Privacy Policy

Last updated: 24/09/2026

TPP Projects Pty Ltd, ACN 652 696 190, ABN 88 652 696 190, trading as The Play Way (we, us, our) values the protection of your personal information.

This Privacy Policy explains what we collect, why we collect it, who we share it with, how long we keep it, and how you can see it, correct it or complain about it.

It covers:

• our website at theplayway.com

• The Play Way Hub at hub.theplayway.com, including Ask a Therapist and Ask Sunny

• our emails, forms and social media accounts

• the orders you place with us

1. Health information

Through Ask a Therapist, and through the profiles you create in the Hub, you tell us about your child's development, behaviour and health.

That is health information. Australian privacy law treats health information as sensitive information, and holds it to a higher standard than an email address.

We only collect it with your agreement. You give that agreement when you accept the Ask a Therapist Consent and Service Agreement, or when you choose to enter it into a Hub profile.

We handle it under the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

2. Children

The Hub is for adults. You must be 18 or over to hold an account.

We do collect information about children, because parents, carers, educators and clinicians tell us about the children they are supporting.

If you give us information about a child, you must be that child's parent or legal guardian, or have the permission of the person who is.

We do not knowingly collect personal information directly from anyone under 16 without the agreement of their parent, guardian or educational institution.

3. What we collect

When you use our website

• your name and email address when you fill in a form, subscribe or contact us

• what you look at on the site, through cookies and analytics

• your device, browser and general location, from your IP address

When you buy from us

• your name, email address, phone number and delivery address

• your order history

• confirmation that payment succeeded. We do not see or store your full card number. Payments are processed by our payment provider.

When you hold a Hub membership

• your name and email address

• your membership type and status

• the profiles you create, including a child's first name, age and anything else you choose to add

• what you view, favourite and complete

• messages you send our support team

The Hub does not use passwords. You sign in with a six digit code we email you.

When you use Ask a Therapist

• what you tell us on the intake form about you and your family

• the full text of every message you send and every reply we send

• photos, videos and voice recordings you attach

• dates, times, and whether you have opened our reply

• a record that you accepted the terms, including the exact wording shown to you, the version, and the date and time

Most of this is health information about you or your child.

When you use Ask Sunny

Ask Sunny is an AI helper inside the Hub. It helps you find things and points you at our resources. Sunny is not a person and is not a clinician.

Sunny runs on Claude, made by Anthropic, inside Amazon Web Services. What you type into Sunny is used to give you an answer. It is not stored and it is not used to train anything.

When a clinician, educator or service uses the Hub with clients

• their name, email address and role

• the client records they create, including the child's details

• goals, progress and outcome measures they record about a child

• what they assign and when

If you are a clinician, an educator or a service, you are responsible for getting consent from the parent or guardian before you enter a child's details. You remain responsible for that record under your own professional obligations.

What we do not ask for

We do not ask about your political or religious beliefs, your sexuality, your racial or ethnic origin, your trade union membership or your criminal record.

We do ask for health information, because that is what the service is for.

Your choice about giving us your information

Giving us your personal information is optional, but it may be necessary for us to provide you with our services. Where it is optional for you to give us non-essential personal information, we will make that clear to you at the time.

When you give us your personal information, you are consenting to our storage, use and disclosure of that information as set out in this Privacy Policy.

4. Why we collect it

We use your personal information to:

• give you access to the Hub and the content you have paid for

• answer your Ask a Therapist questions and suggest resources

• keep a record of the guidance we gave you

• process your orders and deliver your products

• send you service messages, for example that we have replied to you

• send you marketing, if you have agreed to it

• improve the Hub and understand how it is used

• meet our legal obligations

We do not use your Ask a Therapist messages, photos, videos or recordings for marketing, teaching, training or research. We would only do that with your separate written permission.

We do not sell your personal information. We do not rent it, licence it or trade it.

5. Who we share it with

We share personal information with the service providers we need to run the business. Each one gets only what it needs.

 

We also disclose personal information where the law requires or allows it, and where you have asked us to.

If we believe a child is at risk of harm, we may contact an appropriate service, including a child protection authority or the police. Where it is safe and appropriate to do so, we will tell you first.

6. Storage outside Australia

Some of the providers above may store or process information outside Australia.

Where that happens, we take reasonable steps to make sure the recipient handles your information in a way consistent with the Australian Privacy Principles.

7. Security

We store personal information electronically, and occasionally on paper.

In the Hub:

• you cannot see another member's conversations

• photos, video and audio are stored privately and can only be opened through a link that expires after a short time

• only authorised staff can open a conversation

• we check your access is current before you can use Ask a Therapist

No system is completely secure, and nothing sent over the internet is completely safe. We take reasonable steps but we cannot guarantee it.

If we have a data breach that is likely to cause you serious harm, we will tell you and the Office of the Australian Information Commissioner, as the Notifiable Data Breaches scheme requires.

8. How long we keep it

At the end of the period we destroy the information, or permanently remove anything that identifies you.

Separately, if we hold personal information about you and we no longer need it for any purpose for which it may be used or disclosed, we take reasonable steps to destroy it or de-identify it, unless the law prevents us from doing so.

Deleting an Ask a Therapist conversation hides it from you and from our staff straight away. It does not erase the messages or attachments at that moment.

If you want your information removed sooner than the periods above, email hello@theplayway.com and we will remove it. We will keep only what our record keeping obligations require.

9. Seeing and correcting your information

Contact our Privacy Officer for anything in this section:

Email hello@theplayway.com

Phone 1800 953 761

Post Privacy Officer, TPP Projects Pty Ltd, 19 Hume Street, Yarrawonga, Victoria 3730

We will respond within 30 days.

Keeping your information accurate

We take all steps that are reasonable in the circumstances to make sure that the information we collect from you is accurate, up to date and complete, and that the personal information we use or disclose is accurate, up to date, complete and relevant, having regard to the purpose of the use or disclosure.

Asking for a copy

In most cases you have the right to access the personal information we hold about you, including your Ask a Therapist conversations.

We will deal with your request as quickly as possible. A request for a large amount of information, or for information that is not currently in use, may take longer.

We will never charge you a fee for making a request. We may charge a reasonable fee where a cost is incurred by us in retrieving your information. Where a fee applies we will tell you how it is calculated, or the total amount where we can, and you can then decide whether to go ahead.

When we can refuse access

In some cases we will refuse to give you access. This includes, but is not limited to, where:

• refusing is required or authorised by Australian law or by a court or tribunal order, or giving access would be unlawful

• giving access would have an unreasonable impact on another person's privacy

• giving access would prejudice an investigation of unlawful activity, or enforcement activity conducted by or for an enforcement body

• giving access would reveal our intentions in negotiations with you and prejudice those negotiations

• giving access would reveal evaluative information generated in our business in connection with a commercially sensitive decision making process

• the information relates to existing or anticipated legal proceedings and would not be accessible through the discovery process in those proceedings

• the request is frivolous or vexatious

• we reasonably believe that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety

• we reasonably believe that unlawful activity, or misconduct of a serious nature, is being or may be engaged in against us, and giving access would be likely to prejudice appropriate action being taken

If we refuse, we will tell you why, unless it would be unreasonable to do so. We will take reasonable steps to give you access in a way that meets your needs without giving rise to the reason for our refusal. We will also tell you how to complain about our decision.

Asking us to correct something

If you believe the personal information we hold about you is inaccurate, out of date, incomplete or misleading, tell us and we will correct it.

If we refuse to change it, we will tell you why, unless it would be unreasonable to do so, and we will tell you how to complain. You can then ask us to attach a statement to the information saying that you consider it inaccurate, out of date, incomplete or misleading, and we will take reasonable steps to do that.

Where we correct information about you, you can ask us to take reasonable steps to notify anyone we have already given the incorrect information to.

These ways of accessing and correcting your personal information sit alongside, and do not replace, any other process by which you may be given access to or correction of your information.

10. Deleting your account

Email hello@theplayway.com and we will delete your account.

We remove what we can, including your Ask a Therapist conversations and the photos, video and audio you sent. We must keep order records for the period in section 8.

11. Marketing

If you have agreed to marketing emails, you can stop them at any time using the unsubscribe link, or by emailing hello@theplayway.com.

Service messages are different. While you hold a membership we will still email you about your account, your orders and replies to your questions.

12. Cookies

See our Cookies Policy.

13. If you are outside Australia

The Play Way is an Australian business. This policy is written to Australian law, and our services are intended for people in Australia.

If you live in the United Kingdom or the European Union and want to know how we handle your information, or you want to exercise a right under the General Data Protection Regulation, email hello@theplayway.com and we will help you.

14. Complaints

If you are unhappy with how we have handled your personal information, tell us first. Put it in writing to our Privacy Officer at hello@theplayway.com. We will respond within 30 days.

If you are not happy with our response, you can complain to the Office of the Australian Information Commissioner, oaic.gov.au, 1300 363 992.

15. Changes to this policy

We are obliged to review and update this policy regularly, and we reserve the right to amend it at any time.

If we make a significant change we will publish the new version on our website 14 days before it takes effect, unless the circumstances make that notice period unreasonable. If you keep using our services after that period, you accept the amended policy.

If a change affects Ask a Therapist, we will ask you to accept the new terms before you send another message.

16. Contact us

Privacy Officer, TPP Projects Pty Ltd

hello@theplayway.com

1800 953 761

19 Hume Street, Yarrawonga, Victoria 3730