Privacy Policy
1. Introduction
1.1 We are PaxAnimi Platform Pty Ltd atf PaxAnimi Platform Unit Trust t/as Pax Psychology (we, us, our). We offer and connect clients (you, your, client) to online psychology services and corporate wellness services via our online platform at our website www.paxpsychology.com.au (Services).
1.2. This Privacy Policy (Privacy Policy) is provided to ensure that you understand your rights and obligations about your personal information when you access and use our Services.
1.3. We respect the rights and privacy of all individuals and are committed to complying with the privacy standards in the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles and protecting the Personal Information we hold.
1.4. In relation to your Personal Information, this Privacy Policy sets out:
- what we collect, hold and use;
- how and why we collect it;
- what happens if we can’t collect it;
- how and why we may disclose it;
- how we use third party hosting;
- how long we retain what we collect;
- how we make sure it is secure;
- how you can access or correct what we collect; and
- how you can complain about privacy breaches; and
- how to contact us.
1.5. We may amend this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date at the top of this page. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our website or platform or sending you an email prior to the change becoming effective. You are bound by any changes to the Privacy Policy when you use the website or platform after such changes have been posted.
2. What is ‘Personal Information’
2.1. We collect personally identifiable information from our psychologists and clients so that we can provide the Services. We may also collect health information which is a category of personal information called sensitive information. Any reference to “Personal Information”, “health information” or “sensitive information” in this Privacy Policy means personal and sensitive information as defined in section 6 of the Privacy Act.
2.2. The Privacy Act currently defines “Personal Information” as meaning information or an opinion about an identified individual or an individual who is reasonably identifiable:
( a ) whether the information or opinion is true or not; and
( b ) whether the information or opinion is recorded in a material form or not.
2.3. If information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “Personal Information” and will not be subject to this Policy.
2.4. Personal Information can include “health information”, which includes (among other things) information regarding an individual’s physical or mental health or a health service provided to an individual or “sensitive information”, which includes (among other things) information or an opinion about an individual’s health, racial or ethnic origin, political opinions, religious beliefs, criminal record, and sexual orientation Sensitive Personal Information).
2.5. We are committed to protecting the Personal Information we collect and regularly monitor our systems and procedures to ensure compliance with this Privacy Policy. This Privacy Policy outlines the way in which we deal with the Personal Information (including Sensitive Personal Information) it collects.
2.6. We are not responsible for the privacy practices of any third-party websites that may be linked on our platform and website.
3. What we collect, hold and use
3.1. If you are a psychologist we may collect Personal Information such as:
( a ) your name;
( b ) your email addresses;
( c ) your address;
( d ) your phone number;
( e ) your date of birth;
( f ) your Medicare provider number;
( g ) your languages spoken;
( h ) your resume;
( i ) your employment history;
( j ) your qualifications and experience;
( k ) your reference checks and criminal history;
( l ) your right to work in Australia documents;
( m ) your proof of identity documents; and
( n ) any other information or opinions relating to you that you provide to us directly through the Services.
3.2. If you are a client, we (or psychologists you engage with on the Platform, together with any other staff employed by or with the psychologist) may collect Personal Information such as:
( a ) your name;
( b ) your email addresses;
( c ) your phone number;
( d ) your date of birth;
( e ) your gender;
( f ) your languages spoken;
( g ) your marital status;
( h) your next of kin;
( i ) your occupation and employment status;
( j ) your psychologist preferences;
( k ) any clinical information that you chose to share with us;
( l ) your rating or review of the session you had with the psychologist;
( m ) you payment information;
( n ) your Medicare number;
( o ) your Private Health Insurance information;
( p ) your GP information; and
( q ) information about your Mental Health Plan.
3.3. We may collect some information automatically when you interact with the Services, including but not limited to your IP address, device ID, browser type, browser version, the time and date of your visit, the time spent on pages, and other diagnostic data.
3.4. The relevant psychologist may take private client notes during the private sessions with the client containing Personal Information and private information. These client notes are confidential and stored by the relevant psychologist (and are the responsibility of the psychologist) and may be stored on our practice management database securely.
3.5. We endeavour to only collect Personal Information where it is reasonable to do so and we aim to collect the minimum amount of Personal Information to enable us to deliver the Services to you.
4. Disclaimer
4.1. By using our platform, you enter a direct and legally binding contractual relationship with us. However, you understand and agree that we act solely as an intermediary between the users and accredited psychologists registered with us (Psychologists). We are not responsible for the provision of psychology or any other medical services. While we use our best endeavours to match you with a Psychologist suitable for your needs, we do not guarantee or warrant that our website or platform will result in any particular clinical outcome or that the Psychologist will meet your needs.
4.2. The information on our website and platform is not intended or implied to be a substitute for professional medical advice, diagnosis or treatment. We make no representation and assume no responsibility for the accuracy of information contained on or available through this website or platform, and such information is subject to change without notice. You are encouraged to confirm any information obtained from or through our website and platform with other sources and review all information regarding any medical condition or treatment with your physician.
4.3. Never disregard professional medical advice or delay seeking medical treatment because of something you have read on or accessed through the Services.
4.4. We do not recommend, endorse or make any representation about the efficacy, appropriateness or suitability of any specific tests, products, procedures, treatments, services, opinions, health care providers or other information that may be contained on the Platform or available through the Services.
5. How and why we collect it?
5.1. The primary purpose for which we collect Personal Information is to enable us to perform and deliver our business activities and functions.
5.2. We collect your Personal Information directly from you when you access our Services, including:
( a ) when you sign-up as a psychologist through our platform;
( b ) when you sign-up as a client through our platform;
( c ) when you use our Services;
( d ) when you contact us;
( e ) when you give us information about you;
( f ) if you consent for a third party to send us your information; or
( g ) during any communications or interactions between you and us.
5.3. We do not sell or share your Personal Information with marketing companies or advertising providers.
5.4. We may use your Personal Information to contact you with updates about our Services that may be of interest to you, news, or promotional materials. You can opt out of receiving these communications from us at any time.
5.5. These communications may be sent by email in accordance with applicable marketing laws, such as the Spam Act 2004 (Cth).
6. What happens if we can’t collect it?
6.1. We may not be able to deliver the Services to you effectively (or at all) if you choose not to provide us with Personal Information.
7. How and why we may disclose it?
7.1. We may disclose your Personal Information to:
( a ) the psychologists registered on the platform to enable us to deliver the Services;
( b ) external or third party service providers to enable us to deliver the Services;
( c ) comply with a legal obligation.
7.2. If we are involved in a merger, acquisition or asset sale, your Personal Information may be transferred. We will provide you with notice before your Personal Information is transferred and becomes subject to a different Privacy Policy.
8. How we use third party providers
8.1. We use HubSpot as our practice management database for storage purposes and Agility Digital Pty Ltd as our third party administrator. Your Personal Information will be collected and stored using HubSpot and Agility Digital Pty Ltd.
8.2. AAll payments made using our Services are processed by our third party payment provider Stripe. We use Stripe to process all payments, whereas HubSpot and Medipass are used to process Medicare rebates and Private Health Insurance claims.
8.3. When you make payments for our Services, you will be redirected to HubSpot and Medipass. HubSpot and Medipass may collect Personal Information from you.
8.4. You can find the Medipass, HubSpot, Agility Digital Pty Ltd and Stripe privacy policies at the below links:
( a ) Medipass – https://medipass.com.au/privacy-policy;
( b ) HubSpot – https://legal.hubspot.com/privacy-policy;
( c ) Agility – https://agility-digital.com/privacy-policy/
( d ) Stripe – https://stripe.com/en-au/privacy
(e) Oliver Grace – https://olivergrace.com.au/
8.5. Our website is hosted by third party service providers.
8.6. We may provide your Personal Information to other third party service providers for the following purposes:
( a ) database management;
( b ) secure storage, management and back up;
( c ) website analytics;
( d ) IT administration;
( e ) efficient communications; or
( f ) any other purposes so that we can effectively operate the Services.
8.7. We take reasonable steps to ensure the security of your Personal Information before disclosure to any third party service provider, including that it does not breach the Australian Privacy Principles or similar requirements.
8.8. We make no representations or warranties about the privacy practices of any third party service providers and we are not responsible for the privacy policies or the content of any third party service provider.
8.9. If you click a link to other websites, we advise you to check the privacy policy and terms and conditions of those websites before using their services.
9. How long will we retain it and make sure it is secure?
9.1. We will retain Personal Information for as long as it is relevant for the purpose it was collected for.
9.2. When disposing of Personal Information, we may take appropriate steps to make it non-personally identifiable. Data may persist in copies made for backup and business continuity purposes for additional time.
9.3. We implement commercially reasonable technical, administrative, and organisational measures to protect Personal Information from loss, misuse, and unauthorised access, disclosure, alteration, or destruction in accordance with the Applicable Laws. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Information to us via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Services, or third-party websites.
9.4. If you suspect any misuse, loss, or unauthorised access to your Personal Information, please let us know immediately.
9.5. If we suspect any misuse, loss or unauthorised access to your Personal Information we may inform you of that suspicion and take immediate steps to limit any further access to, or distribution of, your Personal Information.
9.6. You agree to fully indemnify us for any misuse, loss or unauthorised access to your Personal Information collected by the Psychologists, and which has not been collected from the platform or on our behalf.
9.7. If we determine that any misuse, loss or unauthorised access to your Personal Information is likely to result in serious harm to you and we are unable to prevent the likely risk of serious harm with remedial action, we will take steps to notify the appropriate data protection authority as soon as practicable.
9.8. If we receive unsolicited Personal Information that we are not permitted to collect under this Privacy Policy or within the confines of the law, we will destroy or de-identify the unsolicited Personal Information as soon as practicable if it is lawful and reasonable to do so.
10. How can you access and correct your information?
10.1. You may request access to any Personal Information that we hold about you at any time by contacting us at info@paxpsychology.com.au.
10.2. If you make an access request, we will ask you to verify your identity. There may be instances where we cannot grant you access to the Personal Information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
10.3. If you believe that Personal Information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it.
10.4. We request that you keep your information as current as possible so that we may continue to improve our Services to you.
10.5. If the Personal Information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the products or services you, or they, are seeking.
11. How you can complain about privacy breaches
11.1. If you believe that your privacy has been breached or if you have any questions or concerns about our Privacy Policy please, contact us using the email info@paxpsychology.com.au and we will investigate.
11.2. We are genuinely committed to the rules, ethos and intent detailed in this Privacy Policy and we aim to ensure that your requests or complaints are treated confidentially.
11.3. Our Privacy Officer will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.
11.4. If you are not satisfied with the outcome of our investigation, then you may request that the Office of the Australian Information Commission investigate your complaint at their website https://www.oaic.gov.au/.
12. Contact Us
If you have any questions about your Personal Information, this Privacy Policy or concerns or complaints, please contact our Privacy Officer by email at info@paxpsychology.com.au.