Privacy Policy

Supersedes Version 2.1 (1 September 2026), which superseded Version 2.0 (5 August 2026) and Version 1.0 (3 June 2026)

What changed in Version 2.2: the Nureo app now tells Meta (Facebook and Instagram) when it is installed, when an account is created, when a free trial starts and when a subscription is bought, so we can measure our advertising. New clause 10.5 says exactly what Meta receives and what it never receives. Clauses 3.9, 5, 10.1, 11 and 17 are updated to match. RevenueCat, our in-app subscription processor since 14 September 2026, is now listed in clauses 10.1 and 11.

Nureo Pty Ltd | ABN 84 696 935 154 | 25 South Street, West Wodonga VIC 3690

1. Introduction

Nureo Pty Ltd ('Nureo', 'we', 'us', 'our') operates the Nureo health and nutrition platform. This Privacy Policy explains how we collect, hold, use and disclose your personal information — including your health information — when you use the Nureo mobile application, our website, and the practitioner and clinic workspace (together, the 'Platform').

This Policy is prepared in accordance with the Privacy Act 1988 (Cth) ('Privacy Act') and the Australian Privacy Principles ('APPs') in Schedule 1 of that Act. Because we provide a service that involves health information, we are bound by the Privacy Act regardless of our turnover, and the additional protections that apply to sensitive information apply to much of what we hold about you.

A note on how we have written this. Nureo's product is built on a principle: an assumption should never be presented as an observation, and where the app has guessed, it says so. We have tried to write this Policy the same way. Where we do something you would not expect, we have said it plainly rather than covering it with a general phrase.

This Policy should be read with our Terms of Service. If there is any inconsistency on a privacy matter, this Policy prevails.

1.1 Consent

Where we rely on your consent, we ask for it specifically and at the time it is relevant, not by bundling it into your acceptance of these documents. In particular, we ask separately for your consent to:

• collect and use your health information;
• send the contents of your photographs and your health context to our artificial intelligence provider;
• share information with a practitioner you engage; and
• read data from Apple Health or Health Connect.

You can withdraw any of these consents at any time in the Platform's privacy settings or by contacting us. Withdrawing a consent will limit the features that depend on it. It does not affect anything we lawfully did before you withdrew it.

2. Who We Are and How to Reach Us

Nureo Pty Ltd (ABN 84 696 935 154) is an Australian company based in Victoria.

We aim to respond to privacy enquiries within 5 business days.

3. What Personal Information We Collect

3.1 Account and identity information

• Name and preferred name
• Email address
• Date of birth and age
• Password (stored only as a one-way cryptographic hash — we never hold your plain-text password)
• Profile photograph, if you provide one
• Subscription tier and billing records
• Where you sign in with Apple or Google, the name and email address that service gives us

3.2 Health and wellbeing information you enter

• Daily check-ins: sleep duration and quality, hydration, movement, energy and mood
• Health focus area and your active and historical goals, milestones and progress
• Body measurements and weight, where you record them
• Progress photographs, where you upload them
• Reflections and notes you write

3.3 Food, scanning and nutrition information

This is the largest category of information we hold and the one most specific to Nureo. It includes:

• Meal logs — what you record eating, when, and the nutritional estimate attached to it.
• Photographs of food and of plates, taken through the scanner or selected from your library.
• Photographs of product labels (front-of-pack, ingredient panels and nutrition panels) where a product is not in our catalogue and you choose to photograph it.
• Photographs of shopping receipts, where you use Trolley Scan. A receipt may show the retailer, the date and time, the store location, the items purchased, the amounts paid, a loyalty or rewards number, and the last four digits of a payment card. To read the docket we send the photograph to our artificial intelligence provider (clause 7), which returns the item lines as text. We do not keep the receipt photograph. What we store against your account is the extracted result — the item lines, the store, the date, the total and the grade we calculated — and not the image it came from.
• Scan history — a record of every product you scan, including its identity, its score and the time of the scan. This includes products you scan in a shop and do not buy. We hold this because it lets the app offer to add products to your pantry once you have scanned them a few times, and because scan patterns are one of the signals Nuri uses when it looks for correlations. A scan history describes what you considered, not only what you ate, and we treat it as health information accordingly.
• Your pantry — the products you have confirmed you usually keep. Your pantry has no quantities and no expiry dates; it does not change when you eat something.
• Allergies, intolerances, dietary preferences and eating style — for example that you react to wheat, or that you eat gluten-free by preference. These are health information.
• Symptoms you log — what you felt, how bad it was on a five-point scale, when it started and stopped, and any note you attach. This is the most sensitive information we hold about you, and 3.5 sets out separately what we do and do not do with it.
• Health conditions you tell us about, and any practitioner protocol you are following, where you choose to record them. These are used to personalise your scores and warnings.
• Supplements and medicines you record in your supplement stack, so the app can check a scanned supplement against them for allergens and interactions.
• Weighed corrections — where you tell the app what a meal actually weighed. These build your personal accuracy record and, after enough of them, adjust future estimates.
• Your measured crockery — where you calibrate your plate or bowl (see 3.4).
• Depth measurements — on devices with a depth sensor, the app measures the volume of food standing above the plate at the moment you take a photo, and passes that measurement to the estimate.

3.5 Symptoms you log

You can record how you feel — a symptom, how bad it was, when it started, and when it stopped. This is health information, and under the Privacy Act it is sensitive information, which is the most protected category the Act recognises. We ask for your consent before you log the first one, and you can withdraw that consent and delete the whole record at any time.

What the app does with it is narrow, and worth stating plainly because symptom trackers often do more. Nureo records what you tell it and shows it back to you: on the day it happened, alongside what you had already logged that day, and as a pattern over the last thirty days. It counts. It does not assess.

Specifically, Nureo does not tell you what a symptom means, does not suggest a cause, does not name or rank possible conditions, and does not recommend a treatment or a change to your medication. Where the app shows you that two things you logged tend to occur near each other, that is arithmetic on your own entries and nothing more — it is not a finding about your health, and we say so wherever it appears. Nuri will not diagnose a symptom either, and will refer you to a practitioner if you ask it to.

Some entries cause the app to show you a message asking you to contact a doctor or, where relevant, an emergency or crisis line. That message is a referral and not an assessment: the app is not judging your symptom, it is declining to be the thing you rely on. It does not contact anyone on your behalf, and Nureo is not an emergency service.

Your symptom record is yours alone. It is not visible to practitioners, not shared into circles or with friends, not used for marketing, and not sold. No one else can read it unless you choose to share it, which is a deliberate act that sends a copy of the period you selected and can be revoked. Deleting your account deletes the record.

3.4 The plate calibration photograph

If you choose to calibrate your crockery, the app asks you to photograph a plate or bowl with a bank card beside it, because payment cards are a fixed size worldwide and give the image a scale.

Be aware that the photograph you take does leave your device. It is sent to our artificial intelligence provider (clause 7), which measures the plate or bowl against the card and returns a single number — the diameter of your crockery, in centimetres. So the card is in an image that reaches that provider, and we are telling you so rather than describing this as an on-device measurement.

We do not read anything off the card except its outline. The provider is asked for one thing, and the reply it can give us has only four fields in it: whether a card was visible, the plate width, the bowl width, and a confidence score. There is no field in which a card number, name or expiry could reach us, and none is extracted or retained.

We keep the measurement. We do not keep the photograph. Calibrating is optional, and Nureo works without it — but if you do calibrate, it has to be a bank card: the measurement is taken against the ISO/IEC 7810 ID-1 size that every payment card shares, and no other object is accepted as a reference.

3.5 Payment information

• Your subscription plan and billing history
• Where you pay through the Apple App Store or Google Play, those stores process your payment and we receive only a confirmation that a subscription is active; we do not receive your card details
• Where you pay us directly or pay a practitioner through the Platform, our payment processor (Stripe) handles the card data. We store only a payment token and the last four digits, for identification

We never hold your full card number or bank account details on our systems.

3.6 Apple Health and Health Connect

Connecting Apple Health (on iOS) or Health Connect (on Android) is entirely optional and Nureo works fully without it.

If you connect it, we read only the data types you approve. Those types are:

• Steps
• Distance walked or run, and distance travelled
• Active energy burned, and basal (resting) energy burned
• Heart rate, and resting heart rate
• Sleep — both sleep sessions and time asleep
• Body weight
• Workouts, and workout routes

We read this data. We do not write to Apple Health or Health Connect. Every authorisation Nureo requests is read-only, and the app contains no path that writes a record back. Version 1.0 of this Policy said we write nutrition data back to Apple Health; that was never true of the app and has been removed.

We do not use Apple Health or Health Connect data for advertising, marketing, or any use-based data mining. We do not share it with data brokers or advertising platforms. We do not store it in iCloud. It is used only to show you your own information and to inform the features you have asked for.

3.7 Communications and community

• Messages you exchange with practitioners through the Platform
• Posts, comments, reactions and shared meals where you use the social and circles features, and your chosen visibility for each
• Reports you make about other users' content, and reports made about yours
• Support correspondence, feedback and survey responses
• Your participation in live seminars: which you join, questions you submit, and on-screen reactions. Most participants join as view-only and do not transmit camera or microphone. If you host or present, we process your live video and audio for the broadcast

3.8 Nuri conversations

The messages you send to Nuri and the responses it returns, together with the context passed with them (see clause 7).

3.9 Technical and device information

• Device type, operating system and app version
• IP address, and the approximate region derived from it
• App usage, session duration and feature interactions
• Crash reports and error logs
• Push notification token
• Session tokens and device identifiers
• The advertising-measurement events described in clause 10.5 (app installed and opened, account created, free trial started, store purchase)

3.10 Location

Nureo does not request access to your device's GPS or precise location. We deliberately do not, because the benefit to the product does not justify holding a continuous record of where you are.

Where we need an approximate region — for example to show practitioners near you — we derive it from your IP address, or you tell us.

One exception, and we are naming it rather than leaving it in the Apple Health clause. If you connect Apple Health or Health Connect and approve workouts, we read your workout routes — the GPS trace of a run or ride that your device already recorded. That is precise location data. It is read from Health, not from a location permission, and it is used only to draw the map on your own run summary. It is not uploaded to our servers, it is not stored by us, and it is not shared with practitioners or other members. The route for a single session is read from Health only while you have that run's summary open, drawn on your device, and discarded when you leave the screen. Nothing in the daily record we sync carries route data.

4. How We Collect Your Information

• Directly from you — when you register, complete your profile, check in, scan, log a meal, set a goal, upload a photo, message a practitioner, or contact support.
• Automatically — through your use of the Platform, including analytics, device information and technical logs.
• From your device, with permission — camera, photo library, depth sensor, Apple Health or Health Connect.
• From third parties — sign-in providers (Apple, Google), payment processors, and product data sources (clause 8).
• From practitioners — where you have engaged one and consented to them adding to your record.

Where practicable you may use parts of the Platform without identifying yourself or under a pseudonym. Features involving payment, practitioner engagement or the community require you to be identified.

5. Why We Use Your Information

We use personal information for the purpose we collected it for, for directly related purposes, where you have consented, or where the law permits or requires it.

To run the Platform — creating and managing your account; processing subscriptions; delivering scanning, scoring, logging, goals, pantry, audits and reminders; facilitating practitioner discovery, booking and messaging; providing support.

To personalise what you see — adjusting a product's score for your allergies, preferences, conditions and goals; grounding Nuri's answers in what you have actually logged; adjusting future estimates to your own measured bias; showing relevant practitioners.

To keep our estimates honest — building your accuracy record from your weighed corrections, and using aggregate, de-identified accuracy data to measure and improve the product.

To improve the Platform — analysing aggregated, de-identified usage; monitoring errors, performance and security incidents; research and development.

To build and correct the shared product catalogue — see clause 6.

To meet legal obligations — compliance, lawful requests, enforcing our terms, preventing fraud, and keeping tax and financial records.

To measure our advertising — learning which of our Facebook and Instagram ads lead people to install Nureo, create an account, start a trial and subscribe. See clause 10.5 for exactly what is sent.

To send you marketing, if you have agreed — see clause 9.

6. Community-Contributed Product Data

This is how the catalogue improves, and it is the reason a product you had to photograph today will simply scan for the next person.

What is shared: information about the product. What is not shared: anything identifying you. Your name, your account, your scan history and the fact that you were the contributor are not published, and are not visible to other members.

If you would prefer a submission not to be used this way, do not submit it for review — you can still use the label reading for yourself. If you have already submitted something and want it withdrawn, contact privacy@nureo.com.au, though we may not be able to remove information that has since been independently verified or corrected by others.

7. Artificial Intelligence

Several Nureo features use a generative AI model: Nuri, meal photo analysis, product label reading, receipt reading, supplement label reading, and crockery calibration.

7.1 What is sent, and where

When you use one of those features, the relevant image or text is sent — together with context about you — to Google Vertex AI, running in Google's australia-southeast1 (Sydney) region. Requests are routed through a Nureo server function authenticated with your own account credentials. No AI provider key is embedded in the app.

The context we send with a request may include your allergies, your dietary preferences, your health conditions, your goals, your recent logs, your measured crockery and, where available, the depth measurement from your device. We send it because an estimate that does not know you react to wheat is less useful and less safe than one that does.

For meal photographs, the same image is analysed more than once and the middle result is used, because a single reading of one photograph is less reliable than several.

7.2 What Google may and may not do with it

Google acts as our data processor under the Google Cloud Data Processing Addendum. Your prompts, images and the responses generated are not used to train or improve Google's models, are not reviewed by Google for product development, and are not used for advertising by Google or by us.

We have pinned the model and the region deliberately. Moving to a global endpoint would process your health data offshore, and we treat that as a privacy decision rather than a configuration choice.

7.3 Your consent

Because this sends health information to a third party, we ask for your explicit consent before the first time it happens, separately from your acceptance of this Policy or our Terms. You can withdraw it in privacy settings. If you do, the AI features stop working; barcode scanning, logging, and everything that does not require the model continue to work.

7.4 Retention

AI-generated responses are not stored as part of your health record. Conversation context within a Nuri session may be held briefly to keep the conversation coherent. Your Nuri message history is retained as described in clause 12.

8. Automated Decisions

Some things the Platform does are decided by software rather than by a person. We think you should know which, and we have set them out here. [This clause anticipates APP 1.7–1.9, which commence 10 December 2026. Confirm final wording against OAIC guidance, expected September 2026.]

None of these decisions is final and none is made about you by us in a way you cannot change. You can correct any estimate, weigh a meal to override it, change your allergy and preference settings at any time, decline a pantry proposal, and tell us when a score or a warning is wrong. Where you tell us a product's underlying data is wrong, a person at Nureo reviews it.

If you want to know why the Platform reached a particular result, contact privacy@nureo.com.au and we will explain it.

9. Direct Marketing

We may use your email address and push token to tell you about features, content and offers, but only where you have consented or where the Spam Act 2003 (Cth) permits it.

We do not use your health information to target marketing to you, and we do not use it to decide what marketing you receive.

You can opt out at any time by using the unsubscribe link in any marketing email, changing your notification settings, or emailing privacy@nureo.com.au. Opting out does not stop transactional messages such as billing confirmations, renewal notices and security alerts.

10. Who We Disclose Your Information To

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

10.1 Service providers

We use third parties to run the Platform. They may use your information only to perform services for us, under contract, and must maintain appropriate security. They are:

10.2 Practitioners

If you engage a practitioner through the Platform, we share what is necessary for that engagement — your name, contact details, and the health information you choose to share. We ask for your specific consent before sharing health information with a practitioner, and you choose what to share.

Your pantry and your scan history are not shared with practitioners. They are not part of what a practitioner can see, at any subscription tier, and a practitioner cannot request them. What is in your cupboard is your business; if you want your practitioner to know, you can tell them.

Practitioners are independent professionals bound by their own confidentiality obligations and by the Privacy Act. Where a practitioner records information about you in their clinical record, they are the custodian of that record and their own privacy obligations apply to it.

10.3 Other members

Content you choose to post to the feed, to a circle, or to share with a friend is visible to those people. Every post has a visibility setting, the default is private, and you control it. Progress photographs are private to you unless you deliberately share one.

10.4 Legal, safety and business transfers

We may disclose personal information where the law requires it, including in response to a subpoena, court order or lawful request. We will tell you unless we are prohibited from doing so.

We may disclose it where we reasonably believe it is necessary to prevent a serious threat to someone's life, health or safety, or to investigate suspected fraud or a security incident.

If Nureo is involved in a merger, acquisition or sale of assets, your information may transfer to the successor. We will notify you by email and in-app before that happens.

10.5 Measuring our advertising (Meta)

We advertise Nureo on Facebook and Instagram. To learn which ads lead people to install and use the app, the Nureo app for iPhone and Android includes Meta's App Events software development kit. Meta Platforms, Inc. (United States) and Meta Platforms Ireland Limited receive the following from it:

• that the app was installed, and each time it is opened;
• that an account was created, and whether it was created with email, Apple or Google;
• that your free trial started;
• purchases and subscriptions made through the App Store or Google Play — the product, its price and the currency — which the SDK reads from the store itself;
• the technical information that accompanies any request from the app: device model, operating system and version, app version, language, time zone, and IP address.

What Meta never receives from Nureo: anything you enter, record or connect in the app. No health or wellbeing information, food or meal logs, scans, supplements, symptoms, goals, quiz or questionnaire answers, Apple Health or Health Connect data, Nuri conversations, messages, photos, or your name, email address or phone number.

We do not collect your device's advertising identifier (the Apple IDFA or the Google advertising ID), and the app does not ask for permission to track you across other companies' apps. On iPhone, Meta attributes installs through Apple's SKAdNetwork and Meta's Aggregated Event Measurement, which report results in aggregate.

Because Nureo is a health and nutrition app, the fact that you installed and use it can suggest an interest in health. Meta receives that fact. Meta handles what it receives under its own privacy policy, and it may be able to connect these events with a Facebook or Instagram account used on the same device or network. You can see and disconnect activity that apps share with Meta under "Your activity off Meta technologies" in your Facebook or Instagram settings.

The app does not currently include a switch to turn this off. If you do not want Meta to receive these events, you can email privacy@nureo.com.au, or disconnect the activity in your Meta account as described above.

11. Information Sent Outside Australia

Your account data and your health information are stored in Australia. Nureo's database, file storage, authentication and AI processing all run in Google's Sydney (australia-southeast1) region. Our web application runs in Vercel's Sydney (syd1) region. Our live video, telehealth and email delivery run in Amazon Web Services' Sydney (ap-southeast-2) region.

Live seminars, telehealth consultations and their join tokens do not leave Australia. Both the media and the token-issuing function are hosted in Sydney.

A limited number of things do leave Australia. We have listed them individually rather than describing them generally:

Before disclosing personal information overseas we take reasonable steps to ensure the recipient does not breach the APPs, including data processing agreements binding them to APP-equivalent standards.

On consent and APP 8. Version 1.0 of this Policy relied on your consent to disengage APP 8.1, which would have meant you could not seek redress under the Privacy Act if an overseas recipient mishandled your information. We have removed that. We do not ask you to give up that protection. We rely on the reasonable-steps obligation in APP 8.1 and we accept accountability under s 16C for what our overseas processors do with your information.

A current list of the countries in which our service providers operate is available from privacy@nureo.com.au.

12. How Long We Keep Things

After the applicable period we securely delete or de-identify the information. You may ask us to delete earlier where we have no legal obligation to keep it.

13. Deleting Your Account

You can delete your account from within the app, in account settings. You do not need to email us, and you do not need to explain why.

Deleting your account removes your personal information, your health information, your logs, your photographs, your pantry, your scan history and your community posts. Your Nuri conversations are not covered by this, because they are not ours to delete: they are written to storage on your device and reach our servers at no point. To remove them, uninstall the app or clear its data on each device you have used Nureo on. It does not remove:

• information we are legally required to retain (clause 12) — chiefly financial records and, where you have engaged a practitioner, the clinical record, which belongs to the practitioner and is subject to their retention obligations;
• product data you contributed to the shared catalogue, which is not linked to you (clause 6); and
• de-identified analytics, which cannot be linked back to you.

You can also request deletion from the web at nureo.com.au/delete-account, without opening the app.

Export your data before you delete it if you want a copy — see clause 14.

14. Your Privacy Rights

Access (APP 12). You may request access to the personal information we hold about you. Email privacy@nureo.com.au. We respond within 30 days. We may charge a reasonable fee for the cost of providing access, disclosed before we proceed. We may decline in the limited circumstances the Privacy Act permits, and will give you written reasons.

Correction (APP 13). If information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, ask us to correct it and we will take reasonable steps within 30 days. If we disagree, we will explain why and, if you ask, attach a statement to the record.

Deletion. See clause 13.

Export. You can request a machine-readable export of your data at privacy@nureo.com.au. We aim to provide it within 30 days.

Anonymity and pseudonymity (APP 2). Where practicable, you may deal with us anonymously or under a pseudonym.

Withdrawing consent. You may withdraw any consent at any time in privacy settings or by contacting us. See clause 1.1.

Explanation of an automated result. See clause 8.

15. Security

We hold health information, and we treat it accordingly. Our measures include:

• Encryption in transit (TLS) and at rest
• Passwords stored using one-way cryptographic hashing
• Per-user access rules enforced at the database layer, so one member's records cannot be read by another
• Access controls limiting staff and contractor access on a need-to-know basis
• Staff training on privacy and security
• Documented incident response procedures

No method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security. Use a strong, unique password and keep your device secure.

If you find a security vulnerability, tell us at privacy@nureo.com.au. We will not pursue you for reporting a genuine vulnerability in good faith.

16. Data Breaches

The Notifiable Data Breaches scheme under Part IIIC of the Privacy Act requires us to notify the Office of the Australian Information Commissioner (OAIC) and affected individuals of an eligible data breach — one likely to result in serious harm.

If one occurs we will contain it, assess it, notify the OAIC as soon as practicable, notify you if your information was involved, and tell you what happened, what was involved, and what we suggest you do.

Because we hold health information, we treat every suspected breach as high priority.

17. Cookies and Similar Technologies

The mobile app does not use browser cookies. It uses device identifiers, session tokens and analytics SDKs to keep you signed in, understand usage, and detect fraud. It also includes Meta's App Events SDK to measure our advertising, which is described in clause 10.5. The app does not collect your device's advertising identifier.

Our website, the member dashboard and the practitioner workspace are web applications and use cookies for one purpose: keeping you signed in. Those are strictly necessary cookies — without them you could not hold a session — and they are set when you sign in, not when you arrive.

We use Vercel Analytics for de-identified usage measurement. We do not run advertising, conversion or third-party tracking pixels on any page, and we do not use any non-essential cookie or tracking technology, which is why you are not asked to dismiss a consent banner. If we ever introduce one, we will ask for your consent before it is set, and we will not treat a generic banner as consent for anything that could reveal a health interest.

You can manage some tracking through your device settings; doing so may affect functionality.

18. Children

Nureo is for adults. You must be 18 or over to create an account, and we do not offer the Platform to anyone under that age. This is a single position: there is no under-18 tier and no parental-consent route.

We do not knowingly collect personal information from anyone under 18. If we learn that an account belongs to someone under 18, we will delete the personal information we hold for it and close the account.

If you are a parent or guardian and believe your child has given us personal information, contact privacy@nureo.com.au and we will remove it.

Information about children in your household. If you scan a lunchbox or a product for a child, we hold that as your data, not the child's, and Nureo's scoring is calibrated for adults. Do not use Nureo's scores to make clinical decisions about a child's diet.

19. Third-Party Links

The Platform may link to third-party sites and services. This Policy does not apply to them. Read their privacy policies.

20. Changes to This Policy

We may update this Policy. We will notify you of material changes by email and by prominent in-app notice at least 14 days before they take effect.

If a change would broaden how we use your health information, we will ask for your consent again rather than relying on your continued use.

Previous versions are available on request.

21. Complaints

Talk to us first. Email privacy@nureo.com.au with 'Privacy Complaint' in the subject line. We will acknowledge within 5 business days and aim to resolve within 30 days. If we need longer we will tell you why.

If you are not satisfied, you may complain to the Office of the Australian Information Commissioner:

• www.oaic.gov.au
• 1300 363 992
• enquiries@oaic.gov.au

The OAIC can investigate and make determinations, including ordering remedial action or compensation.

Appendix A — How We Meet Each Australian Privacy Principle

APP 1 — Open and transparent management. This Policy is published on our website and in the app. We have a Privacy Officer. From 10 December 2026, clause 8 discloses our automated decision-making.

APP 2 — Anonymity and pseudonymity. Available where practicable. Identification is required for payment, practitioner engagement and community features.

APP 3 — Collection of solicited personal information. We collect only what is reasonably necessary. Health information is collected with express, specific consent, sought at the point of collection rather than bundled.

APP 4 — Unsolicited personal information. Where we receive information we did not solicit and could not have collected under APP 3, we destroy or de-identify it.

APP 5 — Notification of collection. This Policy, plus in-app notices at the point of collection for camera, health data, AI processing and practitioner sharing.

APP 6 — Use and disclosure. Used for the primary purpose, directly related secondary purposes, or with consent. Health information is not used for advertising.

APP 7 — Direct marketing. Consent-based, with opt-out on every message. Health information is not used to target marketing.

APP 8 — Cross-border disclosure. Clause 11 lists each overseas disclosure individually. We rely on reasonable steps and contractual protections, not on asking you to waive your redress rights.

APP 9 — Government-related identifiers. We do not adopt, use or disclose government identifiers as our own.

APP 10 — Quality. We take reasonable steps to keep information accurate and current, and you can correct it yourself.

APP 11 — Security. Clause 15. We destroy or de-identify information we no longer need (clause 12).

APP 12 — Access. Within 30 days, refusable only on lawful grounds with written reasons.

APP 13 — Correction. Within 30 days, with a statement attached if we disagree.