Privacy Policy

Avahn Health is committed to protecting your privacy and ensuring the confidentiality of your personal health information. This Privacy Policy explains how we collect, use, disclose, and store your data when you use our website, mobile app, or services.

Please read them carefully.

Introduction

Avahn Health (“we/us”) recognizes the importance of your privacy and acknowledges your right to control how your personal information is collected and used. We understand that providing personal information is an act of trust, and we take that responsibility seriously. Unless you provide direct consent to do otherwise, we will only collect and use your personal information as detailed in this policy. Our privacy policy is designed to represent industry best practice and comply fully with the Privacy Act 1988 and other applicable privacy laws in Australia.

Please also visit and read our Terms and Conditions. Under those Terms and Conditions, you acknowledge the content of this Privacy Policy and provide your consent to your personal information being handled in the manner set forth herein. Further, by accessing or using our website (https://avahnhealth.com.au) (“Website”), our connected healthcare operating system (app.avahnhealth.com.au) and realted social media sites you agree to the terms of our Privacy Policy and consent to the handling of your personal information in the manner detailed below

Privacy Policy & Data Collection

1. Introduction to Privacy: Avahn Health (“we/us”) recognizes the importance of your privacy and your right to control how your personal information is collected and used. Providing personal information is an act of trust which we take seriously. Unless you provide direct consent to do otherwise, we will only collect and use your personal information as set out in this policy. Our practices are designed to represent industry best practice and comply fully with the Privacy Act 1988 and other Australian privacy laws.
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2. Information Collection for Service Delivery: Avahn Health operates as a connected healthcare operating system that connects customers with registered doctors and pharmacists. To facilitate these Services, we collect Personal Information and Sensitive Information through our Website.

Personal Information Collected: We collect information reasonably necessary to undertake our business activities and deliver Services to you, including:
- Contact Details: Full name, address, date of birth, and telephone numbers.
- Account Details: Username and password for portal access.
- Transaction Information: Details regarding products or services you have ordered.
- Payment Data: Billing information for facilitated consults (Initial $59, Transfer $59, or Review $59).
- Technical Usage Data: IP addresses, browser characteristics, device identifiers, and usage statistics.
Sensitive Information Collected: Due to the nature of our healthcare infrastructure, we collect health-related data, including:
- Medical History: Current and historical treatment and medication history.
- General Health Data: Family medical history (where relevant) and general health information.
- Government Identifiers: Medicare numbers, IHI Number, pension veteran affairs numbers, or aged care provider identifiers.
- Practitioner Requests: Any other health information requested by registered doctors and pharmacists to provide safe care.

3. Consent and Portal Architecture: By providing health or sensitive information through the Patient Portal, you provide express consent for Avahn Health to collect, use, and disclose that information as described in this policy. Your data flows through a modular portal architecture designed to prevent data leakage and cross-contamination:

Patient Portal: Captures demographics, medical questionnaires and identity.
Doctor Portal (3rd Party EHR System): Receives structured intake data to enable SOAP-style documentation and prescribing.
Pharmacy Portal: Accesses necessary prescription details for fulfillment without seeing your full clinical history.

4. Withdrawal of Consent: You may withdraw your consent at any time by contacting us. However, please note that withdrawing consent may result in Avahn Health being unable to provide you with further Services.

Cookies and Digital Tracking

1. Avahn Health may collect information when you access and use our Website and its associated portals by utilizing features and technologies of your internet browser, including cookies and similar technologies. A cookie is a piece of data that enables us to track and target your preferences within our multi-portal architecture.

2. Information Collected via Tracking: The type of information we collect may include:

Statistical Information: Usage statistics and drop-off analysis.
Technical Details: Your operating system, browser type, and internet protocol (IP) address.
Engagement Data: The date and time of your visit, pages accessed, and links clicked.
Location Data: General location information to ensure compliance with Australian healthcare regulations.

3. How We Use Cookies: We use cookies and similar technologies to:

Personalise Your Experience: Identify you as a return user to the Patient Portal and enhance your interaction with our Core Health OS.
Improve Navigation: Ensure our Website and various portals remain easy to use and navigate.
Analyse Trends: Utilize your IP address to track traffic patterns, administer our platform, and gather demographic information.
Security and Fraud Prevention: Use IP addresses and other Personal Information for credit fraud protection and risk reduction.

4. Managing Your Preferences: Most browsers are initially set up to accept cookies. You may reset your browser to refuse all cookies or warn you before accepting them. Please note that if you reject our cookies or similar technologies, you may still use the Website, but you may experience limited functionality in certain areas, such as the Patient Portal.

How We Collect Your Information

1. Avahn Health collects your Personal Information in several ways to enhance your experience within our ecosystem:

Direct Interaction: Through your use or orders of our Services, including records of these transactions.
Patient Portal Submission: When you visit our Website, submit information through the Patient Portal, contact us directly, or complete digital forms and documents.
Onboarding & Intake: During our onboarding journey where we capture demographics, identity, and condition-specific health data.
Third-Party Professionals: From independent registered doctors or pharmacists within our network.
Employment Applications: When you apply for a position with us.
Public and Legal Channels: From publicly available sources of information or when legally authorised or required to do so.
Emergency Situations: Where it is impracticable to seek your consent, such as during a medical emergency.

2. Purpose and Authority: The Personal Information we collect is utilized to track and enhance your use of the Website and our Services, ultimately assisting us in providing better care coordination. By providing your Personal Information, you acknowledge that you are authorised to disclose such information to us. We will take reasonable steps to notify you of the collection at or before the time it occurs.

Privacy Policy – Collection from Authorised Representatives

1. Collection from Your Authorised Representative: When Avahn Health collects your Personal Information from an authorised representative - such as a legal guardian, family member, or carer - we will take reasonable steps to ensure you are made aware of this collection. This transparency is a core part of our Patient Portal onboarding and intake process.

2. Providing Information About Another Individual: If you act as an authorised representative and provide Avahn Health with Personal Information about another individual, we rely on you to:

Inform Them: Notify the individual that you are providing their Personal Information to us.
Advise on Contact: Inform them that they may contact Avahn Health directly for further information regarding their data.
Ensure Awareness and Consent: Take reasonable steps to ensure the individual is aware of and consents to the matters outlined in this Privacy Policy. This includes:
- The fact that their Personal Information is being collected.
- The purposes for which that information is being collected.
- The intended recipients of that information (e.g., clinicians in the EHR Platform or pharmacists in the Pharmacy Portal).
- The individual’s right to access their information.
- Avahn Health’s identity and how to contact our team.

3. Assistance with Data Requests: Upon our request, you must assist Avahn Health with any requests by the individual to access or update the Personal Information you collected from them and provided to our platform. This ensures data integrity across our all our portals, which serves as our control tower for compliance and auditability.

Purpose of Use and Disclosure

1. Avahn Health does not sell your Personal Information to advertisers or third-party sellers. We use and disclose your Personal Information primarily to operate our connected healthcare operating system and for the purposes for which the information was collected, including (but not limited to):

Service Delivery: Providing or delivering our modular health platform and facilitated care services to you.
Support: Assisting with or responding to your queries through our Patient Care team.
Communication: Informing you about our Website, Services, or other matters of interest, such as platform updates or recruitment opportunities.
Employment: Establishing and maintaining records for staff recruitment, workplace health and safety, and other employment-related purposes.
Third-Party Integration: Sharing necessary data with our Third-Party Providers, such as payment processors (Artspay) and delivery partners.
Platform Management: Administering, improving, and managing our Website and the various Portals within our architecture.
Billing: Charging and billing you for facilitated consultations and services.
Identity Verification: Verifying your identity to ensure safe and regulated clinical access.
Development: Research, planning, and development purposes to enhance the application.
Marketing & Engagement: For fundraising and direct marketing purposes, where permitted.
Compliance: Complying with our legal and regulatory obligations under Australian healthcare law.

2. Clinical and Pharmacy Disclosures: To facilitate safe clinical care, we disclose your Personal Information within our multi-portal architecture:

EHR Platform: Your data is shared with our network of independent registered doctors to determine whether it is appropriate and safe to prescribe medicines to you.
Pharmacy / Dispensary Portal: If a registered doctor prescribes medicines, we share necessary Personal Information with partner pharmacists to prepare, dispense, and deliver your medication.

3. De-identified and Aggregated Information: We may use, share, or disclose information that has been de-identified or aggregated so that it cannot reasonably identify you. This includes applying technical measures such as hashing before disclosure.

We use de-identified insights for research, analytics, and sharing product usage trends with trusted third parties.
Legal Status: As this information does not reasonably identify you, it is not considered “Personal Information” under the Privacy Act 1988 (Cth).

Disclosure to Third Parties

1. In order to operate our connected healthcare operating system and deliver our Services to you, Avahn Health may disclose your Personal Information to several categories of third parties:

Platform and Operational Partners: This includes our related bodies corporate, business partners, and external service providers who perform essential functions on our behalf. These include website developers, legal and accounting providers, account and billing software providers, and banking or payment processors.
Logistics and Fulfillment Specialists: We share necessary data with couriers and fulfillment specialists to manage the delivery of prescription medicines.
Clinical and Pharmaceutical Network: Your information is shared with our network of independent registered doctors via the third party EHR Platform and our partner pharmacists via the Pharmacy / Dispensary Portal.
Regulatory and Law Enforcement Bodies: We may disclose information to law enforcement or regulatory authorities to assist with their functions or as otherwise required or authorized by Australian law.

Collectively, these entities are referred to as Third Party Providers.

2. Data Security and Compliance: Prior to disclosing any Personal Information to Third Party Providers, Avahn Health takes reasonable steps to ensure these entities treat your data securely and comply with the relevant Australian Privacy Principles. Our modular portal architecture is specifically designed to enforce strict permission boundaries, ensuring that each provider only accesses the data necessary for their specific role.

3. Direct Communication with Health Practitioner: Third Party Providers may occasionally request Personal Information from you directly to facilitate care. For example:

A registered doctor may request additional medical details via email, or telephone.
You acknowledge and consent that the doctor may provide copies of these exchanges to Avahn Health.
We will handle all such information in accordance with this Privacy Policy.

Disclaimer

1. Avahn Health will not disclose your Personal Information to any third party (other than our Third Party Providers) without your written consent, unless:

We are otherwise required by law.
We are permitted to do so under this Privacy Policy.
Such disclosure is, in our opinion, reasonably necessary to protect our rights or property, avoid personal injury or death to any person, or ensure the proper functioning of the Website and its integrated portals.

2. For clarity, this restriction does not apply to information that has been de-identified or aggregated, including through hashing or other technical measures. Because such information does not reasonably identify you, it is not considered “Personal Information” under the Privacy Act 1988 (Cth).

This Privacy Policy only covers the use and disclosure of information we collect from you. The use of your Personal Information by any third party (including independent clinicians and pharmacists in our network) is governed by their respective privacy policies and is not within our direct control.

Marketing Communications

Avahn Health may use and disclose your Personal Information to send you information about our Website and Services, as well as other information that may be of interest to you. This includes updates regarding our healthcare operating system, such as new health productivity tools or platform features. We may send this information in a variety of ways, such as by mail, email, SMS, telephone, social media, or by customizing online content and displaying advertising on our Website.

If you do not wish to receive any of these marketing communications, you can opt out at any time by:

Following the unsubscribe instructions included in the relevant marketing communication.
Contacting us directly using our support contact details.

Overseas Disclosures of Personal Information

1. In the course of operating our connected healthcare operating system and delivering our Services to you, it may become necessary or desirable to disclose Personal Information to Third Party Providers located overseas. The specific countries in which these overseas recipients are located will depend upon individual circumstances and the requirements of our modular portal architecture.

The data protection laws in these overseas jurisdictions provide various levels of protection for Personal Information, which may not always be equivalent to the levels provided under Australian law. Where Avahn Health transfers your Personal Information overseas, we will take reasonable steps to ensure that your information is treated securely and that the means of transfer provides adequate safeguards in accordance with industry best practices.

Notifiable Data Breaches Scheme

1. In the event of any loss, or unauthorised access or disclosure of your Personal Information that is likely to result in serious harm to you, Avahn Health will investigate and notify you and the Australian Information Commissioner as soon as practicable. This process is conducted in strict accordance with the notifiable data breach scheme contained in Part IIIC of the Privacy Act 1988 (Cth).

2. Our multi-portal architecture, is designed to provide full audit logs and monitoring to ensure a secure healthcare environment.

Access to Information

1. At Avahn Health, we are committed to transparency and providing you with control over your personal data within our healthcare operating system.

Requesting Access: If at any time you want to know exactly what Personal Information we hold about you, you are welcome to access your record by emailing us at mail@avahnhealth.com.au.
Updating Information: If you wish to change Personal Information that is inaccurate or out of date, please email our support team.
Portal Updates: If you have an account, you may also be able to update certain information directly through the Patient Portal by clicking on "Edit Details". Otherwise, you can call or email us to update the information.
User Responsibility: If we provide you with a username and password for any of our portals, you are responsible for the security of your login information and must ensure its confidentiality.

Privacy Complaints

1. If you have any complaints or issues regarding the way Avahn Health has handled your Personal Information, or if you would like to discuss any aspects of our Privacy Policy, please contact us directly via email at mail@avahnhealth.com.au

When contacting us, please provide:

Full details of your complaint.
Any supporting documentation that may assist in our investigation.

2. Our Resolution Process:

Acknowledgment: We will respond to you within a reasonable period of time to acknowledge your complaint.
Next Steps: Our team will inform you of the specific steps we will take to resolve the issue.
Confidentiality: At all times, we will treat your privacy complaint seriously and in a strictly confidential manner.
Escalation: If you are unhappy with the response or resolution provided by our team, you may direct your complaint to the Office of the Australian Information Commissioner.

Changes to This Policy

1. From time to time, Avahn Health policies will be reviewed and may be revised to align with our evolving healthcare operating system. We reserve the right to change our Privacy Policy at any time and will notify you by posting an updated version of the policy on our Website.

Responsibility: You should check our Privacy Policy from time to time to ensure you are aware of any changes.
Consent: By accessing our Website or any of our integrated portals (such as the Patient Portal) after a change to our Privacy Policy, you agree to the terms of the policy as at the date of that access.
Inquiries: We are always happy to answer any questions you may have regarding privacy or security via our contact form or by emailing us at mail@avahnhealth.com.au.