Reset App
Privacy Policy

SLR Associates Pty Ltd (Trading as Sarah Rusbatch)
ABN: 23 628 140 241 | ACN: 628 140 241
Last Updated: June 2026

SLR Associates Pty Ltd (ACN 628 140 241) trading as Sarah Rusbatch (“we”, “us”, “our”) is committed to protecting your privacy. This Privacy Policy explains what personal information we collect through the Reset App, how we use it, who we share it with, and how we keep it safe.

By downloading, installing, or using the Reset App, you consent to the practices described in this Privacy Policy. This Privacy Policy complies with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Where you are located in the European Union or United Kingdom, we also meet the requirements of the General Data Protection Regulation (GDPR) and UK GDPR as set out in this Policy.


1.Who We Are

SLR Associates Pty Ltd (trading as Sarah Rusbatch) is the data controller responsible for personal information collected through the Reset App.

Registered Office: South Perth WA 6151, Australia
ABN: 23 628 140 241 | ACN: 628 140 241
Contact: app@sarahrusbatch.com
Data Protection contact (GDPR enquiries): app@sarahrusbatch.com


2. What Personal Information We Collect

2.1 Account Information

• Your name and email address when you register for an account;

• Password (stored in encrypted form); and

• Profile preferences and settings you configure within the App.


2.2 Health-Related and Sensitive Information

To personalise your experience and support your alcohol reduction journey, we may collect:

• Your current or recent alcohol consumption levels and patterns;

• Your goals and motivations related to reducing or eliminating alcohol;

• Mood, wellbeing, and lifestyle information you choose to log within the App; and

• Progress data including streaks, milestones, and journal entries.

This information constitutes sensitive information under the Privacy Act 1988 (Cth) and special category personal data under Article 9 of the GDPR. We collect it only with your explicit consent, obtained during account registration. You may withdraw consent at any time by contacting us at app@sarahrusbatch.com, although this may affect the App’s ability to personalise your experience.


2.3 In-App Activity

• Features and content you access within the App;

• Subscription and purchase history;

• Notification preferences and engagement; and

• Any content you create within the App, such as journal entries or reflections.


2.4 Device and Technical Information

• Device type, model, and operating system;

• App version and crash or error reports;

• Unique device identifiers; and

• General location data (country or region level only, not precise location).

2.5 Communications

  • Messages or enquiries you send us via in-app support or email; and

  • Feedback or survey responses you provide.


3. How We Collect Your Information

We collect personal information:

  • Directly from you when you create an account, set up your profile, log data, or contact us;

  • Automatically as you use the App, through analytics and error reporting tools; and

  • From third-party platforms where you connect an account (for example, if you sign in with Apple or Google).


    We use cookies and similar tracking technologies within the App to collect information about how you use the App and help us improve performance and personalise your experience. Where required by law (including under the EU ePrivacy Directive and UK PECR), we will seek your consent before deploying non-essential cookies or tracking technologies. You can manage your preferences within the App settings.


4. Why We Collect and Use Your Information

4.1 Delivering the App

  • Creating and managing your account;

  • Personalising your experience and content recommendations;

  • Tracking your progress and delivering insights relevant to your goals;

  • Processing subscription payments and managing your access; and

  • Providing in-app support and responding to your enquiries.

4.2 Improving the App

  • Analysing how the App is used to fix bugs and improve features;

  • Conducting research to develop new content and functionality; and

  • Monitoring App performance and stability.

4.3 Communications

  • Sending push notifications relevant to your progress (where you have enabled these);

  • Sending transactional emails such as receipts and account notifications; and

  • Sending marketing communications about new features or content where you have opted in.

    You can manage your notification and communication preferences within the App settings at any time.

4.4 Legal and Safety Obligations

• Meeting our obligations under Australian law;

• Responding to legal claims or regulatory enquiries; and

• Protecting the safety and security of the App and its users.


5. Legal Basis for Processing (GDPR and UK GDPR)

For users in the European Union or United Kingdom, the following table sets out the legal basis under which we process each category of your personal information:

Account information and App delivery Legal basis: Contract performance (Article 6(1)(b) GDPR). We need this information to provide you with the App and the features you have signed up for.

Health-related and alcohol consumption data Legal basis: Explicit consent (Article 6(1)(a) and Article 9(2)(a) GDPR). This is special category data. We collect it only with your explicit consent, which you may withdraw at any time.

Analytics and App improvement Legal basis: Legitimate interests (Article 6(1)(f) GDPR). We have a legitimate interest in understanding how the App is used so we can improve it. This processing does not override your privacy interests.

Marketing communications Legal basis: Consent (Article 6(1)(a) GDPR). You may withdraw consent at any time. Legal and safety obligations Legal basis: Legal obligation (Article 6(1)(c) GDPR) and legitimate interests (Article 6(1)(f) GDPR).

You may withdraw consent for any consent-based processing at any time by contacting us at app@sarahrusbatch.com or adjusting your preferences in the App settings. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

6. Sharing Your Information

We do not sell your personal information. We may share your information with:

6.1 App Service Providers

  • Cloud hosting and data storage providers;

  • App analytics and crash reporting tools;

  • Payment processors (e.g. Apple App Store, Google Play Store);

  • Push notification services; and

  • Customer support platforms.

All third-party providers are required to handle your information securely and only for the purposes we specify.

6.2 Professional Advisers

Lawyers, accountants, and insurers where necessary for the operation of our business.

6.3 Legal Requirements

Government bodies or law enforcement where we are legally required to disclose your information.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of our business, your information may be transferred to the acquiring entity subject to equivalent privacy protections.


7. International Data Transfers

Some of our third-party service providers may be based outside Australia.

The following table summarises the key international transfers we make and the safeguards in place:

Google LLC (Firebase / Crashlytics) — United States — Google’s Standard Contractual Clauses and Google’s adequacy commitments under its Data Processing Terms.

Apple Inc. (App Store payment processing) — United States — Apple’s standard data processing terms.

For all transfers of personal data from the European Economic Area (EEA) or United Kingdom, we ensure that either (a) the destination country has been granted an adequacy decision by the European Commission or UK Secretary of State, or (b) we have entered into Standard Contractual Clauses (SCCs) approved by the European Commission or the UK ICO, or (c) another appropriate safeguard under Article 46 GDPR or UK GDPR applies.

For Australian Privacy Act purposes, where we disclose personal information to overseas recipients, we take reasonable steps to ensure those recipients handle the information in a manner consistent with the Australian Privacy Principles (APP 8.1), or we rely on an applicable exception.


8. Data Security

We take reasonable technical and organisational measures to protect your personal information, including:

  • Encryption of data in transit and at rest;

  • Access controls limiting who can access personal data within our systems;

  • Use of reputable, security-certified third-party platforms; and

  • Regular review of our security practices.

No digital system is completely secure. While we strive to protect your information, we cannot guarantee absolute security. We have procedures in place to detect and respond to data breaches, and will notify you and the Office of the Australian Information Commissioner (OAIC) where required by law.

For EU and UK users, we will notify the relevant supervisory authority of a personal data breach within 72 hours of becoming aware of it, where required under Article 33 GDPR or UK GDPR, and will notify affected individuals where required under Article 34 GDPR or UK GDPR.


9. Data Retention

We retain your personal information for the following periods:

Account and profile information For as long as your account remains active, plus 12 months after account closure to allow for account reactivation.

Health-related and alcohol consumption data (including journal entries and progress logs) For as long as your account remains active. Upon account deletion, this data will be deleted within 30 days, except where retention is required by law.

Transaction and payment records 7 years from the date of the transaction, to comply with our tax and financial reporting obligations.

Communications and support records 3 years from the date of the last communication.

Analytics and technical data Up to 26 months (in accordance with Base44’s analytics data retention settings), unless you request earlier deletion.

When your information is no longer required for the purpose for which it was collected and no legal obligation requires its retention, we will securely delete or de-identify it.


10. Your Rights

You have the following rights in relation to your personal information:

  • Access: Request a copy of the information we hold about you;

  • Correction: Request that inaccurate or incomplete information be corrected;

  • Erasure: Request deletion of your personal information, subject to legal obligations;

  • Restriction: Request that we limit our processing in certain circumstances;

  • Portability: Request your data in a portable format (GDPR / UK GDPR users);

  • Objection: Object to processing based on legitimate interests; and

  • Withdraw consent: Where processing is based on consent, withdraw it at any time.

To exercise any of these rights, please contact us at app@sarahrusbatch.com. We will respond within 30 days. We may need to verify your identity before actioning your request. There is no charge for making a request unless it is unfounded, repetitive, or excessive.

You may also delete your account directly within the App settings, which will result in the deletion of your personal data subject to any legal retention obligations.


11. Children’s Privacy

The Reset App is intended for users aged 18 and over. We do not knowingly collect personal information from anyone under 18.

We implement an age verification step during account registration to confirm that users are 18 years of age or older. If we become aware that we have collected personal information from a user under 18 without appropriate consent, we will delete that information promptly.

For users in the European Union, we note that the GDPR sets the minimum age for consent to information society services at 16 years (or lower in certain member states). As our App is strictly 18+, this threshold is in any event exceeded.

If you believe we have collected information from a minor, please contact us immediately at app@sarahrusbatch.com so we can delete it.


12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, the updated Policy will be made available within the App with a revised Last Updated date. Where changes are material, we will notify you via the App or by email. Your continued use of the App after any changes constitutes your acceptance of the updated Policy.


13. Complaints

If you have a concern about how we handle your personal information, please contact us first at app@sarahrusbatch.com. If you are not satisfied with our response, you may lodge a complaint with:

  • The Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au | 1300 363 992

  • For EU residents: your local data protection supervisory authority. A list of EU supervisory authorities is available at: https://edpb.europa.eu/about-edpb/about- edpb/members_en

  • For UK residents: the Information Commissioner’s Office (ICO): www.ico.org.uk |0303 123 1113


14. Contact Us

If you have any questions about our use of AI, please contact:

SLR Associates Pty Ltd (Trading as Sarah Rusbatch)

ABN: 23 628 140 241 | ACN: 628 140 241

Email: app@sarahrusbatch.com

Website: www.sarahrusbatch.com