Privacy Policy

Privacy Policy - CHARLI

This Privacy Policy was last updated on 21 March 2024.

About this Privacy Policy
1. AI ASSOCIATES SPRING HILL PTY LTD ACN 673 723 254 trading as CHARLI Health (CHARLI, we, us or our) has implemented this Privacy Policy to provide information about what kinds of Personal Information we may collect or hold, how we collect, hold, use and disclose that Personal Information, choices you have regarding our use of that Personal Information, and your ability to access or correct that Personal Information. If you wish to make any inquiries regarding this Privacy Policy, you should contact us in any of the ways specified in paragraph 17.
2. From time to time, we may be related to other companies and entities (related entities). This Privacy Policy applies to the use of your Personal Information by us and by those related entities. A reference in this Privacy Policy to CHARLI, we, us or our is also a reference to those related entities.
About CHARLI
1. CHARLI is an innovative hybrid technology and real-world solution that provides evidence based information about important reproductive conditions, promotes lifestyle change and empowers geographically local and remote consumers to access lifestyle education and compressive care through data driven health insights.
2. CHARLI employs artificial intelligence to track patterns in self-logged user data, such as menstrual, fertility and pregnancy diaries and integrates with real world clinical management, therapeutics and support.
3. CHARLI consists of Integrated Health App (CHARLI app) and Virtual Health Clinic (CHARLI clinic) for reproductive health care.
Personal Information
1. "Personal Information" is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.
What Personal Information do we collect and hold?
1. The types of Personal Information we may collect about an individual will depend upon the nature of our interaction with them. Personal Information that we collect may include (but is not limited to) the following:

Types of personal information	This includes:
Identity information	Full name, age or date of birth.
Contact information	Email address, contact number and mailing or residential address.
Financial information	Payment information - Please see paragraph 4.2.
Socio-demographic information	Your age, gender, number of dependants, occupation and nationality.
Interaction information	Details of when you interact with us, including your interactions through telephone, CHARLI app, CHARLI clinic, web portal, when you raise an inquiry, complete a form, provide feedback or a complaint.
Digital information	Information you provide to us through CHARLI app, CHARLI clinic, and our website or use of our application and website, social media platforms or through other websites or accounts from which you permit us to collect information.
Marketing information	Information provided through surveys or when you enter any of our promotions or competitions.
Sensitive information	Health information you provide to us, including but not limited to information about your cycles and your fertility, information about your pregnancy, sexual and reproductive health, and any other information you chose to share with us through the CHARLI app and CHARLI clinic including information collected from a device you connect to the CHARLI app such as a Fitbit or Apple Watch.

We use payment processing services provided by Stripe to process any payments made through the app such as pre-payments made to CHARLI for the use of third party services offered through us. For example, when you use the app to book an appointment with a clinician, CHARLI will forward the pre-payment you make through the app to the respective clinician (minus our referral fee). The payment card information used to make such payment is handled directly by Stripe and is not stored by CHARLI. You can read more about how Stripe will use that personal information in its Privacy Policy available at https://stripe.com/au/privacy. CHARLI does not store or maintain access to any payment card information.
We collect and record Personal Information about individuals such as:
1. our customers, potential customers and their representatives
2. our investors
3. our medical providers and third party service providers
4. our suppliers and potential suppliers and their representatives, directors, partners, proprietors and shareholders
5. contractors and subcontractors and potential contractors and subcontractors and their representatives in relation to providing goods and services to us
6. our employees past and present, including applicants, and
7. any other person who comes into contact with CHARLI.
Generally, when providing our products and services, dealing with our personnel, or obtaining goods and services from our service providers, suppliers or contractors, we collect personal information directly from the relevant individual where reasonable and practicable.
We may also collect Personal Information about you from third parties and other sources such as:
1. your nominated representatives (including medical providers and experts you have a consultation with)
2. any device you connect to the CHARLI app to assist with collecting data about you such as a Fitbit or Apple Watch
3. publicly available sources of information, or
4. related entities, companies and businesses of CHARLI,

but we will only collect your Personal Information in this way if it is unreasonable or impracticable to collect this information directly from you or if we are otherwise permitted to do so.

In order to provide you with the CHARLI app and CHARLI clinic, we need to collect sensitive information, including health information and biometric information about you. We will ask for your consent to collect sensitive information, unless the law allows us to collect it without your consent.
Where we engage with you multiple times over a short period in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you.
If you choose not to provide your Personal Information to us for the purposes set out in this Privacy Policy, or if we do not or are unable to collect the Personal Information we require, we may not be able to provide you with requested information, products or services, or to effectively conduct our relationship with you.

Information collected via your devices
1. You will have the option via the CHARLI app to request that the app gathers information your device collects about you. For example, your Fitbit may measure your heart rate throughout the day and if you elect to have this device connected to the CHARLI app, such information will be stored on the CHARLI app and used by us to assist in suggesting potential diagnoses and appropriate medical providers for you. We may also disclose such information to medical providers if you book them through our app.
2. When you connect a device to the CHARLI app such as a Fitbit or Apple Watch, you are subject to the privacy policy and terms and conditions of that device when information is collected and stored on that device.
Information collected via our Website and applications
1. Personal information may be collected by us and by our third party service providers who assist us in operating our website at https://CHARLI.health/, including its subdomains and any other website we operate from time to time (collectively the Website) and the CHARLI app and CHARLI clinic.
2. We may use various technological methods from time to time to track the visiting patterns of individuals accessing our Website or using the CHARLI app and CHARLI clinic, including but not limited to the methods set out in this paragraph 6.

Google Analytics

We use Google Analytics to help analyse how you use our Website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated is used to create reports about the use of our Website. Google will store this information.
If you do not want your Website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout.

Cookies

Our Website may use 'cookies' from time to time. Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity, browser type or website visiting patterns. Cookies may be used on our Website to monitor web traffic, for example the time of visit, pages visited and some system information about the type of computer being used. We use this information to enhance the content and services offered on our Website.
Cookies are sometimes also used to collect information about what pages you visit and the type of software you are using. If you access our Website or click-through to our Website from a link in an email we send you, a cookie may be downloaded onto your computer's hard drive.
Cookies may also be used for other purposes on our Website.
You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.
If you disable the use of cookies on your web browser or remove or reject specific cookies from our Website or linked sites then you may not be able to gain access to all of the content and facilities in those websites.

Third party content (eg social media links)

Some of the content on our Website may include applications made available by third parties, such as social media buttons or links that allow you to share content or links to our Website through the relevant third party platforms. These third party applications themselves may facilitate collection of information by those third parties, through your interaction with the applications and sometimes even if you do not interact directly with them. We are not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant third party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal Information.

Why do we collect, use and disclose Personal Information?
1. We collect your Personal Information to allow us to conduct our business functions, to provide, market and sell our products and services and for the specified purposes set out below. In some circumstances the collection of Personal Information may be required by law.

Purpose	This includes:
Providing you with products and services	assisting you to create an account and use our products and services. managing and administering your existing products and services. enabling you to access and use our application and website including the portal. sending you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting. administering rewards, surveys, competitions, or other promotional activities or events sponsored or managed by us or our business partners. to enable us to suggest appropriate consultations that may be of interest to you based on the information you provide us. to identify critical dates in your menstrual cycle and during pregnancy.
Administering the CHARLI clinic	to enable us to suggest appropriate medical providers to you to based on information collected via the CHARLI app. to provide relevant information to your chosen medical provider to assist them to service you. facilitating your payment to your chosen medical provider.
Administering our products and services	maintaining the website, CHARLI app, CHARLI clinic and services you have with us. making and managing payments and transactions connected to your products and services. to enforce our rights under the contracts we have with you. managing complaints or feedback you may raise with us.
Servicing you as our customer	to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you. for business support services including maintenance, backup and audit.
Improving our offering	to operate, protect, improve and optimise our website, CHARLI app, CHARLI clinic, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing. we may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.
Conducting medical research	to conduct medical research about data you have included in the app about symptoms you are experiencing.
Protection and security	identifying you and to prevent, identify and assess suspicious or fraudulent activities. supporting out information systems security infrastructure and network controls to prevent unauthorised disclosures and cyber-attacks. to provide for the safety and security of workers and onsite visitors.
Complying with our legal and regulatory obligations	to verify your identity when you first acquire our products or services, and for subsequent verifications. to comply with our obligations or directions from law enforcement agencies, tax authorities, external dispute resolution schemes and other regulatory bodies. resolve any disputes we may have and to comply or enforce our third party agreements.
Employment-related purposes	to consider your employment application.

We may aggregate personal information for reporting, statistical and analysis purposes, and for business, product and service improvement purposes. This allows us to better inform ourselves and anticipate our customers' preferences and requirements, and to monitor and improve the effectiveness of our business, products and services. We may also de-identify information for inclusion in such aggregated databases or reports.
We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website, CHARLI app and CHARLI clinic or to retain the content of any user session.
You consent to us using your Personal Information in the above ways and as set out in this Privacy Policy.
We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is:
1. in accordance with this Privacy Policy or any agreement you enter into with us, or
2. required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth).

When do we disclose your Personal Information?
1. We may disclose, or provide access to, your Personal Information to third parties in connection with the purposes described in the table in section 7. Depending on the circumstances and the nature of your engagement with us, we may disclose your Personal Information to our related entities, to third parties that provide products and services to us or through us, or to other third parties (such as your referee(s) in connection with a job application you have submitted).
2. When you use the CHARLI clinic, we will make available to experts and medical providers you have selected for consultation, the information collected about you through the CHARLI app.
3. We may also disclose your Personal Information to:
  1. medical providers that you elect to service you
  2. any of our internal divisions, business units or departments
  3. your nominated representatives
  4. other organisations or individuals who assist us in providing products and services to you
  5. professional service providers and advisors who perform functions on our behalf, such as lawyers
  6. representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing goods or services or administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development)
  7. medical research agencies (see paragraph 12)
  8. auditors, business consultants and IT service providers, and
  9. Government, regulatory authorities and other organisations as required or authorised by law (such as Centrelink or the Police).
4. We may also disclose your Personal Information to our Website host or software application providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.
5. As we continue to develop our business, we may buy, merge or partner with other companies or organisations, and in so doing, acquire customer Personal Information. In such transactions, Personal Information may be among the transferred assets. Similarly, in the event that a portion or substantially all of our business or assets are sold or transferred to a third party, we may also disclose certain information including your Personal Information to a purchaser or potential purchaser in connection with the sale or potential sale of us, our business or any of our assets, including in insolvency.
Overseas disclosures
1. Some of your Personal Information may be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers. This may happen if:
  1. our offices or related entities are overseas
  2. we outsource certain activities overseas
  3. transactions, information, services or products have an overseas connection, or
  4. our computer systems including IT servers are located overseas.
2. You consent to the collection, use, storage, and processing of your Personal Information outside of Australia as set out in this Privacy Policy.
3. In particular, your Personal Information may be disclosed to third parties in the Netherlands and the US and such other countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in this Privacy Policy. In these circumstances, you consent to the collection, use, storage and processing of your Personal Information in those countries, without us being responsible under the Privacy Act 1988 (Cth) for such use (or for any breach). Where such parties are located overseas, you may have rights to enforce such parties' compliance with applicable data protection laws, but you might not have recourse against those parties under the Australian Privacy Act in relation to how those parties treat your Personal Information.
Other uses and disclosures
1. We may collect, use and disclose your Personal Information for other purposes not listed in this Privacy Policy. If we do so, we will make it known to you at the time we collect or use your Personal Information.
Marketing
1. You consent to us using your Personal Information for sending you information, including promotional material, about us or our products and services, as well as the products and services of our related entities and third parties, now and in the future. You also consent to us sending you such information by means of direct mail, email, SMS and MMS messages.
2. If you do not want to receive marketing information from us, you can unsubscribe in any of the following ways:
  1. changing your marketing preferences in the app
  2. clicking on the 'Unsubscribe' or subscription preferences link in a direct marketing email that you have received from us, or
  3. contacting us using the contact details specified in paragraph 17.
Medical Research
1. We may also use your Personal Information and Sensitive Information for medical research purposes but we will not do so without first obtaining your consent to each individual research project we undertake. If you do provide your consent to this, we may disclose your Personal Information and Sensitive Information to our third party medical research agencies to undertake research on our behalf using data we provide about you. You can chose to unsubscribe from being contacted about medical research by contacting us using the details specified in paragraph 17.
Storage and security of Personal Information held by us
1. We aim to keep your Personal Information secure. Any Personal Information that is collected via our Website or which is held on our computer systems is protected by safeguards including physical, technical (firewalls, SSL encryption etc) and procedural methods.
2. If we find that we no longer require or have no further need for your Personal Information we may de-identify it or remove it from our systems and destroy all record of it.
You can access and update your Personal Information
1. You are generally entitled to access Personal Information that we hold about you. If you request access to your Personal Information, in ordinary circumstances we will give you full access to your Personal Information. Depending on the nature of the request, CHARLI may charge for providing access to this information, however such charge will not be excessive. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Information, we will provide you with reasons for the refusal where we are required by law to give those reasons.
2. You can access and correct some of your Personal Information through the app by logging into your account and updating or editing your profile at any time. A request for access can be made by contacting us in any of the ways specified in paragraph 17.
3. We take all reasonable steps to ensure that any Personal Information we collect and use is accurate, complete and up-to-date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to keep it true, accurate, current and complete.
4. Please contact us in any of the ways specified in paragraph 17 if you believe that the Personal Information is inaccurate, incomplete or out of date, and we will use all reasonable efforts to correct the information.
5. It would assist us to ensure we properly understand your request, and allow us to respond more promptly, if requests are made in writing and include as much detail as possible.
How do we deal with complaints about privacy?
1. If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Policy, please contact us in any of the ways specified in paragraph 17 and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint.
2. It would assist us to respond to your complaint promptly if it is made in writing. Please detail information relevant to your complaint.
3. We will notify you of the outcome of our investigation.
Updates to this Privacy Policy
1. We may, from time to time, review and update this Privacy Policy, including to take into account new laws, regulations, practices and technology. All Personal Information held by us will be governed by our most recent Privacy Policy, posted on our Website at: http://CHARLI.healthwhere the Privacy Policy will be located. Any changes to this Privacy Policy may be advised to you by updating this page on our Website. We will aim to provide reasonable advance notice of such changes though this may not always be possible depending on the circumstances. We encourage you to check this page from time to time for any changes.
What to do if you have a question, problem or complaint, or want to contact us about our use of your Personal Information or this Privacy Policy
1. If you:
  1. have a query or concern about this Privacy Policy or our Personal Information handling processes
  2. wish to make a complaint in relation to a breach of your privacy
  3. would like to access your Personal Information held by us
  4. would like to update or correct your Personal Information held by us, or
  5. would like to opt out of direct marketing,

please contact us by emailing info@CHARLI.health.