Privacy Policy

In this Privacy Policy, 'us' 'we', 'our' or ‘Pair’ means Pair Pty Ltd (ACN 694 587 776) and any of our group companies.

This Privacy Policy sets out our commitment to protecting the privacy of your Personal Information provided to us, or otherwise collected, used, stored, handled or disclosed by us when providing our online platform and website (together, the Services) or when otherwise interacting with you in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth).

By using our Services, or in providing Personal Information to us, you consent to our collection, use, storage, handling and disclosure of your Personal Information in accordance with this Privacy Policy and any other arrangements that apply between us.

We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

In this Privacy Policy:

Where this Privacy Policy refers to “you” or “your”, it means any individual to whom this Privacy Policy applies, including Users and Clinicians, unless the context indicates otherwise.

We only collect Personal Information reasonably necessary to provide the Services, or for its functions or activities.

The type of Personal Information we collect depends on how you interact with the Services. By completing the Pairing Questionnaire, you consent to our collection and use of any health or other sensitive information you choose to provide for the purpose of providing the Services to you.

Users may access and complete our Pairing Questionnaire without registering for an account. When you complete the Pairing Questionnaire, we securely collect the following information:

• your age;
• suburb or postcode;
• preferences in relation to therapy services (including preferred session format, availability or areas of focus);
• information about the traits or characteristics you would like your therapist to have; and
• information about how you intend to fund therapy services, including whether you have private health insurance, access to Medicare rebates, or access to NDIS funding.

Depending on the information you choose to provide, your responses may include information about your mental health, wellbeing or treatment needs. This may constitute Sensitive Information under the Privacy Act.

At the point of completion, questionnaire responses are stored without direct identifiers and are associated only with a system-generated session ID. No name, email address or other direct identifying information is required to complete the Pairing Questionnaire.

We have designed the Pairing Questionnaire to minimise the collection of directly identifying information.

Users may choose to provide their email address if they wish to receive their pairing results by email. Where a User elects to do so, their email address will be collected for that purpose.

If you choose to contact a Clinician through the “email for appointment” function, you will be prompted to provide:

• your name;
• email address;
• any additional information relating to you that you choose to include in the message.

You may also choose to attach referral documentation or other supporting materials.

When you submit this form, the Clinician does not receive your Pairing Questionnaire responses, your match scoring, or any algorithm-generated data unless you choose to share that information separately.

Pair does not collect, receive or store clinical treatment records or therapy notes created by Clinicians in the course of providing professional services. Any health information shared directly with a Clinician is handled in accordance with that Clinician’s own privacy practices.

If you register as a Clinician on the platform, we collect Personal Information reasonably necessary to verify your identity, administer your account, facilitate payments and allow Users to contact you.

This includes:

• your title;
• name;
• date of birth;
• practice name;
• practice address(es);
• email address;
• phone number;
• website URL;
• profile photo;
• AHPRA registration number;
• AHPRA registration type;
• qualifications;
• areas of speciality;
• therapy modalities offered;
• populations served (adults, adolescents, etc);
• billing name;
• ABN; and
• payment method details.

You may also choose to provide:

• your cultural background;
• your faith;
• LGBTQIA+ identity; and
• languages spoken.

These fields are intended to improve match accuracy and support Users seeking culturally aligned care.

When you access or use the Services, certain information may be collected automatically for security, operational and performance purposes, including:

• your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information; and
• aggregated analytics data which includes page views, navigation flow through the Pairing Questionnaire, clicks on “email clinician” and “visit website”, and conversion metrics.

Some Personal Information we collect is Sensitive Information, including information about your ethnic origin, religious beliefs or affiliations, membership of a professional association, sexual orientation or health information.

We only collect Sensitive Information with your consent and only where reasonably necessary for the operation of the Services. We will only use Sensitive Information for the primary purpose for which it was collected, for directly related secondary purposes, or where required or authorised by law.

Certain professional information provided by Clinicians, including their name, professional registration number, qualifications and areas of practice, will be made publicly available as part of their professional profile.

Clinicians may also choose to include additional profile information, which may include Sensitive Information (such as sexual orientation or religious belief). By electing to include such information, Clinicians consent to its public display.

Clinicians may update or remove Sensitive Information included in their professional profile at any time through their account settings or by contacting us. Changes will apply on a prospective basis and will not affect information that has already been accessed or retained by third parties.

We collect Personal Information directly from you when you:

• complete the Pairing Questionnaire;
• use the “Email a Clinician” function;
• register as a Clinician;
• communicate with us;
• subscribe to updates or marketing communications;
• provide any additional information to us directly through our website or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
• complete customer surveys;
• otherwise interact with us in relation to the Services; or
• apply for a role with us.

We may collect, hold, use and disclose your Personal Information for the purposes set out below.

We may use the information we collect about you, including your Personal Information, to:

• respond to enquiries or support requests;
• operate, protect, improve and optimise our Services, business and our Users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
• to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
• to send 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;
• to comply with our legal obligations, resolve any disputes that we may have with any of our Users, and enforce our agreements with third parties;
• to fulfill any other purpose for which you provide it; and
• to consider your employment application.

We may use Personal Information collected from Users to:

• provide and operate the Pairing Questionnaire;
• generate Clinician pairing results; and/or
• facilitate communication between Users and Clinicians where a User chooses to contact a Clinician.

We may use Personal Information collected from Clinicians to:

• verify identity and professional registration status;
• administer Clinicians accounts;
• publish professional profiles on the platform;
• enable Users to contact Clinicians;
• facilitate billing and payment processes;
• communicate important administrative or regulatory information; and/or
• maintain, secure and improve the Services.

As described in section 3.d, certain information is collected automatically when you access the Services.

While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

We may also use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.

We may also use cookies to enable us to collect data that may include Personal Information. For example, where a cookie is linked to your account, it will be considered Personal Information under the Privacy Act. We will handle any Personal Information collected by cookies in the same way that we handle all other Personal Information as described in this Privacy Policy.

Where a specific preference manager or privacy setting is not available, you may be able to utilize third-party tools and features to further restrict our use of automatic data collection technologies. For example:

• some browsers may allow you to change browser settings to limit automatic data collection technologies on websites
• some email providers allow you to prevent the automatic downloading of images in emails that may contain automatic data collection technologies; and
• many devices allow you to change your device settings to limit automatic data collection technologies for device applications.

Please note that blocking automatic data collection technologies through third-party tools and features may negatively impact your experience using our Services, as some features and offerings may not work properly or at all. Depending on the third-party tool or feature you use, you may not be able to block all automatic data collection technologies, or you may need to update your preferences on multiple devices or browsers. We do not have any control over these third-party tools and features and are not responsible if they do not function as intended.

We and/or our carefully selected business partners may send you direct marketing communications and information about our Services. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (e.g. an unsubscribe link).

We may disclose Personal Information for the purposes described in this Privacy Policy to:

• our employees and related bodies corporate;
• third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and Services to you);
• professional advisers, dealers and agents;
• payment systems operators (e.g. merchants receiving card payments);
• our existing or potential agents, business partners or partners;
• our sponsors or promoters of any competition that we conduct via our Services;
• anyone to whom our assets or businesses (or any part of them) are transferred;
• specific third parties authorised by you to receive information held by us; and/or
• other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

We may disclose Personal Information to service providers located outside Australia (for example cloud hosting providers). Where we do so, we will take reasonable steps to ensure that the overseas recipient handles Personal Information in a manner consistent with the Australian Privacy Principles.

We may hold your Personal Information in either electronic or hard copy form. We take reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your Personal Information.

For example:

• questionnaire responses are stored without direct identifiers and are associated only with a system-generated session ID, if a User does not provide contact details, the responses remain de-identified;
• de-identified or pseudonymised responses are kept separate from personally identifiable User information;
• questionnaire and account data are stored in a secure cloud-hosted environment (including infrastructure hosted by Amazon Web Services (AWS)); and
• data is encrypted in transit using industry-standard encryption protocols (such as HTTPS/TLS).

While we take reasonable steps to safeguard Personal Information, no method of electronic transmission or storage is completely secure. Accordingly, we cannot guarantee the absolute security of your Personal Information.

We retain Personal Information only for as long as reasonably necessary to fulfil the purposes for which it was collected, including to provide the Services, comply with our legal and regulatory obligations, resolve disputes and enforce our agreements.

Where Personal Information is no longer required for these purposes, we will take reasonable steps to destroy or de-identify it, unless we are required or authorised by law to retain it.

If you are a Clinician and have created an account to access the Services, you are responsible for maintaining the confidentiality of your login credentials and for any activity that occurs under your account. You may delete your information through Account Settings or request that we delete your account.

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

You can access the Personal Information we hold about you by contacting us using the information below. Sometimes, we may not be able to provide you with access to all of your Personal Information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your Personal Information.

If you think that any Personal Information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.

If you would like to request deletion of your Personal Information from our records, please contact us using the information below.

If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your Personal Information, you can contact us using the details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.

For further information about our Privacy Policy or practices, or to access or correct your Personal Information, or make a complaint, please contact us at info@pairpsychology.com.