics or advertising tools. Our hosting and font providers see your IP address and browser details when you visit.

Sensitive information

We don't ask for health information. However, services can type free-text notes about a child, which may include things like allergies, and vacation care surveys can include inclusion needs. That can be sensitive information under the Privacy Act. Services should only record it with consent and where it's needed to care for the child, and we protect it the same way as all other information in Cleo.

How we collect it

• From your service, when staff enter it or import it from their booking system (such as Xplor) or rostering system (such as Deputy).
• From you directly, when you create an account, complete a vacation care survey or contact us.
• Automatically, through sign-in cookies and the device details used for PIN login.

How we use it

We use personal information to:

• run Cleo Hub for your service, including movement rolls, alerts, rosters and dashboards;
• give families access to the family portal;
• build and deliver vacation care programs;
• send account, service and order emails and push notifications;
• provide support, keep Cleo secure, and fix problems.

We don't sell personal information, use it for advertising, or share it for anyone else's marketing.

AI features

Some Cleo features use Anthropic's Claude AI, which is based in the United States:

• Vacation care programs: your survey answers are used to draft your program. Your name, role and email are removed first. Every program is reviewed by a person before it's delivered.
• Learning story polishing: if an educator chooses to polish a piece of text, that text is sent with the names of the service's children, families and staff swapped for placeholders, which are put back once the text returns to Cleo. Photos and the list of tagged children are not sent.
• Staff profile bios: if a staff member asks Cleo to write their bio, their answers to the bio questions are sent, without their name.

Booking and roster imports don't use AI. Under Anthropic's commercial terms, information sent through its API isn't used to train its models.

Who we share it with

We use the service providers below to run Cleo. They only receive what they need to do their job for us. We may also disclose information where the law requires it.

When a service connects Deputy, Cleo reads staff and shift details from Deputy. We don't send information back to Deputy.

Overseas disclosure

Cleo's database is in Sydney, but some of the providers above process information in the United States and other countries, as shown in the table. We choose established providers and take reasonable steps to make sure they handle information in a way that's consistent with the Australian Privacy Principles.

How we keep it secure

• Information is encrypted in transit, and stored in Australia.
• Each service's information is kept separate, and staff only see what their role allows.
• Families in the portal only see information about their own children, and photos of children are never shown in the portal.
• PINs are stored hashed, and services can set an automatic logout for shared devices.
• Integration credentials are encrypted.
• Cleo support can only access a service's account when the service switches it on. Access expires and is logged.

Cookies and local storage

We only use cookies needed to keep you signed in and secure. Your browser also stores a few display preferences, such as light or dark mode. We don't use tracking or advertising cookies.

How long we keep it

We keep a service's information while it uses Cleo, so it has a complete record of its sessions. Services can delete or archive records at any time.

When a service stops using Cleo, we'll delete or de-identify its information within 90 days of a written request, unless the law requires us to keep it. Program orders are kept as long as we need them to support your program and meet our record-keeping obligations.

Accessing and correcting your information

You can ask to see or correct the personal information we hold about you by emailing programs@cleo.net.au. We'll respond within 30 days, and there's no charge. If the information is held for an OSHC service, we may refer your request to them.

Data breaches

If a data breach is likely to cause serious harm, we'll notify the affected services and people, and the Office of the Australian Information Commissioner (OAIC), as required by the Notifiable Data Breaches scheme.

Children

Children don't use Cleo themselves. Information about children comes from their OSHC service, and families can see their own child's shared information through the family portal.

Complaints

If you have a concern about how we've handled personal information, email programs@cleo.net.au. We'll respond within 30 days. If you're not satisfied with our response, you can complain to the OAIC at oaic.gov.au or on 1300 363 992.

Changes to this policy

We'll update this policy when the way we handle information changes. The date at the top shows when it last changed.