Privacy & Content Policy

AT A GLANCE

Human in the Loop: PhysiPal is an AI-assistive tool. All AI-generated SOAP notes, summaries, and referrals are drafts. Clinicians assume 100% professional and legal responsibility for verifying and utilizing these outputs.

No Data Selling: We do not sell your personal or health information to third parties.

Data Access Limits: We only access and process your data for the specific purposes of delivering and improving PhysiPal's functions and services.

Audio Privacy: Audio is processed for real-time transcription and is not stored. Once the transcript is generated, the raw audio is deleted.

Data Residency: Sensitive clinical data and transcripts are stored securely in Melbourne, Australia (for AU users) and within the United Kingdom (for UK users). All clinical processing subprocessors are located in the same region as the user.

Telehealth Privacy: Telehealth sessions are end-to-end encrypted; no unrecorded audio or video data is stored on our servers.

I. CONTENT

PhysiPal Pty Ltd (ABN 61 641 678 891) is the Data Controller for the personal information collected through our services. Registered address: 174 Bridge Richmond 3121, Australia.

This policy applies to all interactions within the PhysiPal ecosystem, including Communities, Patient Messaging, and Custom Branding.

1. Content Restrictions

Users are strictly prohibited from creating, sharing, transmitting, or displaying content that is:

  • Offensive or Discriminatory: Promoting hatred, harassment, or harm.
  • Medical Misinformation: Sharing health advice in Communities or the IHL Wiki that contradicts established clinical guidelines or professional standards.
  • Obscene or Explicit: Sexually explicit material or content that promotes exploitation.
  • Violent or Threatening: Content that incites violence or threatens physical harm.
  • Branding Misuse: Using the "Customise PhysiPal" feature to impersonate other clinics, professionals, or entities.

2. Behavioral Restrictions

Harassment and Bullying: Zero tolerance for intimidation within patient groups or direct messaging.

Data Breach: Unauthorized access to, or alteration of, other users' clinical data or personal information.

3. Enforcement

Violation of these provisions may result in immediate account termination. PhysiPal reserves the right to modify these policies at any time.

II. PRIVACY

1. WHAT INFORMATION DO WE COLLECT?

Clinical Documentation: We collect and process health information such as SOAP notes, EPCs, referrals, discharge summaries, Body Charts, and other clinical records as provided by the user. Health information constitutes special category personal data under UK GDPR Article 9 and sensitive information under the Australian Privacy Act, and is processed with additional safeguards.

Transcription Data: We process audio to generate transcripts. Raw audio files are used only for the duration of the transcription process and are deleted immediately after transcription.

Visual Media: Videos of patients for the Recorded Exercises feature.

Sensitive Information: Health data (symptoms, injury history, and exercise progress) collected via the Diary and Patient Feed.

Device Permissions: Access to Camera/Microphone (for Telehealth and Recording) and Storage (for PDF/Report generation).

Communications Data: Email addresses and preferences for newsletters and product updates, where consent is given.

Technical and Security Data: Logs of system access, IP addresses, device information, and security events for compliance and protection purposes.

Source of Data: We may receive personal information directly from patients, or from their treating clinicians, referring practitioners, or healthcare providers acting on the patient's behalf.

2. HOW WE PROCESS YOUR INFORMATION

We process your information only for the following PhysiPal functions:

AI Generation: Using AI to draft clinical documentation.

Text Analysis (IHL): Utilising a clinically tailored AI LLM to "dejargon" patient messages and identify alternative terminology to improve health literacy.

Exercise Delivery: Transmitting prescriptions via the App, Email, SMS, PDF, or print.

Operational Use: Syncing data with third party Practice Management Software (PMS) to simplify EHR obligations.

Lawful Bases for Processing (UK/EU users)
  • Service delivery and account management: Performance of a contract (UK GDPR Article 6(1)(b))
  • Clinical documentation and health information processing: Performance of a contract (Article 6(1)(b)) and provision of health or social care under the responsibility of a health professional (Article 9(2)(h))
  • AI processing of clinical content: Performance of a contract (Article 6(1)(b)) and Article 9(2)(h), with explicit patient consent (Article 9(2)(a)) obtained by the treating clinician for ambient AI transcription
  • Marketing communications: Consent (Article 6(1)(a))
  • Security, fraud prevention, and audit logging: Legitimate interests (Article 6(1)(f))
  • Legal and regulatory record-keeping: Legal obligation (Article 6(1)(c))

3. THIRD-PARTY DATA SHARING & INTEGRATIONS

PhysiPal does not sell user information. We share data only as necessary to provide the Services:

Inter-Clinic Cooperation: Sharing notes and reports with other clinicians at your direction via referral tools.

Practice Management: Syncing data to third-party EHR systems as configured by the user.

Subprocessors

We use a limited set of subprocessors to deliver our services:

  • Authentication: Google (authentication services). Authentication data may be processed outside the user's region.
  • Clinical AI processing and storage: Regional subprocessors located in the same region as the user. UK user data is processed by subprocessors located in the United Kingdom (including Google Vertex AI UK and regional speech-to-text services). Australian user data is processed by subprocessors located in Australia.

This regional architecture means that clinical and health information is processed and stored within the user's own jurisdiction.

International Data Transfers

For authentication services, limited personal data (such as email addresses and authentication tokens) may be transferred outside the user's region. Where such transfers occur from the UK or EU, we rely on appropriate safeguards including the UK Addendum to the Standard Contractual Clauses and EU Standard Contractual Clauses, supplemented by technical and organisational measures including encryption in transit and at rest. A current list of subprocessors and details of safeguards is available on request via hello@physipal.com.au.

4. AI & CLINICAL RESPONSIBILITY (Human in the Loop)

PhysiPal is an AI-powered assistive platform. All AI functions are designed with a "Human in the Loop" model:

Draft Status: All AI-generated SOAP notes, referrals, and summaries are considered drafts.

Clinician Responsibility: The attending clinician assumes full legal and professional responsibility for reviewing, editing, and utilizing AI outputs. Clinicians must sign off on all documentation before it is finalized or synced to an EHR.

Ambient AI Consent: Clinicians are responsible for obtaining explicit patient consent before using the Ambient AI transcription feature.

Text Analysis Accuracy: Clinicians must verify that AI-simplified language remains medically accurate and appropriate for the patient's condition.

No Solely Automated Decisions: PhysiPal's AI outputs are not used to make solely automated decisions about individuals. All clinical decisions are made by qualified clinicians who review and approve AI-generated content. Patients have the right to request information about how AI is used in relation to their care.

5. DATA STORAGE & SECURITY

Telehealth: Sessions are end-to-end encrypted. No unrecorded audio or video data is saved on our servers.

Storage Locations:

  • Australia: Sensitive files and transcripts for Australian users are stored securely and encrypted in Melbourne, Australia.
  • United Kingdom: Sensitive files and transcripts for UK users are stored securely and encrypted within the United Kingdom.

Audio Deletion: Raw audio used for Ambient AI transcription is deleted immediately following the processing of the transcript.

Security Measures: We implement industry-standard technical and organisational measures including encryption in transit (TLS) and at rest, access controls, multi-factor authentication for staff, audit logging, and obfuscation techniques to protect clinical records.

Data Breach Notification: In the event of a data breach affecting personal information, we will notify affected individuals and the relevant supervisory authority — the UK Information Commissioner's Office (for UK users) or the Office of the Australian Information Commissioner (for Australian users) — within the timeframes required by applicable law.

6. DATA RETENTION

We retain personal information for the following periods:

  • Patient account information: For the active life of the account, plus a reasonable period after deletion for legal and operational purposes.
  • Clinical records: Minimum 7 years from the last entry for adults, in line with medico-legal record-keeping obligations. Longer retention may apply for records concerning minors.
  • Raw audio (Ambient AI): Deleted immediately after transcription.
  • Telehealth session content: Not retained.
  • Payment and transaction records: 7 years for tax and audit purposes.
  • Marketing communications data: Until consent is withdrawn.
  • Customer support records: Up to 3 years.
  • Audit and security logs: Up to 2 years.

Retention periods may be extended where required by law, regulation, or to handle disputes.

7. RIGHT TO BE FORGOTTEN (DATA DELETION)

PhysiPal respects your right to have your data erased.

Patient Account Deletion: If a patient deletes their account, all data created or personally uploaded by that patient (e.g. Diary entries, exercise recordings they initiated) will be permanently deleted from our active databases.

Clinician Account Deletion: If a clinician chooses to delete their PhysiPal account, all associated clinical data will be purged from PhysiPal's servers. It is the clinician's sole responsibility to export or backup all clinical records required for their professional record-keeping obligations (typically 7–8 years) prior to account deletion. PhysiPal will not maintain or host records for deleted clinician accounts.

8. CHILDREN'S DATA

Where patients are under 18, processing of their personal and health data is undertaken with consent obtained by the treating clinician from a parent or legal guardian. PhysiPal does not knowingly collect personal data directly from children without appropriate authorisation by a treating clinician or guardian.

9. COOKIES & WEBSITE TRACKING

Our website uses cookies and similar technologies for essential site functionality, analytics, and (where you consent) marketing purposes. You can manage your cookie preferences via the cookie banner displayed on first visit and at any time through your browser settings. Non-essential cookies are only set with your consent.

10. YOUR RIGHTS (AUSTRALIA & UK)

Australia: We comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. You have the right to lodge a complaint with the Office of the Australian Information Commissioner at oaic.gov.au.

United Kingdom: We comply with the UK GDPR and Data Protection Act 2018. You have the following rights in relation to your personal data:

  • Right of access to your data
  • Right to rectification of inaccurate data
  • Right to erasure ("right to be forgotten")
  • Right to restrict processing
  • Right to data portability
  • Right to object to processing
  • Right to withdraw consent (where processing is based on consent)
  • Right not to be subject to solely automated decision-making
  • Right to lodge a complaint with the UK Information Commissioner's Office at ico.org.uk
How to Exercise Your Rights

To exercise any of these rights, contact us at hello@physipal.com.au. We will respond within one month, as required by UK GDPR. We may need to verify your identity before processing your request to protect the security of your data.

GDPR Article 27 Representative

As PhysiPal Pty Ltd is established outside the United Kingdom, we have appointed a UK Representative under Article 27 of the UK GDPR. UK users may contact our representative regarding any data protection matters:

Prighter Ltd
20 Mortlake High Street
London SW14 8JN
United Kingdom

Withdrawal of Consent: Where processing is based on consent (e.g. marketing communications, optional features, ambient AI transcription), you may withdraw consent at any time by contacting us at hello@physipal.com.au. Other lawful bases may continue to apply for processing necessary to deliver our services or meet legal obligations. Withdrawal of consent for certain processing activities may impact app functionality.

11. DATA PROTECTION OFFICER

Privacy enquiries may be sent to hello@physipal.com.au.

12. UPDATES TO THIS POLICY

This policy was last updated on 30/04/2026. We may update this policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Material changes will be notified via the app or by email to registered users.

13. CONTACT US

For data access, updates, support or deletion requests:

Email: hello@physipal.com.au
Post: PhysiPal PTY LTD, 174 Bridge Richmond 3121, Australia

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