Suite 502, Level 5, 492 St Kilda Rd, Melbourne 3004
+61 (0) 3 9534 7222

GoShare Privacy Policy

HEALTHILY – GOSHARE HEALTHCARE APP PRIVACY POLICY

The GoShare Healthcare web application (App) and GoShare Voice Artificial Intelligence software

(Software) is owned and operated by Healthily Pty Ltd ACN 78 613 342 635 (Healthily, We or Us).

GoShare is a platform for the distribution of health and lifestyle resources.

Healthily is committed to ensuring that your privacy is protected. This Privacy Policy describes how

Healthily collects, uses, discloses and stores your personal information when you use or receive

information from the App and/or the Software. We encourage you to read this Privacy Policy

carefully and contact us at goshare@healthily.com.au if you have any questions.

The App enables your health practitioner to send you information. The Software enables you to

interact with a digital assistant that will provide you with and confirm healthcare appointments and

other administrative services.

Personal Information is any information about you where your identity is apparent or can reasonably

be ascertained from the information. The Personal Information collected by Healthily when you use

or receive information from the App is limited to your name, email address and phone number and

when you use or receive information from the Software it is limited to your name and phone number.

We also record which health and lifestyle resources you wish to receive.

Sensitive Information is a subset of Personal Information which contains information or an opinion

about your racial or ethnic origin, political opinions, membership of a political association, religious

beliefs or affiliations, philosophical beliefs, sexual preferences or criminal records. Sensitive

Information also includes any of your health information.

This Policy explains the key measures we have taken to implement the requirements of the Privacy

Act 1988 (Act), the Australian Privacy Principles and where applicable, other data protection laws

such as the European Union General Data Protection Regulations (GDPR). This Privacy Policy covers

any Personal Information collected or received by Healthily as a result of your use of the App or your

health practitioner’s use of the App to send you information with your consent, or your interaction

with the Software, or your health practitioner or healthcare clinics’ use of the Software.

By using the App or the Software, you are agreeing that Healthily may make use of the information

we collect from you, including your Personal Information, in accordance with this Privacy Policy.

We endorse fair information handling practices and use of information in compliance with our

obligations under the privacy laws in force in Australia from time to time. Any information provided,

including identification of individuals, will be used only for the purpose/s intended or authorised and

where the intention includes confidentiality, information will be treated as such unless otherwise

required by law.

Healthily may change this Privacy Policy by updating this page from time to time. Any update to this

Privacy Policy will be effective from the date that it is posted on the App or on our

website, healthily.com.au (Site). You should check this page occasionally to ensure that you are

familiar with any changes.

1. USE AND DISCLOSURE OF PERSONAL INFORMATION

Collection of Personal Information

We may collect Personal Information about you when: a health practitioner uses the App to provide you with health and lifestyle information, with

your permission;

you click on the unique URL created for you by the App to access health and lifestyle

information;

a health practitioner or health clinic uses the Software to provide administrative assistance

including enabling a digital assistant to contact you to provide or confirm information or

appointments, with your permission; or

you provide Personal Information when engaging with the digital assistant.

The Personal Information we may collect is limited to:

in relation to the use of the App and the Software, your name and your mobile number,

in relation to the use of the App, your email address; and

in relation to the use of the Software, any other Personal Information you choose to provide

during an interaction with the digital assistant.

It is your responsibility to keep your information up to date with us. Should you wish to alter your

Personal Information, please advise your healthcare provider or notify us in accordance with section 6

of this Policy.

Healthily will not collect or use Sensitive Information when you use or receive information from the

App other than information about the health or lifestyle resources you want to receive.

As a result of the nature of the Software and the services it provides, being an artificial intelligence

digital assistant, Healthily may collect and store Personal Information, including Sensitive

Information, that you provide to the digital assistant using the Software. If this occurs, that Personal

Informational will be handled in accordance with this Policy.

Use of Personal Information – the App

We may collect, use and disclose your Personal Information:

for the purpose of providing the services you have requested to you;

for the purpose of providing health, lifestyle and related resources to you; and

any other purposes required or authorised by law.

Healthily may also disclose your Personal Information to its agents or sub-contractors for the above

purposes, always on the condition that the agent or sub-contractor in question will be obliged to use

that Personal Information in accordance with the terms, and subject to the disclaimers and limitations

disclosed in this Privacy Policy.

Healthily may also use deidentified information for:

the compilation and analysis of statistics relevant to public health and safety and complying

with our legal obligations; and

for purposes connected with the operation, administration, development or enhancement of

the App.

Use of Personal Information – the Software

Healthily will only collect, use and store Personal Information received from use of the Software for

the purposes of enabling use of the Software by you, your healthcare practitioner and healthcare

provider.The Software enables interactions between you and the digital assistant to be recorded for quality

control purposes. The recordings (audio and transcript), including any Personal Information that may

be contained in the recordings, will be stored by Healthily in accordance with this Policy. Healthily

will not access or use any Personal Information contained in those recordings. The recordings are

disclosed to your healthcare clinic and healthcare practitioner in accordance with this Policy.

Healthily will not use your Personal Information to enable direct marketing to you.

If we collect information about you from a third party that is not referred to in this Policy, we will

determine whether we could have lawfully collected that information directly from you and, if not,

we will destroy or de-identify that information (provided it’s lawful to do so).

If we receive unsolicited Personal Information about you, we will ensure it is protected and secure in

the same way that we treat Personal Information that we do intend to collect. If such Personal

Information would not have otherwise been collected by us in accordance with this Policy, we will

de-identify that information (provided it’s lawful to do so).

Any complaints relating to the treatment of your Personal Information or breach of the relevant

privacy laws in force in Australia from time to time should be directed to Healthily’s complaint

management facility at goshare@healthily.com.au. We will respond to every email within a

reasonable time period. We will endeavour to resolve all complaints as soon as possible.

We will keep your Personal Information for as long as it is required to provide you with our services

and to comply with legal requirements

If we no longer require your Personal Information for any purpose, including legal purposes, we will

take reasonable steps to securely destroy or permanently de-identify your Personal Information.

If you no longer wish to receive communications from us, please use the unsubscribe link contained in

all of our email communications or replying “STOP” to any SMS message. Alternatively, you may

contact our Privacy Officer.

2. INFORMATION SHARING AND DISCLOSURE

Healthily may disclose Personal Information to a related body corporate or an unrelated third party as

set out in this Privacy Policy or otherwise, if your consent has been granted for such disclosure.

Healthily does not rent, sell, or share Personal Information about you with third parties or non-

affiliated companies, except to provide products or services requested by you and otherwise in

accordance with this Privacy Policy.

In addition to the uses set out above, by proceeding to use the App and/or the Software, you consent to

disclosure of your Personal Information as follows:

to your healthcare clinic and/or healthcare practitioner;

to a trusted partner who works on behalf of or with Healthily under confidentiality

agreements (Service Partner);

to a Service Partner who requires access to your Personal Information to help Healthily

communicate with you, eg: an email service (the Service Partner will not have the

independent right to share, use or sell Personal Information or to contact you regarding any

matter not related to Healthily). If the Service Partner requires you to leave the App, e.g.

Stripe, you will be subject to the Service Partner’s privacy policies and Healthily takes no

responsibility or liability for such third party privacy policies. We encourage you to read their

terms and policies; as required under a subpoena, court order, or legal process, or in order to establish, exercise or

defend Healthily’s legal rights or otherwise as required by law;

in order (in the reasonable opinion of Healthily) to investigate, prevent, or take action

regarding illegal activity, suspected fraud, situations involving potential threats to the physical

safety of any person, or violations of Healthily’s Terms and Conditions;

in order to enforce our Terms and Conditions; and

in order to investigate or resolve complaints against or involving Healthily which raise civil

liabilities and to aid any government agency in any investigation circumstances.

For the purposes of the Software, a Service Partner includes but is not limited to:

Amazon Web Services;

Kore.Ai;

Twilio or Whispir; and

Stripe.

When we share information with other organisations and service providers as set out above, we do so

in accordance with this Policy. To the extent that these organisations and service providers gain access

to Personal Information, their use is governed by their own privacy policies, the Act, GDPR and any

other relevant law. Healthily will not disclose any Personal Information it collects through the

Software except to your healthcare clinic or healthcare practitioner.

In the event that the App and the Software are sold by Healthily, the data, including your Personal

Information may be transferred to the purchasing entity which would be bound to comply with

the Privacy Act 1988 in relation to the access, storage and use of your Personal Information. Further,

in circumstances where Healthily is sold or merged with another entity, the data, including your

Personal Information, may be transferred to the purchasing entity, which would be bound to comply

with the Privacy Act 1988 in relation to the access, storage and use of your Personal Information.

Your Personal Information would not be disclosed to a buyer in either circumstance, other than as a

part of the transfer of all data related to the App to that buyer.

3. CONFIDENTIALITY & DATA SECURITY

All Personal Information collected by the App and the Software is stored on secure AWS servers in

Australia.

We take all reasonable steps to manage data stored on our servers to ensure data security and to

prevent the loss, misuse or alteration of your Personal Information.

Access by Healthily’s employees or contractors to your Personal Information will be restricted to

circumstances where we reasonably believe such access is needed in order to provide products or

services to you. Any access provided by employees or contractors will be restricted to the minimum

necessary for them to perform their jobs.

Physical, electronic, and procedural safeguards have been implemented in order to protect your

Personal Information, and although we take all care to respect and protect your Personal Information

you acknowledge that:

a) You are responsible for the security of your own device and we will not accept any responsibility

for any unauthorised use of your account or of the App generally by third parties who access your

device;b) the emails and SMS messages the App will send you are not encrypted and, in the event that your

personal emails or messages are accessed by a third party, the information may be viewed by the third

party;

c) we use third party payment providers and gateways, we cannot ensure the security or privacy of

transactions that do not occur within the App;

d) you are responsible for ensuring the content of your account information that you provide to us is

accurate and up to date. You are responsible for the security of any password and details needed to

access the App and/or Healthily at all times;

e) you are responsible for any additional Personal Information you choose to provide when using the

Software;

If we have reasonable grounds to believe that your Personal Information that we hold may be subject

to unauthorised access or disclosure (eligible data breach), we will investigate and assess the suspected

eligible data breach to determine whether the eligible data breach is likely to result in serious harm to

you (Notifiable Data Breach). If a Notifiable Data Breach occurs, then we will notify you and the

Australian Information Commissioner as soon as practicable after we become aware of the Notifiable

Data Breach in accordance with our obligations under the Act. We will comply in every way with our

obligations under Part IIIC – “notification of eligible data breaches” of the Act.

4. LINKS TO EXTERNAL WEB APPS

This Privacy Policy does not extend beyond the App or the Software. When following links to other

Apps from this App, we recommend that you read the Privacy Policies of those Apps in order to

familiarise yourself with their privacy practices.

5. COOKIES

Like many Apps, the App may use cookies from time to time on your computer to keep track of your

login status.

Cookies are small data files that a web server places on a user’s computer hard drive to be a unique

identifier. Cookies enable Healthily to save your log in details for further login to our services or

product.

For example, we may use cookies to record that you have viewed a particular section of the App, that

your browsing software is a particular version or to ensure that online applications and transactions do

not require you to re-input information when moving between pages. In this way, cookies can

improve the operation of the App, and make the experience more efficient, more enjoyable or more

personalised.

Importantly, in depositing information on a user’s computer and referring to it later in the same

session (sessional) or on a subsequent visit (persistent), cookies do not need to identify the user or

record any Personal Information.

Our cookies do not have an expiration date.

The default settings of browsers like Chrome may allow some or all cookies, but users can easily take

steps to erase cookies from their hard-drive, block all cookies, or receive a warning before a cookie is

stored. However, some parts of the App may not function fully for users that disallow cookies.

6. CHANGING INFORMATION AND PREFERENCES

You are entitled to access any of our records that contain your Personal Information.Healthily will, at your request, correct as soon as reasonably possible any of our records that contain

your Personal Information and which you advise are inaccurate.

Although Healthily may charge a fee for a complex or resource intensive change to your Personal

Information there will normally be no fee charged for processing an access or correction request.

You can lodge a request to access and/or correct your Personal Information, edit your account

information at any time or cancel your registration by contacting support

at goshare@healthily.com.au. Any request received by Healthily will be dealt with within a

reasonable time period and if, for any reason, we decline your request for access, we will give you

reasons for our decision when we respond to your request.

We reserve the right to delete your Personal Information unless we are required by law to retain it.

You may contact us using the above email address if you wish us to delete your Personal Information.

Healthily will comply with a request to delete Personal Information unless we are required by law to

retain it.

Despite anything contained in this Privacy Policy to the contrary, the Freedom of Information

Act 1982 continues to apply to any Personal Information held by us. The access and correction

requirements in the Act operate alongside and do not replace other informal or legal procedures by

which an individual can be provided access to, or correction of, their Personal Information.

7. CONTACT HEALTHILY

If you would like further information about:

how you may access and request correction of your personal information that is held by

Healthily; or

how to make a complaint about the handling of your personal information and how your

complaint will be dealt with by Healthily,

please contact our Privacy Officer.

Contact details

Email: goshare@healthily.com.au

Phone: (03) 9534 7222

Facsimile: (03) 9534 7333

Postal address:

Privacy Officer

Healthily

Level 5, 492 St Kilda Road

Melbourne VIC 3004

Last reviewed: May 2025