1. Who is We Lysn

1. We Lysn (A Noii Health Pty Ltd company), (“We Lysn”) (ABN 38 668 231 776) with our registered address at Gill Delaney Lawyers, 40/161 Castlereagh Street, Sydney NSW 2000, respect your rights to privacy and are conscious of the provisions of the Privacy Act 1988 (Cth) (“Privacy Act”).
2. The Privacy Act contains the Australian Privacy Principles (“APPs”) which covers areas including the collection, use, disclosure, quality and security of personal and sensitive Information. We are also conscious of the relevant health privacy principles under State and Territory legislation.
3. We Lysn owns and operates the Platform (“Platform”) and website on welysn.com (“Websites”) (collectively “Platform”).

2.  What do we do 

1. The Platform facilitates confidential access to digital health services, particularly telehealth and video consultation with registered health and wellbeing professionals. More specifically, this may include psychologists, social workers, counsellors, mental health nurses, psychiatrists, dieticians and coaches (collectively referred to as “Service Provider”).
   

3. Personal, sensitive and health information

1. There are legal and regulatory requirements for We Lysn to retain personal and sensitive  information. Personal information may include but is not limited to your name, signature, address, phone number, date of birth, internet protocol (IP) addresses, location information from a mobile device. 
2. The collection, use and disclosure of sensitive information has a higher level of privacy protection than other personal information and may include a person’s race, health information, ethnic origin, political opinions, membership of political, professional or trade associations, religious or philosophical beliefs, sexual preferences and criminal history.
3. As part of providing health and wellbeing services, We Lysn and our subsidiaries will access, collect, use, maintain, record, and store personal and sensitive information about you. This Privacy Policy outlines what information we collect about you and how we may use and disclose it, and the required steps we take in relation to security.
4. All references to personal information in this document include personal, sensitive and health information unless indicated otherwise
5. Information containing personal information is subject to strict  legal and regulatory obligations which requires We Lysn to take reasonable steps to destroy or de-identify personal information it holds once the personal information is no longer needed for any purpose for which it may be used or disclosed under the APPs, subject to law or court order to retain the personal information.
6. This Privacy Policy explains what information we collect about you, how we may use and disclose it, and the steps we take in relation to security.
7. If you have any questions we can be contacted regarding our this document or our Privacy Policy at:

Contact Person: Compliance Officer

Phone Number: 1800935976 (1800WELYSN)

Email: customerservice@welysn.com

Online: www.welysn.com

Postal Address: Level 1, 1-5 Link Road Zetland NSW 2017

4. Personal Information that We Lysn Collects

1. Personal information that We Lysn may collect, use, and store vary depending on the nature of our interaction with you and may include the following information:
2. Identifying and contact information such as your name, address, contact number and email, including telephone conversations with us, communication between We Lysn’s personnel, Service Provider and you, written and verbal communications;
3. If you are a client, We Lysn will be required to collect health information to provide you the services. Information that may be collected and stored may consist of the following: 
4. your past, present or future health or a disability (at any time), health records, health requirements; or expressed wishes about future provision of health services to you; or
5. Any past, present, or future telehealth or in-person health services provided or yet to be provided to you;
6. any past, present or future pharmacy scripts that have been dispensed or yet to be dispensed to you, and 
7. any referrals provided to We Lysn by you via the Platform or any information provided in the referrals that may include information you provide and/or by a referring doctor or provider, in the course of delivering services;
8. any information you provide through our Service Providers; 
9. Information collected to provide, or in providing, a health service which consists of your information or an opinion; 
10. genetic information about you in a form that is, or could be, predictive of the health of you or your genetic relative.
11. Other type of sensitive information such as: 
12. your gender at birth;
13. whether you are of Aboriginal or Torres Strait Islander descent.
14. We may also collect personal information about:
15. Your emergency contact, next of kin or carer;
16. Healthcare providers including doctors;
17. Employers;
18. Insurance policy number;
19. Any other information to help verify your eligibility to provide services.
20. Government identifiers such as Medicare numbers and individual healthcare identifiers; 
21. We Lysn may collect identified and/or de-identified information via cookies on the Platform. Cookies allow We Lysn to collect information about your computer which may include but not limited to as follows: 
22. We your IP address; 
23. type of browser; 
24. operating system; 
25. domain name; 
26. Any details of any website which has referred you to the Platform; 
27. frequency of visits, 
28. length of time you visit and stay on the Platform, 
29. track your identity; 
30. may include links to other websites that are being visited by you; 
31. recognize your computer while you are accessing the Platform and this information is used to maintain the quality of our service and to provide tracking and statistics regarding the use of the Platform.

5. Storage of Personal Information

1. In order to help prevent unauthorised access, use and disclosure, We Lysn is required to have reasonable procedures in place to help safeguard and secure the personal information that is collected. 
2. Currently, all personal information collected and stored is held on Amazon Web Services (AWS) cloud storage, and We Lysn currently stores all personal information collected on servers located in Australia. The information is accessible only to authorised We Lysn personnel or Service Providers in the provision of services
3. We Lysn takes reasonable steps to protect the personal information we hold from unauthorised access, use and disclosure by: 
4. Offering multi-factor authentication which requires two or more proofs of identity to grant you access; 
5. Conducting regular audits to assess We Lysn’s compliance with the Privacy Act and APP; 
6. We Lysn uses a combination of firewall barriers, encryption and authentication procedures to maintain the security of the Platform, protect your account and personal information. 
7. All information handled and stored in accordance with the Privacy Act and APP. 
8. We Lysn will take all reasonable steps to destroy your personal information, consistent with any legal requirements. 
9. By continuing to use this Platform you consent to storing your personal information in this manner.

6. Purpose of collecting, storing, holding and using personal information

1. We Lysn may collect, hold, use and disclose personal information for a range of purposes including the following:
2. to communicate with you;
3. if you provide your email address, telephone and/or mobile phone number, you also consent to We Lysn using your email address, telephone and/or mobile phone number to contact you (including by telephone call, SMS or email) for any of the above purposes; 
4. for record keeping purposes;
5. to enable a Service Provider to provide Services through the Platform;
6. as required for the ordinary operation of We Lysn Platform;
7. to manage, review, develop and improve We Lysn relationship with you
8. to manage, review, develop, and improve We Lysn services to you; 
9. to manage, review, develop your experience with We Lysn;
10. to provide you the functionality of the Platform; 
11. to inform you about important matters relating to the Platform or your personal information;
12. to conduct market research;
13. to invoice and process any fees payable in relation to the services rendered through the Platform;
14. for any purpose disclosed to you or required or authorised by or under law;
15.  for quality and assurance and training purposes and as may be required by We Lysn insurers;
16.  where there is a serious and imminent threat to an individual’s life, health or safety; or a serious threat to public health or public safety;
17. to payment system operators (e.g. Banks, Paypal, merchants who receive any credit card payments that We Lysn will use from time to time) and organisations who carry out credit, fraud and other security checks.
18. Health Information
19. If you are client, your sensitive and health information collected by us will only be used or disclosed as follows: 
20. to enable a Service Provider to provide services to you through the Platform;
21. to third party suppliers and Service Providers, and other providers for the operation of our Platform, Websites and/or our business or in connection with providing our Services to you;
22. to those who work for us, either an employee or contractor, our officers ad related body corporates;
23. to any relevant government authority, where we reasonably believe that such disclosure is necessary;
24. should a Service Provider form the professional opinion that a patient is at imminent risk of harm, including self-harm, and where it is consistent with the Service provider’’s professional ethical obligations to do so, to contact emergency services to request a welfare check or similar intervention;
25. to any entity with which we merge or proposed to merge, or by which we are acquired or proposed to be acquired or to which we may sell all or part of our business and assets; and
26. to enable us to comply with laws and assist government or law enforcement agencies where we are required and authorised to do so.
27. De-identified information may be used for quality assurance, service funding and evaluation, research and clinical supervision activities. In these instances, We Lysn and your Clinician will preserve and protect your privacy in accordance with the Privacy Act and APP.
28. If you do not provide us with the Personal Information about you that we request we may not be able to provide you with the services you request or require.
    

7. How your Information will be shared

1. We Lysn will share your personal information with our related bodies corporate (as defined in the Corporation Act 2001 (Cth)) to enable us to conduct our business, Platform, and our services.
2. We Lysn will also share your personal information with third parties engaged by us for the purposes such as data storage providers, IT support providers, and payment system operators.
3. We do not share your personal information with other healthcare providers who are not associated or affiliated with We Lysn or they are not your referring service providers or doctors, without your explicit consent.
4. For our financial obligations we are required to divulge limited personal information about you to our financial auditors. Wherever possible, personal information used for the purpose of our financial audit is de-identified.
5. If you are a client, please refer to 5.2 of this Privacy Policy for further information in relation to whom we may disclose your health information.
6. You acknowledge and agree that should we sell, merge or otherwise change control of our business, our company, the Platform to a third party, we shall be permitted to disclose your personal information to the third party without giving notice or seeking prior consent from you. We shall also be entitled to assist the benefit of any agreements we have with you to the third party.
7. We Lysn may disclose de-identified information to third parties for the purposes of reviewing the quality of services delivered and conducting clinical research.

8. Access and correction of your information

1. At any stage you may request to see the information that is stored in your file. 
2. You can ask We Lysn to correct or update your information and you can express your concerns or complaints to us about your privacy or the way we are handling your personal information. We take your concerns seriously and will consider or investigate your complaint and endeavour to respond to your complaint within 14 days.
3. We Lysn will amend any personal information about you which is inaccurate or out of date, however in some circumstances and in accordance with the applicable privacy laws, we may not permit you access to your personal information, or may refuse to correct your personal information, in which case we will inform you and about the reason for this decision.
4. In most instances the assigned Service Providers will be required to discuss the file contents with you before providing information, subject to the Privacy Act 1988.
5. All requests by clients for access to information or to exercise any of your rights in relation to personal information, please contact our Compliance Officer using the contact details in Clause 1.7 and provide your request in writing. We Lysn will endeavour to respond within 30 days and an appointment with a personnel or Service Provider may be required for clarification purposes

9. How to lodge a complaint

1. If you are not satisfied with the way we handle your query or handle your personal information you have a right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC) by visiting the OAIC website. If your complaint relates to the handling of your health information and you reside in Victoria, New South Wales, or Australian Capital Territory, you can lodge a complaint with the relevant State/Territory health complaints commissioner.
   

10. Other websites

1. The Platform may contain links to websites operated by third parties. We are only responsible for the privacy practices and security of our Platform. We recommend that you check the Privacy Policy, Terms of Use  and procedures of other websites you visit. 
2. Links that are provided are provided for convenience and may not remain current or be maintained. 

11. Consent

1. You do not have to consent to and provide your personal Information, however this may impact We Lysn’s capacity to provide services to you. However if you continue with your registration and check the consent box, you consent to the collection of your personal information as outlined in this Privacy Policy and you agree this information is reasonably necessary for one or more of We Lysn's primary purposes, activities and to assess and provide We Lysn's services and any other secondary purpose as required.

12. Updates

This Privacy Policy is effective from 9 May 2023.