Privacy Policy

1. About this policy

Doctor Snap Pty Ltd ("Doctor Snap", "we", "us", "our") respects your privacy. This policy explains how we collect, hold, use and disclose personal information, including health information, when you use the Doctor Snap app, the website at dr-snap.com, or contact us.

We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). By using our services, you agree to your information being handled as set out in this policy.

2. Who this policy applies to

This policy applies to:

• patients and other individuals who use the Doctor Snap app
• doctors and other health practitioners who use the app
• visitors to our website
• anyone who contacts us, applies to test the app, or otherwise deals with us.

3. What information we collect

We only collect information that is reasonably necessary to provide our services. Depending on how you use Doctor Snap, this may include:

Identity and contact details

• name, email address, phone number and date of birth
• account login details (passwords are encrypted and not visible to us).

Health information (sensitive information)

• photographs and images you capture or upload through the app
• symptoms, notes, medical history or other health details you provide
• communications between you and a health practitioner through the app
• [any other health data the app records, e.g. assessment results].

Practitioner information

• name, practice details and contact details
• AHPRA registration number and professional qualifications.

Technical and usage information

• device type, operating system and app version
• IP address, log data and crash reports
• how you use the app and website, including pages viewed and features used.

Payment information

• [If applicable] payments are processed by [payment provider]. We do not store your full card details.

We do not collect government identifiers such as your Medicare number [delete or amend if the app does collect them].

4. Health information and your consent

Health information is sensitive information under the Privacy Act and receives a higher level of protection. We will only collect your health information with your consent, or where otherwise required or authorised by law.

You give consent when you create an account and choose to capture, upload or share health information through the app. You may withdraw your consent at any time by contacting us, although this may mean we can no longer provide some or all of our services to you.

5. How we collect information

We collect personal information:

• directly from you, when you register, use the app, complete a form or contact us
• from health practitioners using the app, when they record information relating to your care
• automatically, through cookies and similar technologies on our website and app
• from third parties, such as a practitioner who refers you, where you have agreed to this.

If you provide information about another person, you must have their permission to do so.

6. Why we collect and use information

We use personal information to:

• provide, operate and maintain the Doctor Snap app and website
• enable you to share images and health information with health practitioners you choose
• verify the identity and registration of health practitioners
• respond to enquiries, provide support and manage your account
• maintain the safety, security and integrity of our services
• meet our legal and regulatory obligations, including those relating to the Therapeutic Goods Administration (TGA)
• improve the app, including by analysing de-identified usage data
• conduct testing and research for app development, with your specific consent
• send you service updates and, where you have agreed, marketing communications.

We will not use your health information for marketing.

7. Automated decisions and AI

[Confirm with your developer and complete or delete this section.]

[If the app uses artificial intelligence or automated processing:] Doctor Snap uses [describe the tool, e.g. automated image analysis] to [describe what it does]. [Describe whether any decision that could significantly affect you is made or assisted by this technology, and what kinds of personal information are used.] Outputs from the app are not a diagnosis and do not replace advice from a qualified health practitioner.

8. Who we disclose information to

We may disclose personal information to:

• health practitioners you choose to share information with through the app
• service providers who help us operate our business, such as cloud hosting, IT support, analytics and email providers
• our professional advisers, such as lawyers and accountants
• regulators, including the TGA, where required
• law enforcement agencies, courts or others where required or authorised by law
• anyone else you have consented to.

Our service providers are required to protect your information and use it only for the services they provide to us. We do not sell your personal information.

Our current key service providers are:

9. Information stored or sent overseas

We store your health information in Australia [confirm with developer]. Some of our service providers may store or access other personal information overseas, including in [list countries]. Where this happens, we take reasonable steps to ensure the overseas recipient handles your information in a way that is consistent with the APPs.

10. How we protect your information

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure. These steps include:

• encryption of data in transit and at rest
• secure, access-controlled cloud hosting
• multi-factor authentication for staff access
• restricting access to staff and contractors who need it for their role
• regular review of our security practices.

No system is completely secure. Please keep your login details confidential and let us know immediately if you think your account has been compromised.

11. How long we keep information

We keep personal information only for as long as needed for the purposes set out in this policy, or as required by law. Health information is kept for [retention period, to be confirmed by your lawyer]. When information is no longer needed, we securely destroy or de-identify it.

12. Accessing and correcting your information

You may ask to access the personal information we hold about you, or ask us to correct it if it is inaccurate, out of date or incomplete.

To make a request, contact us using the details below. We will respond within 30 days. We may need to verify your identity first. There is no charge to make a request, although we may charge a reasonable fee for providing access in some circumstances. If we refuse a request, we will explain why in writing.

13. Deleting your account

You can ask us to delete your account at any time through [the app settings / by contacting us]. We will delete or de-identify your information unless we are required by law to keep it, in which case we will tell you.

14. Cookies and analytics

Our website and app use cookies and similar technologies to make them work properly, remember your preferences and understand how they are used. You can adjust your browser or device settings to refuse cookies, though some features may not work as intended.

15. Marketing

We will only send you marketing communications where you have agreed or where the law allows. Every marketing message includes a simple way to unsubscribe, in line with the Spam Act 2003 (Cth).

16. Children and young people

Doctor Snap is intended for users aged 18 and over. [If younger users are permitted, describe how a parent or guardian provides consent and how young people's information is handled.] If we learn we have collected information from a child without appropriate consent, we will delete it.

17. Data breaches

If a data breach is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner (OAIC) in line with the Notifiable Data Breaches scheme.

18. Making a complaint

If you have a concern about how we have handled your personal information, please contact our Privacy Officer using the details below. We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days.

If you are not satisfied with our response, you can contact the OAIC:

• Website: www.oaic.gov.au
• Phone: 1300 363 992

19. Changes to this policy

We may update this policy from time to time. The current version will always be available on our website and in the app, with the date it was last updated. If we make a significant change, we will let you know.