Prime Protocols Pty Ltd (ABN 74 697 768 237) (“we”, “us”, “our”, or “Prime Protocols”) operates the website primeprotocols.com.au. We provide a specialized telehealth administrative platform alongside proprietary, clinical treatment protocols developed and licensed under the governance of our Chief Medical Officer. We are committed to protecting your privacy and handling your personal and health information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and applicable Australian health privacy frameworks.

1. Types of Information We Collect

We collect information across two distinct categories:

Personal Information: This includes your full name, date of birth, email address, phone number, residential address, billing details, and any information submitted via website inquiry fields, contact forms, or newsletter sign-ups.

Sensitive & Health Information: This includes medical intake responses, historical clinical data, treatment selections, clinical notes, patient therapy plans, and prescription records generated during your onboarding and consultations.

2. Digital Infrastructure & Third-Party Processors

Clinical Data Architecture: 100% of our patient-facing software management, secure clinical data tracking, booking engines, and electronic health records are securely processed, stored, and hosted via Halaxy, our integrated third-party practice management provider. Halaxy acts as the primary data processor for your clinical files.

Website Analytics: Our website uses tracking technologies, cookies, and analytics tools to gather non-identifiable user metrics (such as IP addresses and browsing habits) to optimise platform performance and manage digital marketing funnels.

3. Purpose of Collection and Use

We collect, hold, and use your information for the following administrative and clinical governance purposes:

* To facilitate appointment bookings, scheduling workflows, and automated reminders;

* To securely process private billing collections on behalf of your practitioner;

* To securely deliver our Chief Medical Officer’s proprietary clinical intake protocols to your consulting practitioner;

* To verify patient identity and ensure clinical safety before data is accessed by practitioners;

* To manage customer support inquiries, technical platform updates, and authorized newsletter communications.

4. Disclosure of Your Information

We do not sell, trade, or rent your personal or health data. Your information is disclosed strictly to:

Independent Contracted Medical Practitioners: Fully qualified, independently insured General Practitioners who utilize our platform and license our protocols to deliver clinical telehealth treatments. Under our framework, these practitioners maintain absolute clinical independence and act as the legal custodians of your clinical record entries.

Enterprise Infrastructure Partners: Secure cloud infrastructure, payment processors, and data back-up systems (including Halaxy and Google Workspace) necessary to securely run our business.

5. Data Security, Retention, and Purging

We and our technology partners deploy enterprise-grade cybersecurity controls— including Multi-Factor Authentication (MFA), role-based access, and data encryption both at rest and in transit.

In compliance with Australian statutory regulations governing medical records, health data hosted on our platform is securely retained for a minimum mandatory period of 7 years from the date of the last entry (or until a pediatric patient turns 25 years of age). Inactive records that have exceeded their statutory limit are securely destroyed or permanently de-identified.

6. Access, Corrections, and Complaints

You have the right to request access to the personal information we hold about you or request corrections to inaccurate details. Please direct all privacy inquiries, data access requests, or privacy complaints to our Privacy Officer at [email protected]. If you are unsatisfied with our internal response, you may escalate your complaint to the Office of the Australian Information Commission (OAIC).