My Genius Global Privacy Policy

Initial Effective Date: June 30, 2025(AEST)
Latest Revised Date: October 23, 2025 (AEDT)
Version: 1.0.2

Our global privacy policy ("Privacy Policy") explains what My Genius (“we”, “our”, “us” or “My Genius”) does with your provided information when you use our website or web pages (mygenius.com.au), web-based or mobile-based software (“My Genius app” or “app”) and its services. You may try out one or more services made available to you. These include:

The aim of the app is to provide support in the form of a multidimensional survey tool and the provision of a range of digital self-help tools. The app can help with general parenting and caring strategies but not with severe or enduring physical or mental health conditions. The AI Coach is an AI technology powered software, not a real person, so it is restricted in the means of response. If you need medical advice, it will suggest that you see a local professional.

We will work with your public institution, healthcare institution, educational institution or other organization to offer our services. These are called Institutional services. Before you can use these Institutional services, you will need to agree to our notices and to the notices of your Institution.

By using our website, web pages, app and services, you agree that we can use your information as described in this privacy policy and any other related terms and policies ("notices").

  1. About My Genius and Our Contact Details :

KWCMA Holdings Pty. Ltd. ATF Kecaasre Family Trust (“My Genius”) are the makers of the My Genius app and its services. The app and services are available in native English. 

Where My Genius decides the purpose of personal data processing, we will be the “data controller or data fiduciary or equivalent”. Where we perform personal data processing at the direction of your Institution, we will be “data processors”.

If you have any questions, comments, complaints, or requests about our app and services, you can email us at theteam@mygenius.com.au.

  1. What Information We Collect and Use

Depending on how you interact with us, we may collect minimal personal data that you're suggesting identify you. Notably personal data does not include publicly available information from or anonymised or aggregated information.

When you use our app and services.

When you use the app and services, we collect the following information. You control the information you share with us. We design our app to collect as little personal data as possible to keep your data safe and protect your privacy. This means there is less risk of your information being misused. When you share information with us, we are responsible for taking care of it.

Information provided by you.

Information collected via automated means or by third parties.

When you use the AI Coach over WhatsApp.

Where, you directly use the AI Coach on WhatsApp, the service does not give medical advice and always suggests seeing a doctor if needed. My Genius will not use your WhatsApp messages to send you marketing material. We do collect and use the additional information to provide you with our service.

Where your Institution provides access to the AI Coach on WhatsApp, they do not give us any of your personal information. They only share a unique identifier to help us connect with your Institution systems and offer our AI Coach service to you. This unique identifier cannot be used to identify you.

When you participate in a My Genius research study.

You can choose to sign up and join any of our or our research partner run studies. When you volunteer, we will collect some information from you. These include:

When you visit our website or social media accounts or our web pages.

When you visit our website or web pages or just reach out to us for business purposes, we will collect the following information from you.

You can follow us on Instagram through the My Genius app settings. If you do not have an Instagram account, you can create one and follow us at @My Genius_buddy. Your Instagram account will not be linked to your My Genius app account. We will know your personal information when you interact with us on our social media channels.

When you use our Digital Survey or FAST Tool services

When you use the Digital Survey or FAST Tool services, we will need to collect some information to complete the survey. 

You can fill out the information required at your own pace. We will obtain your personal data directly from the Institution (such as member id, plan details, demographic information). We will also receive personal details (such as name, date of birth. contact details), answers to health related questions, and any long-term health issues or disabilities. Your Institution decides if you qualify for these services, not us.

We do not decide who is accepted by the institution, nor the type or step of care provided. The Digital Survey or FAST Tool only collects the required information and passes it to your Institution and/or their authorised service providers.

When you text your institution clinician or well-being advisor within co-pilot service

Your Institution Clinician or Well-being advisor may add some information about you to identify you on the platform and provide the relevant service. This may include, but not limited to, your title, gender, primary language, and timezone. My Genius will only share the required personal data with your Institution and their clinician or well-being advisor. This to help them review your progress during the service.

Provision of personalised recommendations of supportive resources and tools

To support your mental health and wellbeing in relation to parenting or caring for a client, we use Artificial Intelligence technology to derive key insights from your conversation data and recommend appropriate self-help resources and tools. These insights and recommendation information is never shared with third parties for marketing or commercial purposes. If you wish to delete your conversation data including the derived recommendations, you can do so by choosing the “Reset my data” from the app setting. On reset my data, all your conversation data will be permanently deleted from our system and cannot be retrieved. Please note that provisioning of personalised recommendation is core to providing our services. Opting out of this feature may limit your access to our app functionality and services. If you have any questions about this processing, please write to us at theteam@mygenius.com.au.

When you participate in our campaigns or promotions or marketing events.

Any promotions, campaigns, or surveys you participate in will not be connected to your app account. Instead, this information will be stored securely in our Google Workspace or marketing tool accounts. We may collect and process the following information as part of these promotions.

We may put ads online to see how many people are interested in our service or to promote it. We use only trusted ad managers. We do not collect any personal information when you see or click on our ads.

When you apply for a role at My Genius

We may process personal information you may provide us when you apply for an open position or attend our hiring interviews.

Sources of personal data

We get your personal data either from you or your Institution, or service providers your Institution asks us to work with.

  1. How We Use Your Information

Legal grounds

We need to follow data protection laws that make sure we look after your personal data properly. Here is how and why we might use it:

  1. Consent: Sometimes, we ask you if it is okay to use your personal data. You can always change your mind later if you decide you do not want us to use it anymore by writing to us
  2. Contract Performance: When you use our app or services, we might need some of your personal data to provide our services and make sure everything works properly.
  3. Legitimate Interests: We or someone we trust, might use your personal data to keep our services safe from fraud or security problems. We might also use it to make our services better.
  4. Legal Obligation: Sometimes, we need to use your personal data to follow the law or to protect our company and the people who provide the services.

Sometimes, we need to use sensitive data that you share, like how you feel, your mood, or other things about your emotional health. We will only do this if we follow the law and have a good reason, such as:

  1. Reasons for substantial public interest: Helping you with advice or support like counselling, or keeping you safe while you use our app and services.
  2. Health Care: Acting on behalf of your Institution to provide healthcare and redirect you to care resources.

Uses of your Information

We might use the information you give us on our app and services for these reasons.

  1. Information about you
  2. Use of Conversation data
  3. Use of Correspondence data
  4. Use of Feedbacks
  5. Regarding Information sharing with your Institution
  6. Use of app event and device data
  7. Use of Cookie Information
    We need to use some necessary cookies to make sure our website and app works properly. Here is a simple guide to the kinds of cookies we might use:
  8. "Do Not Track" (DNT) is something you can turn on in your web browser to keep your online activities more private. However, even if you turn DNT on, we do not collect those signals today.
    Legal basis: legitimate interests.

Additional processing for AI Coach over WhatsApp.

  1. To process your provided Information. We do the following
  2. Legal basis: For each purpose listed above we will rely on one among the following, contract performance and legitimate interests.
    Note: Your messages on WhatsApp Business are always end-to-end encrypted. According to WhatsApp's Privacy Policy, your messages are usually stored on your device(s) and not on WhatsApp's global servers. WhatsApp will keep your messages in encrypted form temporarily while they are being delivered. Once delivered, your messages are deleted from WhatsApp's global servers. You can protect your information on WhatsApp by using its privacy and security features. Find out more about WhatsApp’s end-to-end encryption and how it keeps business messages safe. WhatsApp allows you to send attachments or voice messages, but we do not need them to provide our service. Please avoid sharing such information with us.

Additional processing when you use the Digital Survey and FAST Tool service

  1. For processing your eligibility and clinical assessment data
    1. To process your provided data: We do the following with your information:
      1. We gather, move and store the information you submit.
      2. We delete your personal data when we no longer need it, as agreed with your Institution.
      3. The app provides you with safety resources and guides you on how to use them.
    2. Legal basis: as defined by your Institution for public health, legitimate interests. Use of appropriate additional conditions for any special category personal data specified by your Institution.
    3. To transfer data to your Institution: We do the following with your information:
      1. We connect securely with your Institution clinical management system (EPR/EHR).
      2. We receive your personal information for sharing with Institution authorised service providers for care purposes.
      3. We share your eligibility and clinical assessment information with your Institution.
      4. We retain and delete your information as agreed with your Institution.
    4. Legal basis: as defined by your Institution for public health, legitimate interests. Use of appropriate additional conditions for any special category personal data specified by your Institution.
    5. To transfer data to your Institution authorized service providers: We do the following with your information:
      1. Provide you access to your Institution provided therapy or care services.
      2. We connect securely with the service provider’s clinical management system.
      3. We transfer your Institution provided data along with data provided by you with the service providers for care purposes.
      4. We share your clinical assessment information with the service providers.
      5. We retain and delete your information as agreed with your Institution.
    6. Legal basis: as defined by your Institution for public health, legitimate interests. Use of appropriate additional conditions for any special category personal data specified by your Institution.

Additional processing when you text your institution clinician or well-being advisor as part of co-pilot service

  1. For processing your data when you communicate with your Institution clinicians or well-being advisors
    1. To process your provided data: We do the following
      1. Provide access to use the resources provided by your assigned clinician or well-being advisor.
      2. Allow your Institution assigned clinicians or well-being advisor to review your AI Coach progress and support you in your care.
      3. Where provided access, to allow clinicians or well-being advisors to review your AI Coach conversation data, and assessment evaluations.
      4. Assist you with appropriate support resources and guidance.
    2. Legal basis: For each purpose listed above we will rely on one among the following, contract performance, legitimate interests.

Additional processing during participation in research studies.

  1. To process the information shared by you during participation. We do the following
    1. Inform about the study purposes.
    2. Understand your eligibility for the study.
    3. Manage your joining process.
    4. Send study related information and reminders.
    5. Contact you during the study for research purposes and respond to requests.
    6. Seek your feedback and clarify any questions.
    7. Perform analysis using the information provided.
  2. Legal basis: your consent and legitimate interests.
    Note: You can stop participating in the research at any time after it starts. You can do this by changing the settings in the app or sending an email to theteam@mygenius.com.au with the subject "opt out of My Genius Study". Once you opt out, we will delete your enrollment data within one year. However, the data you provided while using the app will be kept according to our data retention policy, which you can read about here. Your study data will always be kept safe. You can learn more about how we protect your data here.

Additional processing when you visit our website or social media accounts or our web pages.

  1. To process your correspondence data: We do the following
    1. We collect, store, and use business data when you contact us.
    2. We respond and provide support for your questions.
    3. We talk to customers to find new leads, help our business grow, manage accounts, or for marketing purposes.
    4. Monitor, enforce and comply with unsolicited communication laws prior to any marketing and business development reach outs.
  2. Legal basis: your consent and legitimate interests.
  3. To process cookie information during your visit. To find out how we manage cookie data, please look at Use of Cookie Information section.

Additional processing during online group well-being sessions.

  1. To process your provided information: We do the following
    1. We collect, store and use your information to enroll and connect you to the well-being sessions.
    2. Contact you regarding the session and future sessions.
    3. Send session related materials and resources.
  2. Legal basis: For each purpose listed above we will rely on one among the following, your consent, legitimate interests and as defined by your Institution.

Additional processing during campaigns or promotions or marketing events.

  1. To process the promotion event data: We do the following
    1. Sign you up and get you started on the promotion or campaign.
    2. Contact you about campaigns and promotions.
    3. Send you information about promotions, newsletters, webinar invites, and reminders.
    4. Make sure we follow the rules about not sending unwanted messages before we contact you for marketing or business reasons.
  2. Legal basis: For each purpose listed above we will rely on one among the following, your consent, legitimate interests and as defined by your Institution.

Note: If you want to leave the promotion or campaign, you can email us at theteam@mygenius.com.au. We will reply within 3 business days. Your information will stay private.

We use Meta Ads Manager to make ads about our service, to send these ads, and to see how well they are doing. We also group users together for anonymous cohort analysis. We use Google Analytics to see how much people use this service, but no personal data is collected or shared with them.

Additional processing when you apply for a role at My Genius

  1. To process recruitment data: We do the following
    1. Gather, save, and organize recruitment data from external recruitment sources.
    2. Review your application.
    3. Make a job offer.
    4. Sign a work contract with you.
    5. Run background and reference checks.
    6. Inform you of your application status.
    7. Consider you for other job opportunities.
    8. Make our hiring process better.
  2. Legal basis: your consent and legitimate interest.

We do not share or sell your information, messages, or how you use our apps to advertisers or companies that buy data.

Processing for Legitimate Interests

We may need to use your personal information for important reasons. Before doing this, we will always protect your rights and privacy. Here are the reasons we might use your data:

  1. To follow our agreements with your school or Institution.
  2. If the law requires us to use or share it.
  3. For court cases or legal orders.
  4. For law enforcement or national security needs.
  5. To help investigate or stop illegal activities.
  6. To freeze data for legal reasons so that it cannot be changed or deleted.
  7. To report public health information.
  8. To prevent serious risks to health or safety.
  9. To do basic research and understand how people use our services.
  10. To communicate with you about using our app and services.
  11. To fix and protect the app’s security and operations.
  12. To stop fraud or misuse of our service.
  13. To keep your data secure and private.
  14. To make sure the app and services work well and are easy to use.
  15. To protect your fundamental rights, and safety.
  16. To use anonymous data for benchmarking and marketing.
  17. To create new services, technologies, and products.
  18. To answer your questions and requests.
  1. How We Protect Your Information

Where is your information stored
The information we collect is saved and kept safe in our cloud servers managed by Amazon Web Services (AWS). Some of your information might be shared and stored with our third-party service providers to provide our services. For a list of service providers please read here.

How long do we keep your information

When you use our app and Services including Institutional Services

When you send us text messages, any personal identifier you share is removed and saved in a way that cannot be undone. We keep this information only for as long as we need to follow the law or our Institutional contracts. If there is no specific time limit mentioned, we keep your information for up to 10 years from the last time you updated it. You can also choose to delete all your conversation data forever by using the 'reset my data' option in the app settings.

Your correspondence data

When you email us, we use the information you give to help you. We keep your emails safe in our Google Workspace account, and only certain staff can look at them. We will keep your email for up to 10 years from the last time you contacted us.

When you use our Digital Survey 

We keep your information for the time of operation of the App or until you have deleted your account. After the agreed time, we delete your information forever from our systems. Once you submit the form and your information, we cannot change it. If you need to add or edit your personal data you will need to reach out to your Institution.

Provision of personalised recommendations

We irreversibly remove any accidental personal identifiers from your conversation data prior to processing. All insights and recommendations are pseudonymised and encrypted in our system.

Information received from your Institution

We keep your information for the time your Institution has decided. After that time, we delete your information forever. Once you send us your information, we cannot change it. If you need to fix something or have any questions, please talk to your Institution.

When you join our research initiatives

You can stop participating in the research at any time after it starts. You can do this by using any of the suggested opt-out features or by sending an email to theteam@mygenius.com.au with the subject "opt out of research study". Once you opt out, we will delete your study data within one year. However, the data you provided during research study will be kept according to our data retention policy. We will keep this information only for as long as we need. If there is no specific time limit mentioned, we keep your information for up to 10 years from the last time you updated it. After that, we delete your data from our system. Where required, we may retain one copy of your anonymised data for a longer duration for any future audit or verification purposes.

Data Security

We use physical, organizational, and technical safeguards to keep your information safe. Here are some ways we do that:

Protecting your privacy

  1. You do not need to register to use the app.
  2. Just give us a nickname so our chatbot knows what to call you.
  3. We use masked identifiers to keep your data and identity safe.
  4. No real people can listen to what you are talking about with the AI Coach.
  5. If you accidentally share personal data, we will make sure to remove it so no one can see it.
  6. As an app user, you can choose "reset my data" to delete your information.
  7. Before we use any personal data about you, we make sure it respects your rights.

Protecting your security

  1. We use strong encryption to protect your data when it is being sent or stored.
  2. Only authorised people can access your data. They have to use strong passwords and an additional access code.
  3. All our staff computers have extra security.
  4. We maintain contracts with companies we work with to keep your data safe.
  5. We carefully check the background of new staff before hiring them.
  6. We train our staff on how to handle your information securely.
  7. We have experts from outside our company check if we are following the rules every year.
  8. We regularly test our app and systems for any weaknesses.
  9. We fix any problems in our computer code to make sure it is safe.
  10. We often check to make sure we are following our safety plans and rules.

Responsible use of Artificial Intelligence

At My Genius, we use artificial intelligence (AI) programs to understand what you type to us. These programs help us talk with you in a way that makes sense and guides you to helpful information. Our programs follow set rules and do not learn new things on their own. We make sure our AI chatbot is fair, safe, and treats your information with care. If you use the Gen AI or My Genius+ service, we use Generative AI technology to assist you. We have safety measures in place to keep our conversations secure and trustworthy. We also have good practices to monitor and check the use of AI at My Genius, making sure your rights are protected. Please contact us at theteam@mygenius.com.au if you have any more questions about our use of AI.

While My Genius has put in place reasonable clinical safety and data protection controls, you understand and acknowledge that AI is a developing technology. The potential risks inherent to this technology may not be fully understood and fulsome safeguards may not be fully developed. Due to the nature of the technology, you may sometimes get incorrect responses that do not accurately reflect the action required.

We do our best to keep your personal data safe, but no method is perfect. We cannot promise complete security. You can help keep your data safe too. Please do not share personal identifiers where not asked. Please do not copy and share your chats with people you do not know.

Payment Data

We do not collect, keep, or store your credit card information. Third-party payment companies handle your card processing. We do not get any personal data from app stores after you buy something or from our third-party payment providers. However, we might note the name of the business for our internal purposes. Please read the payment gateway’s terms and privacy policy before you make a payment. We do receive and handle payment confirmations and subscription details. This is to help you with your subscription requests.

Third-Party Sites

The app might have links to other websites or resources. When you click on these links, remember that these other sites have their own rules about privacy. We do not control these other sites and we are not responsible for their privacy rules. It is a good idea to read their privacy rules before you share any personal data on those sites.