Introduction

This Privacy Notice for PractaLuma Pty Ltd ('we', 'us', or 'our'), describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), including when you:

• Visit our website at https://www.practaluma.com, or any website of ours that links to this Privacy Notice
• Use PractaLuma. PractaLuma is an AI-first platform reimagining practice management systems for mental health clinics. We combine advanced voice agents, intelligent documentation, and proactive patient engagement to automate the entire front and back office, from intake and scheduling to clinical notes and follow-ups. Our solution reduces clinician admin time, directly unlocking revenue and improving patient outcomes.
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

• What personal information do we process?

  Some personal information such as your name, email, address, and phone number.

• Do we process any sensitive personal information?

  Some of the information may be considered 'special' or 'sensitive' in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more aboutsensitive information we process.

• Do we collect any information from third parties?

  We do not collect any information from third parties.

• How do we process your information?

  We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

• In what situations and with which parties do we share personal information?

  We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

• How do we keep your information safe?

  We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more abouthow we keep your information safe.

• What are your rights?

  Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

• How do you exercise your rights?

  The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect?Review the Privacy Notice in full.

What information do we collect?

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• job titles
• usernames
• passwords
• contact or authentication data
• billing addresses
• debit/credit card numbers

When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• health data

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/au/privacy.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called How do we handle your social logins? below.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps' ), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Google API

Our use of information received from Google API Services User Data Policy, including the Limited Use requirements.

How do we process your information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts.We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user.We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users.We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you.We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To enable user-to-user communications.We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To request feedback.We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications.We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see WHAT ARE YOUR PRIVACY RIGHTS?below.
• To deliver targeted advertising to you.We may process your information to develop and display personalised content and advertising tailored to your interests, location, and more.
• To identify usage trends.We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To save or protect an individual's vital interest.We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

What is our basis for collecting and using your information?

In Short: We collect and use your personal information only where it is reasonably necessary for our functions and activities, with your consent, to provide the Services, to meet our legal obligations, or to protect someone's safety.

Consistent with the Australian Privacy Principles, we rely on one or more of the following:

• Consent. Where you have given us permission to use your information for a specific purpose. You can withdraw your consent at any time (see 'What are your privacy rights?' below).
• Providing the Services. Where we need to process your information to deliver the Services or to do what you have asked of us.
• Legitimate business purposes. Where it is reasonably necessary to run, secure and improve our business, in a way you would reasonably expect and that does not override your privacy.
• Legal obligations. Where we need to comply with the law, cooperate with regulators or law enforcement, or establish or defend legal claims.
• Safety. Where it is necessary to protect the safety of a person, for example a serious threat to someone's life, health or safety.

When and with whom do we share your personal information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

You can manage or refuse cookies through your browser settings, as described in the section 'What are your privacy rights?' below.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

Google Analytics

We may share your information with Google Analytics to track and analyse the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Termspage.

Do we offer Artificial intelligence based products?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, 'AI Products'). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers ('AI Service Providers'), including Microsoft Azure AI and Amazon Bedrock. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in 'WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?' You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

• AI document generation
• Natural language processing
• Text analysis
• AI applications
• AI insights

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.

How do we handle your social logins?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

Is your information transferred internationally?

In Short: We store your information in Australia.

PractaLuma is an Australian company, and our servers and patient data are located in Australia. We do not transfer patient data overseas, it is not replicated outside Australia, and by contract it is never used to train foundation models.

If you access the Services from outside Australia, please be aware that your information is handled in Australia in accordance with this Privacy Notice and the Australian Privacy Principles.

How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than twenty four (24) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Do we collect information from minors?

In Short: We only process information about people under 18 where a parent or guardian has given consent. Otherwise, we do not knowingly collect information from, or market to, minors.

Some of the people our customers care for are under 18. Where a clinician using PractaLuma records information about a minor, we process that information on the clinician's instructions and only where the minor's parent or guardian has consented to their care and to the use of the Services. We do not knowingly collect personal information directly from minors, market to them, or sell their personal information. If we learn that information about a minor has been provided without the required parent or guardian consent, we will take reasonable steps to delete it. If you believe we hold information about a minor without proper consent, please contact us at [email protected].

What are your privacy rights?

In Short: Under the Australian Privacy Act 1988 and the Australian Privacy Principles (APPs), you can access the personal information we hold about you, ask us to correct it, and complain if you believe we have mishandled it.

You have the right to:

• Access the personal information we hold about you and request a copy of it.
• Correct information that is inaccurate, out of date, incomplete, or misleading.
• Withdraw consent at any time where we rely on your consent to process your information. This does not affect processing carried out before you withdrew consent.
• Opt out of marketing using the unsubscribe link in our emails, or by contacting us. We may still send service messages necessary to run your account.

To exercise any of these rights, contact us at [email protected]. We respond in accordance with the Australian Privacy Principles, usually within 30 days.

Making a complaint: If you believe we have breached the Australian Privacy Principles, please contact us first so we can try to resolve it. If you are not satisfied with our response, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

Account information

You can review or change your account information at any time by logging in to your account settings, or by contacting us. On request to close your account, we will deactivate or delete it and your information from our active databases, though we may retain limited information to meet our legal obligations, prevent fraud, or resolve disputes.

Cookies: Most browsers accept cookies by default. You can set your browser to remove or reject cookies, though some features of the Services may not work properly if you do.

If you have questions or comments about your privacy rights, email us at [email protected].

Users outside Australia

In Short: PractaLuma is built for Australia, but if you access it from overseas your local privacy laws may give you additional rights.

We are an Australian service governed by the Privacy Act 1988 (Cth). If you are in another region, you may have further rights under your local laws, for example the General Data Protection Regulation (GDPR) in the EU and UK, or state privacy laws in the United States. These can include the right to access, correct, delete, or port your information, and to object to certain processing.

To make any such request, contact us at [email protected] and we will respond as required by the laws that apply to you. EU and UK residents also have the right to complain to their local data protection authority.

Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

How can you contact us about this notice?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at [email protected], or contact us by post at:

How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information.