Privacy Policy
1. INTRODUCTION
Welcome to Hlthera FZCO (“Hlthera”, “We”, “Us”, or “Our”) holding trade license number 7878. Hlthera operates this
digital portal (“App”) to provide Our users (“User(s)”, “You”, or “Your”) with access to a global social healthcare
platform and digital portal that includes features such as online medical consultations via Hlthera Engage, community-
based health experiences, and other services designed to support well-being digitally and socially. Hlthera respects
Your privacy regarding any information We may collect while operating Our App (“App”). Please note that Hlthera
operates a representation office located in Mermaid Waters QLD, Australia, holding trade license number 645 813 234.
Please read this Privacy Policy (“Privacy Policy”) carefully to understand how We use Personal Information. If You do
not agree with this Privacy Policy, You must not use the App, its related websites, applications, services, or any other
website operated by Hlthera that links to this Privacy Policy. By accessing or using this App, You agree to this Privacy
Policy. This Privacy Policy may change from time to time. Any changes We make to this Privacy Policy will be posted
on the App. We will also take any other steps, to the extent required by any Applicable Laws, including notifying You
and/or seeking Your explicit consent to material changes. Changes to this Privacy Policy are effective as of the stated
‘Last Updated’ date. Other than where We have sought such explicit consent from You, Your continued use of the App
after We make changes will constitute acceptance of, and agreement to be bound by, those changes. Accordingly,
please review the Privacy Policy periodically for any updates or changes.
Any/all defined terms in this Privacy Policy are the ones referred to in the Terms and Conditions available on Our App.
In the event where a defined term in this Privacy Policy is a defined term in the Terms and Conditions, the defined terms
stated herein, will take precedence over the same defined term in the Terms and Conditions.
This Privacy Policy governs data collection, maintenance, disclosure, and use of the App and its associated Content.
By using the App, Users consent to the collection and use of their Personal Information in accordance with this Privacy
Policy.
A. Use of Hlthera Engage
If You choose to book an appointment through Hlthera Engage, We may share certain Personal Information with the
health centre You have selected, strictly for the purposes of managing Your booking. This includes confirming
appointment availability and ensuring Your booking is reflected accurately across both Hlthera and the health centre’s
systems.
The health centres You interact with through Hlthera Engage may also provide Us with limited information related to
Your booking in order to deliver Our services effectively. This data is handled securely and used solely to support Your
experience within the App. No clinical or medical records are stored or shared through Hlthera Engage.
By using Hlthera Engage, You consent to the sharing of information necessary to complete and manage Your
appointments with Our partner health centres.
Xyra AI assists Users by identifying relevant health specialities based on the symptoms they provide. The information
entered is used solely for this purpose and is not shared publicly. We respect your privacy and ensure that your data is
used only to enhance your experience within the App.
Note: Hlthera is only a platform provider and does not provide any medical and/or other health services. Nothing stated
and/or posted on the platform by Hlthera is intended to be, and must not be taken to be, the practice of medicine and/or
other healthcare professional services. Kindly refrain from using the platform for any/all emergency medical needs. If
you experience a medical emergency, you must immediately call your local emergency services.
2. INFORMATION COLLECTION
A. Information You Provide to Us
When You use the App, You may provide Us with information about You, including, but not limited to, Your name, Your
electronic mail address, Your phone number, Your delivery address, Your medical information such as weight and
height, Your personal medical details registered on Your smartwatch such as heartrate and oxygen levels, and/or Your
financial information to make or receive payment for services obtained through the App. When You use the App, We
may also collect information related to Your use of the App and aggregate this with information about other Users.
B. Information Received from Third Parties
Third parties may also give Us information about You. If We combine that information with information about You,
collected through Our App, We will still treat that combined information in accordance with this Privacy Policy.
C. Information Collected Automatically
Similar to any other online digital portal, We receive technical data including, but not limited to, Your unique device
identification number, Your location data, Your internet speed, and other such information. We do not store this
technical data; it is only used to improve Your experience while browsing the App and will be deleted from Our servers
once You exit the App. The technical information collected on Our servers is used to analyse how people use Our
services, improve Our App functions, save Your log-in information for future sessions, and to serve You with other
information and/or data that may be of interest to You.
Automatic data collection may include, but is not limited to, information pertaining to the browser and operating system
You are using, the URL or advertisement that referred You to Our App, the search terms You entered into a search
engine that led You to the App, areas within the App that You visited, links You clicked on, pages or Content You viewed,
the duration of Content viewed by You and other similar information and statistics about Your interactions (such as
Content response times, download errors, length of visits to certain pages, and other information commonly shared
when browsers communicate with other websites).
We may combine any/all data collected during Your usage of Our App along with any other information retrieved about
You. We do this to improve marketing, analytics, and App functionality so that We can make it more intuitive. The data
collected may also include the Internet Protocol (“IP”) address or other device identifiers for any device (computer,
mobile phones etc.) used to access the services and App. Some mobile service providers may also provide Us or any
third parties with information regarding the physical location of the device used to access Our App.
3. USE OF INFORMATION
In the course of using Our App, We may collect Personal Information about You as necessary that identifies You as a
specific individual and can be used to contact or identify You, including but not limited to, (“Personal Information”).
Examples of Personal Information include, without limitation, Your name, electronic mail address, delivery address,
weight, height, smartwatch information, and phone number. We use Personal Information and other information to:
i. ii. iii. iv. v. Provide and improve the App, complete Your transactions (with regards to the payment and checkout process),
address Your inquiries, process Your registration, verify the information You provide is valid, and for compliance
and internal business purposes.
Contact You with administrative communications and/or promotional offers (on behalf of Us or third parties) and
other information that may be of interest to You.
Tailor the Content by displaying offers in reference to the App and/or elsewhere.
Administer and develop Our business relationship with You and, if applicable, the corporation or any other legal
entity You represent.
Enforce and comply with relevant Applicable Laws, including to investigate, protect the property and respective
rights of Hlthera or any User on the platform, for any activity We may consider to pose a risk of being illegal,
fraudulent, unethical, or legally actionable.vi. Comply with legal obligations, analyse, and improve Our business, communications, and responding to Your
inquiries about Our services.
For any other purposes specified elsewhere in this Privacy Policy.
4. DATA RETENTION
If You do not request Us to delete certain data and/or information, We reserve the right to retain the information You
may submit to verify Your identity so long as Your Account is activated. Such data and/or information shall no longer be
stored once You choose to terminate or deactivate Your Account. Kindly note that We shall not retain any/all financial
information. Your information may be retained for backup, analysis, and business continuity purposes. If You provide
Us with Your Personal Information or any other data, We encourage You to regularly update the data to ensure that We
have accurate and up-to-date information about You.
In the event of a corporate change in control resulting from, for example, a sale to, or merger with, another entity, or in
the event of a sale of assets or a bankruptcy, We reserve the right to transfer Your Personal Information to the new party
in control or the party acquiring assets. In the event of such a change, Your Personal Information will continue to be
treated in accordance with this Privacy Policy.
5. DATA SHARING AND DISCLOSURE
We may share Your data to provide Our services, for legal and investigative purposes, in connection with the App,
promotions, or if We are part of a merger or acquisition. We may also share non-identifying information with third parties.
You have a choice as to whether We share Your Personal Information with third parties for their own marketing
purposes. We do not share Your Personal Information with third parties for marketing purposes unless We first provide
You with the opportunity to opt-in or opt-out of such sharing.
We may share Your Personal Information and/or data at any time, under the following circumstances:
i. Where We are legally required to do so in order to comply with Applicable Laws, governmental requests, judicial
proceedings, or legal processes, such as in response to a court order.
ii. Where We believe it is necessary to investigate, prevent, or take action regarding potential violations of Our
Terms and/or policies, suspected fraud, situations involving potential threats to the safety of any person or User,
any illegal activities, or as evidence in litigation as required by law.
iii. With third-party service providers, contractors, agents, such as third-party payment gateways and other service
providers who perform services for us or on Our behalf and require access to such information to do that work,
employees or affiliates. Examples include payment processing, data analysis, electronic mail delivery, hosting
services, customer service, and marketing efforts. We may allow selected third parties to use tracking
technology on the App, which will enable them to collect data about how You interact with the App over time.
This information may be used to, among other things, analyse and track data, determine the popularity of certain
Content, and better understand online activity.
iv. With the Medical Professionals that the Patients are specifically consulting with in order to facilitate and carry
out Our services.
v. Where there is a transfer of business ownership such as a merger, sale of company assets, financing, or
acquisition of all or a portion of Our business to another company.
vi. To offer You certain promotions.
We may share and disclose Your Personal Information for any other purpose with Your consent.
You are responsible for ensuring the accuracy of any Personal Information that You submit to Us. Inaccurate information
may affect Your experience whilst using the App and Our ability to contact You as described in this Privacy Policy.When providing Personal Information, collected through use of Our services, Users agree to the use, processing, and
storage of Personal Information in countries which may have data protection laws that differ from the laws in the User’s
country.
We also collect any/all information that is not considered Personal Information, made available through web browsers
and servers and may include browser type, language preference, referring site, and date and time of each visitor’s
request.
6. COOKIES
Cookies are files with small amounts of data, which may include an anonymous unique identifier. We use Cookies to
collect information to let Us know that You are a prior User. This information may include IP addresses, browser type,
internet service provider, referring/exit pages, the files viewed on Our App (e.g. HTML pages, graphics, etc.), operating
system, date/time stamp, and/or clickstream data (“Cookies”). Cookies are not used to store other Personal Information.
Users can instruct their web browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if Users
do not accept Cookies, they may not be able to use certain features of the App. Hlthera reserves the right, at any time,
to add or remove certain Cookies, which may be subject to a revision of this Privacy Policy.
Third parties under contract with Hlthera may use Cookies to collect any/all information and/or data about Your usage
of the App. These third-party service providers may use this information to help Hlthera deliver services on the App
based on Your browsing activity.
We also use Cookies in order to enable Us to conduct surveys for Our own use and on behalf of Our advertisers. These
Cookies are used to determine whether You have seen certain Content or advertising so that We may request Your
opinions. We may also use Cookies to authenticate respondents or to help You pick up where You left off in a survey. If
You have Cookies disabled, You may not be able to participate in some surveys.
7. SECURITY
We adopt standard data collection, storage, processing practices, and security measures in accordance with the Health
Level Seven (“HL7”) standards, as well as the GDPR rules and regulations, in order to protect against unauthorised
access, alteration, disclosure, or destruction of Users’ data stored on Our App.
We also adopt the highest security measures in order to keep Your Personal Information secured at all times. Such
measures include, but are not limited to, two-way encryption.
We do not sell, trade, or rent Users’ Personal Information to others. We may, however, share generic aggregated
demographic information, not linked to any Personal Information, with Our business partners and trusted affiliates.
We endeavour to exercise Our best efforts to keep Your information secure. However, We cannot guarantee the safety
of Your Personal Information and shall not be held liable, in any manner and capacity whatsoever, in the event of a
breach of security beyond Our reasonable control.
8. YOUR DATA PROTECTION RIGHTS
You retain the right to: You have the right to access certain Personal Information We hold about You, including the
following details:
Request Hlthera for any/all copies of Your Personal Information, as well as the following information:
i. The purposes for which Your Personal Information is being processed;
ii. The details of Personal Information that will be retained and/or shared;
iii. The recipients to whom Your Personal Information has or will be disclosed to, including, but not limited to, Our
payment gateways and other third-party aggregators We have partnered with for Our point collecting system;iv. The period for which Your Personal Information will be stored, for the period it is retained, as described in the
section on how We collect and store information; and/or
v. Any/all Personal Information that has not been collected from You directly and has been made available through
a separate source.
Request Hlthera to correct any/all Personal Information uploaded by You that You may perceive to be inaccurate and/or
request Hlthera to complete any Personal Information You believe to be incomplete without undue delay.
Request Hlthera to erase Your Personal Information, without undue delay, from the Website and the Website’s servers,
under specific conditions, such as:
i. The Personal Information is no longer necessary in relation to the purposes for which it was being collected and
processed;
ii. The User withdraws consent for processing their Personal Information, and no other legal basis applies;
iii. The User objects to the processing of their Personal Information, and there are no overriding legitimate grounds
to continue;
iv. The Personal Information has been unlawfully processed; and/or
v. The Personal Information must be erased to comply with a legal obligation within the EU.
The above conditions shall not apply unless the processing is necessary for:
vi. Exercising the right of freedom of expression and information;
vii. Compliance with a legal obligation which requires processing by the EU or for the performance of a task carried
out in the public interest or in the exercise of official authority vested in Hlthera;
viii. Public interest purposes in the area of public health;
ix. Archiving purposes in the public interest for scientific, historical research, or statistical purposes; and/or
x. For Hlthera to establish and exercise any/all legal claims that may arise.
Request Hlthera to restrict the processing of Your Personal Information, where one of the following applies:
i. The accuracy of Your Personal Information is contested by You, for a period enabling Hlthera to verify the
accuracy of Your Personal Information;
ii. The processing is unlawful, but You request that Your Personal Information not be erased and instead prefer that
its use be restricted
iii. Hlthera no longer needs Your Personal Information for the purposes of the processing, but You require them for
the establishment or exercise of legal claims; and/or
iv. The User objects to the processing of their Personal Information, and there are no overriding
legitimate grounds to continue;
Object to Hlthera’s processing of Your Personal Information, under specific conditions, such as:
i. The Personal Information is no longer necessary in relation to the purposes for which it was being collected and
processed; and/or
ii. Where Your Personal Information is being processed for marketing purposes, You have the right to object to
such use at any time;
Request Hlthera to transfer Your Personal Information that We have collected to another organisation and/or directly to
You, unless the processing is necessary for public interest purposes or in the exercise of official authority vested in Us.Request Hlthera that You are not subject to a decision based solely on automated processing, including profiling which
affects You, unless such a decision is:
i. Necessary for entering into, or performing, a contract between Hlthera and You;
ii. Authorised by the EU whilst suitable measures are laid down to safeguard Your freedoms and legitimate
interests; or
iii. Based on Your explicit consent.
The above rights shall be restricted where it is reasonably necessary and proportionate to safeguard the following:
i. National security;
ii. Defence;
iii. Public security;
iv. The prevention, investigation, detection, or prosecution of criminal offences or the execution of criminal
penalties, including the safeguarding against and the prevention of threats to public security;
v. Economic or financial interests of the EU, such as monetary, budgetary, taxation matters, public health, and
social security;
vi. The protection of judicial independence and proceedings;
vii. The prevention, investigation, detection, and prosecution of breaches of ethics for regulated professions;
viii. A monitoring, inspection, or regulatory function, connected to the exercise of official authority in specific cases
outlined under Your Data Protection Rights;
ix. Your protection and freedoms; and
x. The enforcement of civil law claims.
Should You wish to make a request and exercise Your data protection rights as outlined under Your Data Protection
Rights, please contact Us via the Contact Us form available on Our website.
9. OTHER WEBSITES
Our App may, from time to time, contain links to and from third-party websites. If You choose to click on third-party
links, You will be directed to that third party’s website. The fact that We link to a website is not an endorsement,
authorisation, or representation of Our affiliation with that third party, nor is it an endorsement of their privacy or
information security policies or practices.
These other websites may place their own Cookies or other files on Your device, collect data, or solicit Personal
Information from You. Your use of Our respective third-party websites is subject to the compliance of their terms and
conditions and privacy policy. Hlthera shall not be held liable for any issues arising out of Your use of the third-party
websites once You have been redirected to their page. Should You have any questions about their use of the
information they collect, You should contact them directly.
10. CHANGES TO HLTHERA’S PRIVACY POLICY
This Privacy Policy shall remain in effect except with respect to any changes in its provisions in the future, which will be
in effect immediately after being posted on this page.
The App and Our business may change from time to time. As a result, at times it may be necessary for Hlthera to make
changes to this Privacy Policy in order to accurately reflect Our data collection and disclosure practices. Hlthera
reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice, unless
otherwise required by any Applicable Laws. Accordingly, please review this Privacy Policy periodically and especially
before You provide any Personal Information. Your continued use of the App after any changes or revisions to thisPrivacy Policy shall indicate Your agreement with the terms of such revised Privacy Policy, without prejudice to Your
rights under any Applicable Laws.
11. ACCEPTANCE OF THESE TERMS
By using the App, Users signify their acceptance of this Privacy Policy. We reserve the right to alter, modify, and/or
amend any one of the provisions stated herein without prior notice to any User. Continued use of the App following any
alterations, modifications, and/or amendments will be deemed as the Users’ acceptance of those changes.
12. CONTACT INFORMATION
For further inquiries or comments about Hlthera’s App or this Privacy Policy, please reach out to us via the Contact Us
form available on our website.