Privacy policy

Apex Vitality Privacy Policy
Issued by: Vitalis 3.0 Pty Ltd (ABN 36 688 866 113)
Trading as: Apex Vitality
Effective Date: 1st January 2026

1. Introduction
Vitalis 3.0 Pty Ltd, trading as Apex Vitality (“Apex Vitality”, “we”, “us”, or “our”), is
committed to protecting your privacy and handling your personal information
responsibly, transparently, and in accordance with Australian law.
This Privacy Policy explains how we collect, use, disclose, store, and protect personal
information, including sensitive health information, in connection with our healthcare,
diagnostics, telehealth, coaching, digital platforms, and e-commerce services.
We comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles
(APPs).
Further information on privacy rights is available from the Office of the Australian
Information Commissioner (OAIC):
https://www.oaic.gov.au/

2. What Is Personal Information?
Personal Information is information or an opinion that identifies, or could reasonably
identify, an individual.
This may include:
• Name, date of birth, gender
• Contact details (email, phone number, address)
• Account and membership information
• Payment and transaction data
• Technical data (IP address, device, browser)
• Health, medical, diagnostic, biometric, or pathology information

3. How We Collect Personal Information
We collect personal information through:

• Online registrations and member portals
• Health questionnaires, diagnostics, consultations, and coaching
• Telehealth consultations (video, phone, digital messaging)
• Email, telephone, and written correspondence
• Website usage, cookies, and analytics tools
• E-commerce transactions
• Third-party providers you authorise (e.g. pathology services, practitioners)

We do not control and are not responsible for the privacy practices of authorised third-
party platforms outside our control.

4. Why We Collect Personal Information
We collect personal information to:
• Deliver healthcare, diagnostics, performance, and wellness services
• Provide personalised medical and coaching programs
• Facilitate telehealth consultations
• Manage memberships, accounts, and purchases
• Communicate with you regarding your care and services
• Meet clinical, legal, regulatory, and professional obligations
Secondary purposes may include:
• Service improvement and analytics (using de-identified data where possible)
• Education and content delivery
• Marketing communications (you may opt out at any time)
Where required, we obtain explicit consent, particularly for health information.

5. Sensitive Information (Including Health Information)
Sensitive information includes health and medical information.
We collect and use sensitive information only:
• For the primary purpose of providing healthcare or related services

• For directly related secondary purposes you would reasonably expect
• With your consent
• Where required or authorised by law
Enhanced safeguards apply to all health information.

6. Disclosure of Personal Information
We may disclose personal information to:
• Healthcare practitioners involved in your care
• Medical practitioner partners providing services via Apex Vitality
• Diagnostic laboratories, pharmacies, or allied providers you authorise
• Technology, hosting, analytics, and payment service providers
• Professional advisers (legal, accounting, compliance)
• Regulators or authorities where required by law
We do not sell personal information.
Where information is stored or processed overseas (e.g. cloud infrastructure), we take
reasonable steps to ensure compliance with Australian privacy standards.

7. Cookies, Analytics & Website Monitoring
Our website and digital platforms use cookies and tracking technologies to improve
performance and user experience.
We currently use:
• Google Analytics – to understand website usage and improve functionality
• Microsoft Clarity – to analyse user interactions (such as navigation patterns and
page behaviour)
These tools may collect:
• IP address
• Browser and device information
• Interaction data (e.g. pages viewed, time spent)
Data is used in aggregated or de-identified form where possible.

You can control cookies through your browser settings; however, disabling cookies may
affect website functionality.

8. Security of Personal Information
We take reasonable and appropriate steps to protect personal information from:
• Misuse, interference, and loss
• Unauthorised access, modification, or disclosure
Safeguards include:
• Secure and encrypted systems
• Restricted access controls
• Confidentiality obligations for staff and contractors
• Regular review of cybersecurity practices

9. Data Retention
Personal information is retained only as long as necessary for:
• The purpose it was collected
• Legal, clinical, and regulatory requirements
Health records are generally retained for a minimum of 7 years, or longer where
required by law.

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

10. Access and Correction
You may request access to, or correction of, personal information we hold about you by
contacting us in writing.
We may require verification of identity before releasing information.
There is no charge for access requests; however, a reasonable administrative fee may
apply for providing copies.

11. Accuracy of Information
We take reasonable steps to ensure personal information is accurate, complete, and up
to date.
Please notify us if your information changes or is incorrect.

12. Privacy Policy Updates
This Privacy Policy may be updated from time to time. The current version will always be
available on our website.

13. Privacy Enquiries and Complaints
Vitalis 3.0 Pty Ltd (T/A Apex Vitality)
Level 35, 477 Collins Street
Melbourne VIC 3000
Email: support@apexvitality.co
If you are dissatisfied with our response, you may contact the OAIC.

Telehealth Privacy Addendum
(Applies to All Telehealth Services)
A. Scope
This addendum applies to all telehealth services delivered by Apex Vitality, including:
• Direct-to-consumer telehealth consultations
• Telehealth services provided via our medical practitioner partners
• Digital communications relating to clinical care

B. Information Collected During Telehealth
Telehealth services may involve collection of:
• Health history and clinical information
• Consultation notes and assessments
• Diagnostic data and treatment plans
• Communications exchanged via telehealth platforms
We do not record consultations unless:
• You are informed in advance; and
• You provide explicit consent; or
• Recording is required by law

C. Telehealth Platforms & Security
We use secure, compliant digital platforms to deliver telehealth services.
Reasonable steps are taken to:
• Protect confidentiality
• Secure transmissions
• Limit access to authorised clinicians and staff only
However, no digital system is entirely risk-free, and telehealth carries inherent technical
risks.

D. Practitioner Partners
Where telehealth services are provided by medical practitioner partners:
• Information is shared only as necessary to deliver care
• Practitioners are subject to their own professional, ethical, and privacy
obligations
• Apex Vitality acts as a facilitator and platform provider where applicable

E. Your Responsibilities
You are responsible for:
• Ensuring privacy at your location during telehealth consultations
• Using secure internet connections where possible
• Advising us if you have concerns regarding telehealth privacy