Privacy Policy

Human Performance Coach (HPC) Privacy Policy

Virtual Psychologist Pty Ltd (“Virtual Psychologist”, “we”, “our” or “us”) is committed to protecting your privacy and handling your personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs) and applicable health privacy legislation.

This Privacy Policy explains how we collect, use, disclose and protect your personal information when you use the Human Performance Coach (HPC) platform, website and mobile application.

By accessing or using the HPC platform you agree to the collection and use of information in accordance with this Privacy Policy.

Who We Are

Human Performance Coach (HPC) is a digital wellbeing platform developed and operated by Virtual Psychologist Pty Ltd. The platform assists individuals and organisations to monitor, understand and improve physical and psychological wellbeing through coaching, assessments, wearable technology integration and digital health tools.

Information We Collect

Depending on how you use the platform, we may collect:

Personal Information

• Full name
• Email address
• Mobile phone number
• Date of birth or age range
• Gender (where provided)
• Organisation or employer (if applicable)
• Emergency contact information (where applicable)

Health and Wellbeing Information

Where you choose to use the platform, we may collect health information including:

• Psychological wellbeing assessments
• Mood check-ins
• Stress levels
• Sleep information
• Activity levels
• Heart rate
• Heart Rate Variability (HRV)
• Blood oxygen saturation (SpO2)
• Body temperature (where supported)
• Exercise data
• Recovery metrics
• Nutrition or lifestyle information you voluntarily provide
• Coaching notes
• Goals and progress tracking

Health information is considered sensitive information under Australian privacy law and receives additional protections.

Wearable Device Data

If you connect a wearable device or health platform (such as Apple Health, Google Health Connect, Garmin, Amazfit, Fitbit or similar providers), we may receive information that you authorise those services to share with us.

You remain in control of which wearable services you connect and may disconnect them at any time.

Technical Information

We may automatically collect:

• Device information
• Browser type
• Operating system
• IP address
• App usage statistics
• Crash reports
• Cookies and similar technologies
• Log files

How We Use Your Information

We use your information to:

• Provide the HPC platform and associated services
• Deliver personalised coaching and wellbeing insights
• Monitor wellbeing trends
• Generate reports and dashboards
• Support clinical and coaching services where applicable
• Improve platform functionality
• Respond to enquiries and support requests
• Verify your identity
• Meet legal and regulatory obligations
• Detect fraud or misuse
• Improve our products through quality assurance and analytics

Where artificial intelligence is used within the platform, it is designed to assist users and coaches by providing insights, summaries or recommendations. AI does not replace professional clinical judgement.

Employer-Sponsored Programs

If your employer or organisation provides access to HPC, they may receive reporting regarding program participation and aggregated wellbeing outcomes.

Unless you have provided explicit consent or disclosure is otherwise authorised or required by law, your employer will not receive your identifiable health information or counselling records.

Reports provided to organisations are generally aggregated and de-identified.

Sharing Your Information

We do not sell your personal information.

We may disclose information to:

• Healthcare professionals involved in your care (with your consent)
• Coaches or wellbeing practitioners providing services
• Cloud hosting providers
• Technology service providers
• Analytics providers
• Payment providers (where applicable)
• Professional advisers
• Regulators where legally required

We may also disclose information:

• where required by law;
• to respond to court orders;
• to protect someone's life, health or safety;
• where there is a serious and imminent threat;
• to investigate fraud or unlawful activity.

Overseas Disclosure

Some technology providers that support the HPC platform may store or process information outside Australia.

Where this occurs, we take reasonable steps to ensure overseas providers handle personal information in accordance with Australian privacy requirements.

Data Security

We take reasonable technical and organisational measures to protect your information, including:

• Encryption during transmission
• Secure cloud infrastructure
• Access controls
• Multi-factor authentication where appropriate
• Audit logging
• Regular security monitoring
• Staff confidentiality obligations

While we use industry-standard security practices, no internet transmission or electronic storage system can be guaranteed to be completely secure.

Data Retention

We retain personal information only for as long as necessary to provide services, comply with legal obligations, resolve disputes and enforce our agreements.

Health records may be retained for periods required under applicable Australian legislation.

When information is no longer required, it is securely destroyed or permanently de-identified.

Cookies and Analytics

Our website and platform use cookies and similar technologies to:

• maintain secure logins;
• improve website performance;
• understand how the platform is used;
• improve user experience.

You may disable cookies through your browser settings, although some platform functionality may not operate correctly.

Your Rights

Subject to applicable law, you may:

• request access to your personal information;
• request correction of inaccurate information;
• withdraw consent where processing is based on consent;
• request deletion of information where legally permitted;
• request that connected wearable services be disconnected;
• make a privacy complaint.

Requests can be submitted using the contact details below.

Children’s Privacy

The HPC platform is not intended for children under 16 years of age unless used with appropriate parental or guardian consent or as otherwise permitted by law.

Third-Party Services

The platform may integrate with third-party health platforms or wearable manufacturers.

Those services operate under their own privacy policies and terms. We encourage users to review the privacy policies of any connected services.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

The latest version will always be available on our website and the date of the most recent revision will appear at the top of this page.

Contact Us

If you have any questions about this Privacy Policy or wish to exercise your privacy rights, please contact:

Privacy Officer
Virtual Psychologist Pty Ltd
Email: privacy@virtualpsychologist.com.au
Website: virtualpsychologist.com.au

If you are not satisfied with our response to a privacy complaint, you may contact the Office of the Australian Information Commissioner (OAIC).