Privacy Policy

1. About this Policy

Massage Mentor is operated by Therapeutic Touch Mastery Pty Ltd (ABN 12 684 156 643, ACN 684 156 643), trading as Massage Mentor (Massage Mentor, we, us or our).

This Privacy Policy explains how we collect, hold, use and disclose personal information in connection with:

• the Massage Mentor website, practitioner portal and mobile applications;
• booking, self-booking, intake, outcome, payment, receipt and unsubscribe links;
• practitioner, clinic, receptionist and administrative features;
• subscription management, customer support, security and internal administration;
• emails, local notifications and other communications; and
• associated services, content, integrations and features,

together, the Service.

We are subject to the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), the Notifiable Data Breaches scheme, and applicable State and Territory health-records laws.

Because the Service holds health information, privacy obligations may apply to Massage Mentor and its practitioner customers even where a small-business exemption would otherwise be available.

This Policy is not blanket consent. Where consent is required for a particular collection or use - especially sensitive health information - we or the relevant health practitioner will seek it separately. Short notices displayed at particular collection points supplement this Policy.

2. Who this Policy covers

This Policy applies to information about:

• sole practitioners, clinic owners and organisations subscribing to the Service (Customers);
• practitioners, receptionists, administrators and other authorised account users (Authorised Users);
• patients and clients whose information is collected through or entered into the Service (Clients);
• people who make bookings, complete intake forms, make payments, receive receipts, respond to outcome requests or use public links;
• website visitors and prospective customers; and
• people who contact our support, billing, security or privacy teams.

Client Records means personal information and health information concerning a Client that is collected through, entered into, generated by or stored in the Service for a Customer.

Third-party websites, app stores, payment services, calendars, speech-recognition services and sharing applications have their own privacy practices. This Policy does not replace their policies.

3. Our role and the Customer's role

3.1 Practitioners and clinics

The practitioner or clinic providing the health service generally determines:

• why Client information is collected;
• which clinical services it supports;
• which staff members may access it;
• the clinical decisions made using it; and
• how long the practice must retain its health records.

The practitioner or clinic is ordinarily the primary health-service provider and record holder for its Clients.

Customers must:

• provide Clients with appropriate collection notices;
• obtain valid consent or another lawful authority;
• collect only information reasonably necessary for the health service;
• ensure they are authorised to enter, import and share information;
• manage staff roles and clinic access;
• respond to Client record requests;
• protect exported information; and
• comply with applicable professional, privacy, health-record, consent, child-safety and retention requirements.

3.2 Massage Mentor

Massage Mentor holds and processes Client Records to operate, secure, support and administer the Service.

We also independently determine limited handling necessary for authentication, billing, fraud prevention, security, legal compliance and administration. Nothing in our agreement with a Customer removes our own obligations under privacy or health-records law.

Clients will usually receive the quickest and most informed response by contacting their treating practitioner or clinic. They may also contact us where the request concerns Massage Mentor's handling or the practice cannot be reached.

3.3 Clinic accounts

A clinic Customer may make Client Records, calendars, appointments, histories, outcomes and related information available to clinic members.

Access depends on assigned role and clinic configuration. For example:

• owners and authorised administrators may manage members, availability, calendars and practice reports;
• practitioners may access their own and authorised clinic-shared Clients and clinical records;
• reception staff may access identity, contact and scheduling information needed for their role; and
• revenue reporting may be restricted to the clinic owner.

Customers must configure and periodically review permissions and promptly remove or restrict access when a person changes role or leaves.

Where a practitioner elects to adopt or share existing private Client records into a clinic, those records may become clinic records. They may remain with the clinic after the practitioner leaves where the clinic is the lawful record holder or retention is required. Massage Mentor does not determine ownership or custody disputes between clinics, practitioners and Clients.

4. Information we collect

4.1 Account and practitioner information

We may collect:

• name, email address, telephone number and hashed account credentials;
• email verification, password-reset and account-recovery information;
• two-factor authentication status, secrets and recovery codes;
• Apple or Google sign-in identifiers and information released under the user's provider settings;
• practice or clinic name, address, timezone, ABN and contact details;
• provider number, qualification, professional association and professional role;
• offered services, fees, availability, blocked time and booking preferences;
• clinic memberships, invitations, assigned roles and administrative status;
• subscription, trial, billing interval, renewal and seat information;
• payment and Stripe account status;
• communication preferences;
• accepted Terms and Privacy Policy version, date, IP address and device information;
• product feedback and survey responses; and
• correspondence with us.

We do not receive a user's Apple or Google password.

4.2 Client identity and contact information

Client Records may include:

• name, phone number and email address;
• date of birth, age, gender or sex and address;
• occupation;
• emergency-contact details;
• communication and reminder preferences;
• general practitioner, referrer or treating-provider details;
• health-fund name and membership number;
• Medicare number or another government-related identifier where lawfully necessary;
• workers-compensation insurer and claim number; and
• historical visit counts and dates.

We do not adopt Medicare numbers or other government identifiers as Massage Mentor account identifiers. They must only be collected, used or disclosed where permitted by law.

4.3 Health and clinical information

Client Records may include sensitive information such as:

• current and historical symptoms, injuries and health conditions;
• pain type, location, side, intensity, onset and duration;
• body-region selections made using the generic three-dimensional body interface;
• pregnancy, pacemaker and contraindication information;
• mobility, range-of-motion, strength and other observations;
• treatment goals, preferences and requested areas of focus;
• free-text intake information and clinical notes;
• practitioner assessments, cautions, referrals and waivers;
• proposed and delivered techniques, body regions, timing and treatment plans;
• consent records, including treatment-specific consent where enabled;
• appointment, attendance, cancellation and treatment history;
• before-and-after measures, outcomes and follow-up responses;
• ratings, Net Promoter Score responses and comments;
• plan feedback and practitioner observations; and
• associated invoices and receipts.

The three-dimensional interface records selections against a generic diagram. It does not scan a Client's body or create a biometric body image.

4.4 Booking and public-intake information

When a person uses a booking, intake, payment, feedback or other public link, we may collect:

• the link or token and its validity;
• selected clinic, practitioner, service, date and time;
• contact and identity details;
• body-region, pain, goal, note and safety information;
• consent and communication choices;
• submission time, IP address and browser or device information;
• booking conflicts, confirmation, cancellation and attendance status; and
• information needed to associate the submission with the relevant practice and Client Record.

A private or one-time link should only be used by its intended recipient and should not be forwarded without authority.

4.5 Treatment and outcome information

The Service may generate or store:

• evidence-ranked treatment suggestions;
• filters, cautions and safety prompts;
• suggested timing and technique order;
• practitioner modifications and final selections;
• completed session information;
• treatment outcomes and Client responses; and
• authorised practice insights derived from the information.

4.6 Payments, subscriptions and invoices

We may collect or receive:

• billing name, email address and billing address;
• subscription plan, price, currency, tax status, trial, renewal and payment status;
• Stripe customer, connected-account, payment, checkout, terminal or transaction identifiers;
• payment method and limited card metadata, such as card brand and last four digits, where Stripe supplies it;
• failed-payment, refund, dispute and chargeback information;
• connected-account onboarding and identity-verification status;
• business, merchant, terminal and Tap to Pay information;
• invoices, receipts, service items, provider details, amounts, GST status and payment method; and
• payment webhook and settlement metadata.

Payment information entered into Stripe-hosted or Stripe-powered forms is ordinarily sent directly to Stripe. Massage Mentor is not designed to receive or store complete card numbers, card security codes, payment PINs or online-banking credentials.

Stripe independently collects payment, bank-account, identity, fraud, location and device information under its privacy terms.

4.7 Technical, security and usage information

We may collect:

• IP address and approximate location derived from it;
• browser, device, operating system and application version;
• account, session, clinic and device identifiers;
• authentication and session information;
• dates, times and durations of requests;
• functions and endpoints used;
• synchronisation status and technical performance;
• errors, diagnostics, audit and security events;
• actions taken on records, including actor, time, action and record identifier;
• email-delivery, booking-link and notification status;
• cookies, local-storage and anti-forgery token information; and
• information needed to investigate faults, abuse or security incidents.

Product analytics may include appointments, cancellations, no-shows, rebooking, treatment outcomes, pain relief, ratings, Net Promoter Score, revenue, body-region trends and practitioner or clinic performance. These are operational practice insights, not behavioural advertising profiles.

We do not currently use third-party advertising cookies or behavioural advertising analytics in authenticated clinical flows.

4.8 Imports and generated files

The Service may process:

• CSV, TSV, text or spreadsheet Client imports;
• original filename, source, column mapping, preview, import status and provenance;
• selected phone contacts reduced to name, email and phone;
• generated receipt PDFs;
• bulk Client-record exports; and
• files handed to printing or sharing destinations chosen by a user.

Massage Mentor does not currently provide general-purpose Client photo, document, treatment-audio or video attachment storage.

5. Device permissions and external destinations

If an Authorised User enables a feature, the app may request:

• Contacts: the device contact picker may read available names, phone numbers and email addresses locally. Only selected contacts are intended to be uploaded. The Customer must have authority to import them.
• Calendar: the Service may write an appointment containing a Client or appointment label and appointment notes to the device calendar. That calendar may sync to Google Calendar, iCloud, Outlook or another provider.
• Microphone and speech recognition: dictation uses the device or operating-system speech service. Apple, Google or another platform provider may process audio depending on the device, language and settings. Massage Mentor does not intentionally retain raw dictation audio on its servers. A saved transcript becomes part of the relevant clinical note.
• Location: Stripe Terminal or Tap to Pay may require device location for terminal discovery, payment, fraud-prevention or regulatory purposes. Location may be supplied to Stripe or the device platform. We do not use precise location for advertising.
• Notifications: appointment information may appear on a lock screen depending on device settings.
• Sharing and printing: an exported file, receipt, payment link, booking link or invitation may be passed to email, messaging, cloud-storage, print or other applications chosen by the user.

Permissions can be withdrawn through device settings, although the relevant feature may stop working. Withdrawal does not delete information already saved or shared.

6. How information is collected

We may collect personal information:

• directly from Customers and Authorised Users;
• from Clients completing public forms;
• when a Customer enters, imports, synchronises or generates a Client Record;
• from selected contacts or calendar features;
• from Apple, Google, Stripe, Postmark or another enabled provider;
• from the Australian Business Register or another public register;
• through support and billing communications;
• automatically through essential cookies, logs and app operation;
• from authorised clinic administrators; and
• by generating service outputs from information already supplied.

Customers must not import personal information from another system unless they have authority and have satisfied applicable notice and consent requirements.

7. Why we handle information

We may collect, hold, use and disclose information to:

• create, authenticate and secure accounts;
• administer clinics, roles, invitations and permissions;
• synchronise authorised local and server data;
• manage bookings, calendars and availability;
• collect public booking and intake submissions;
• maintain Client contact, clinical and treatment records;
• generate treatment suggestions, timing, cautions and safety prompts;
• record consent, treatments, outcomes and feedback;
• send confirmations, reminders, outcome requests, security messages and receipts;
• prepare invoices, reports and authorised exports;
• process subscriptions and facilitate practice payments through Stripe;
• provide support and investigate faults;
• prevent fraud, misuse and unauthorised access;
• improve reliability, performance, accessibility and usability;
• enforce our Terms and protect legal rights;
• handle access, correction, complaint and deletion requests;
• meet health-record, tax, court, regulatory and other legal obligations;
• investigate and respond to security incidents; and
• create genuinely de-identified or aggregated information for service analysis and improvement.

We do not sell or rent Client health information or disclose it for third-party behavioural advertising.

We do not use identifiable Client Records, dictation transcripts or health information to train publicly available or general-purpose generative AI models. A materially different future model-training use would require a fresh privacy assessment, notice and any consent required by law.

Information may be used in genuinely de-identified form only where there is no reasonable likelihood of re-identification.

8. Sensitive information and consent

Health information is sensitive information.

We collect it only where:

• the individual has consented and collection is reasonably necessary;
• the Customer confirms it has consent or another lawful authority;
• collection is required or authorised by law; or
• another privacy or health-records exception applies.

Consent must be informed, voluntary, current and sufficiently specific. Health-data processing, marketing, optional outcome contact and any future AI-training use must not be combined into one blanket consent.

Consent may be withdrawn for future optional handling. Withdrawal does not invalidate previous lawful processing and does not require destruction of records that must be retained.

9. Required information and anonymity

Some information is necessary to:

• operate an account;
• identify a Client accurately;
• maintain a safe clinical record;
• complete a booking;
• process a payment;
• issue a receipt; or
• meet legal requirements.

If it is not provided, the corresponding feature may not be available.

People can browse general website information without identifying themselves. It is generally impracticable to maintain a personalised clinical record, booking, receipt or payment anonymously. Clients may ask their practitioner whether pseudonymous treatment is lawful and clinically appropriate.

10. Automated processing and the treatment engine

Massage Mentor's current treatment engine is deterministic clinical decision-support software, not a general-purpose generative AI chatbot.

It may use:

• selected body regions and sides;
• pain type, intensity and onset;
• treatment goals and session duration;
• pregnancy, pacemaker and contraindication information;
• practitioner selections and service settings;
• relevant history and outcomes; and
• authored rules, evidence rankings and catalogue information.

It may rank or filter techniques, allocate suggested time, display cautions and generate a draft treatment plan. A qualified practitioner must independently review, modify or reject the output and make every final clinical decision.

We do not currently make a solely automated diagnosis, treatment decision or decision determining a Client's legal rights. We will update this section if materially different automated decision-making is introduced.

11. Disclosures

We may disclose information to:

• the relevant Customer and authorised clinic users;
• a Client or authorised representative;
• employees and contractors with a need to know and appropriate confidentiality duties;
• service providers identified below;
• banks, card networks and payment participants;
• professional advisers, auditors and insurers;
• courts, regulators, government bodies and law enforcement where authorised or required;
• persons involved in responding to a serious threat or emergency where permitted;
• another recipient authorised by the relevant individual or Customer; and
• a proposed or actual purchaser or successor, subject to confidentiality and lawful handling.

We do not permit unrelated Customers to access one another's Client Records.

11.1 Main providers

Providers and locations may change. We will update this Policy where a change materially affects personal-information handling.

12. Overseas processing

Personal information, including Client health information, may be stored or processed outside Australia. The primary known country is the United States.

Stripe, Google and Apple may also process information in other countries used by their subprocessors.

Where APP 8 applies, we will take the reasonable steps required by law. These may include provider diligence, contractual protections, access restrictions and data minimisation. Use of the Service is not treated as a blanket waiver of our cross-border obligations.

Overseas privacy and disclosure laws may differ from Australian law. Email and internet routing can also involve additional countries.

13. Direct marketing

We may market Massage Mentor to a Customer where consent has been given or marketing is otherwise lawful.

Marketing messages will:

• identify the sender;
• contain valid contact information; and
• provide a functional unsubscribe method.

We will ordinarily action unsubscribe requests within five working days. A minimal suppression record may be retained to ensure the person is not contacted again.

Booking confirmations, reminders, payment receipts, security notices and account messages are service communications, not general advertising. Optional Client reminders and outcome messages can be managed through the relevant practice where available.

We do not disclose Client health information to unrelated businesses for direct marketing.

14. Cookies and local storage

The site and portal use necessary cookies or similar storage to:

• establish and maintain sessions;
• prevent cross-site request forgery;
• preserve security and essential preferences;
• operate booking and intake features; and
• support bot and network protection.

Blocking essential cookies may prevent features from working.

YouTube, Stripe, Google or Apple may use their own cookies or device technologies when their features are opened.

The mobile app uses secure operating-system storage, an encrypted designated local database and other application storage to support authentication and local-first operation. Some Client information can therefore reside on an authorised device.

Signing out may not immediately remove every local copy. Account switching, clearing application data, uninstalling the app, device management and the Service's retention processes may affect those copies.

We do not currently use advertising cookies or third-party behavioural advertising analytics. If that changes, we will update our notices and obtain consent where required.

15. Security

We take reasonable steps to protect information from misuse, interference, loss and unauthorised access, modification or disclosure.

Measures used in or around the Service include:

• TLS protection for supported network communications;
• authentication and session controls;
• account, clinic and role-based access restrictions;
• secure operating-system storage for supported credentials and tokens;
• an encrypted designated on-device database for synchronised records;
• Stripe-hosted payment-card handling;
• expiry and access controls for certain public links;
• security review, testing and remediation; and
• purpose-limited personnel access.

Security differs across servers, devices, temporary storage, integrations and third-party services. No internet service is completely secure, and this Policy is not a guarantee that an incident cannot occur.

Customers must protect devices and accounts with appropriate passcodes, updates, email security, access reviews and lock-screen settings. They must protect exported files and promptly remove departing staff.

Report a lost device, compromised account or suspected incident to support@massagementor.com.au.

16. Retention and destruction

We retain information only as long as reasonably required for its purpose, a lawful Customer instruction, or health-record, tax, payment, dispute, insurance, limitation-period and other legal obligations.

Cancellation does not automatically erase clinical records. They may need to be exported, returned, archived, restricted, de-identified or retained.

When information is no longer required, we will take reasonable steps to destroy or de-identify it. Deletion may be delayed by legal holds, retention requirements or restricted backup cycles.

17. Access, correction, export and deletion

Individuals may request access to information we hold and correction of information that is inaccurate, incomplete, out of date, irrelevant or misleading.

Clients should usually contact their practitioner or clinic first. We may coordinate with that practice where appropriate. Clients can contact us directly where the request concerns our handling or the practice cannot be reached.

We may:

• verify identity and authority;
• ask for enough information to locate the record;
• provide access in a reasonable form;
• preserve the original clinical entry and attach a correction or statement;
• charge a reasonable access cost only where law permits and after notice; or
• refuse or limit a request where law permits, with reasons and complaint options where required.

We aim to respond within 30 days where practicable. A different statutory health-record period applies where required, including generally up to 45 days for access and 30 days for correction under Victorian health-record law.

Australian law does not provide an unrestricted right to erase every health record. Information may remain where required for health records, tax, payments, fraud, disputes, legal holds, unsubscribe suppression or restricted backups.

Where full deletion is unavailable, we will consider correction, restriction, archival, return or de-identification.

18. Children and young people

Practitioner and clinic accounts are restricted to adults able to enter a binding agreement.

The Service may hold information about a Client under 18. The Customer must determine:

• whether the young person has capacity to consent;
• whether parent or guardian authority is needed;
• which notices must be provided;
• who may access the record; and
• the applicable retention period.

A person under 18 should use a public booking or intake feature only in accordance with the practice's instructions and with guardian involvement where required.

We do not use children's health information for advertising or general-purpose AI training.

19. Data breaches

We will assess and respond to unauthorised access, disclosure or loss as required by law.

Where an incident is an eligible data breach under the Privacy Act, we will notify the OAIC and affected or at-risk individuals, or publish a notice, as required.

Where Client Records are involved, we may coordinate with the relevant Customer so Clients receive accurate information and support. Nothing in that coordination removes our own legal obligations.

20. Complaints

Privacy complaints should be sent to:

Privacy Officer

Therapeutic Touch Mastery Pty Ltd

ABN 12 684 156 643 / ACN 684 156 643

Hampton Park VIC 3976, Australia

support@massagementor.com.au

Please provide sufficient detail without emailing unnecessary health information. We may verify identity or authority.

We will investigate fairly and aim to provide a substantive response within 30 days.

Unresolved complaints may be made to:

• the Office of the Australian Information Commissioner;
• the Health Complaints Commissioner Victoria where applicable; or
• the relevant State or Territory health-privacy regulator.

21. Changes

We may update this Policy as our Service, providers or legal obligations change.

Material changes will receive reasonable notice through the Service, email or another appropriate channel. A policy update alone will not be treated as consent to a new purpose that legally requires separate consent.

Earlier versions may be requested from us.

22. Contact

Privacy Officer

Therapeutic Touch Mastery Pty Ltd

ABN 12 684 156 643 / ACN 684 156 643

Hampton Park VIC 3976, Australia

support@massagementor.com.au