Privacy Policy
This Privacy Policy explains how {{COMPANY_NAME}} ("we", "us") collects, uses, discloses and protects personal information in connection with our clinician‑led healthspan program, website and app (together, the "Services"). We comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
If you do not agree with this policy, please do not use the Services. Where applicable, more detailed information is provided in our informed consent materials within the app.
1. The information we collect
We may collect the following types of personal information as appropriate and lawful:
- Identity and contact details (e.g., name, title, date of birth, phone, email, address).
- Account and authentication information.
- Clinical intake information you provide (medical history, goals, risk factors, lifestyle).
- Referral, laboratory and imaging information handled through our coordination service.
- Genetic and microbiome testing details where applicable and consented.
- Payment and billing information (processed by our payment provider; we do not store full card data).
- Usage data (device/browser, pages viewed, interactions) and cookies/analytics.
- Communications (secure messages, notes related to concierge support).
2. How we collect information
- Directly from you via forms, intake, consent, messages and during telehealth consultations.
- From partner laboratories, imaging providers and specialists when coordinating your care, with your consent and as permitted by law.
- Automatically through cookies and similar technologies for performance and security.
3. Why we use your information
We use personal information to:
- Provide and improve the Services and our healthspan program.
- Assess suitability, issue referrals, coordinate testing and deliver results.
- Conduct mandatory telehealth consultations and provide personalised reports.
- Facilitate payments, bookings and customer support.
- Ensure security, prevent fraud and comply with legal obligations.
- Communicate important updates and, where you opt‑in, education and program information.
4. Legal basis and APPs
We handle personal information in accordance with the APPs, including APP 1 (open and transparent management), APP 3 (collection), APP 6 (use and disclosure), APP 11 (security) and APP 12/13 (access and correction). Where health information is involved, we collect and use it with your consent or as otherwise permitted by law.
5. Payment, analytics and service providers
We use trusted third parties to operate our Services. These may include: payment processors, cloud hosting, analytics, communications, customer support and security services. We only share what is necessary for them to perform their functions under appropriate safeguards.
Examples (subject to change): payment processor, email/SMS provider, analytics provider, cloud platform.
6. Disclosure to third parties and overseas recipients
We may disclose information to partner labs, imaging providers and specialists involved in your care, to our service providers, to professional advisors, or as required by law. Some recipients may be located outside Australia. Where we disclose overseas, we take reasonable steps to ensure recipients comply with privacy standards that are substantially similar to the APPs or obtain your consent.
7. Data retention
We retain personal information only for as long as necessary for the purposes described, to comply with legal obligations, resolve disputes and enforce agreements. Where applicable, we follow health record retention requirements.
8. Security
We implement administrative, technical and physical safeguards designed to protect personal information against loss, misuse, unauthorised access, modification or disclosure. No method of transmission or storage is completely secure; we continuously improve our controls.
9. Your rights: access and correction
You may request access to the personal information we hold about you and request corrections if it is inaccurate, out‑of‑date, incomplete, irrelevant or misleading. We will respond within a reasonable period and may require verification of identity.
10. Marketing and communications
We may send program information and education where permitted. You can opt out of non‑essential communications at any time using provided controls.
11. Cookies
We use cookies and similar technologies to operate the Services, remember preferences and measure performance. You can control cookies via browser settings; disabling some cookies may affect functionality.
12. Children
The Services are designed for adults. We do not knowingly collect information from children.
13. Complaints
If you have a privacy complaint, contact us using the details below. We will acknowledge and respond within a reasonable time. If you are not satisfied, you may contact the Office of the Australian Information Commissioner (OAIC) via oaic.gov.au.
14. Contact
{{COMPANY_NAME}}
Email: {{CONTACT_EMAIL}}
Postal: {{POSTAL_ADDRESS}}
15. Changes to this policy
We may update this policy to reflect changes to our practices or legal requirements. The updated version will be posted on this page with an updated date.