Effective Date: March 15, 2024

Luna Clinical Pty Ltd ("Luna", "we", "our", or "us") respects your privacy and is committed to protecting the personal and health information we collect and handle in providing our services.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use the Luna app and services available via www.lunaclinical.com (the "Services").

1. WHO WE ARE

Luna Clinical Pty Ltd (ABN 12345678901) provides an AI-powered clinical documentation tool designed for use by registered healthcare professionals. The Luna App enables clinicians to record consultations with patient consent, transcribe audio, and generate clinical documents using AI-based tools. We do not provide medical advice or direct healthcare services.

2. SCOPE

This Privacy Policy applies to all users of the Luna App and Services, including clinicians, healthcare organisations, and any individuals whose information may be collected in the course of clinical documentation.

By using our Services, you consent to the practices described in this Policy.

3. INFORMATION WE COLLECT

We may collect and process the following types of personal and sensitive information:

Clinician Information

  • Name, contact details, and account credentials;
  • Professional qualifications and registration details;
  • Usage data and preferences when using the Luna App.

Patient Information

Where clinicians record or upload patient data (with appropriate consent), we may process:

  • Audio recordings of consultations;
  • Transcripts of conversations;
  • Clinical notes and other documents generated via AI;
  • Health information and sensitive data relevant to the consultation.

Technical Information

  • Device and browser type;
  • Operating system;
  • IP address;
  • Log data and usage analytics;
  • Cookies (see Section 9).

4. LEGAL BASIS FOR PROCESSING

We handle personal and health information:

  • With the consent of the individual or treating clinician;
  • As a data processor on behalf of the clinician (the data controller);
  • In accordance with Australian Privacy Principles, the Privacy Act 1988 (Cth), and, where relevant, HIPAA (Health Insurance Portability and Accountability Act, USA);
  • For the legitimate purpose of providing and improving our Services.

5. HOW WE USE YOUR INFORMATION

We use personal and health information to:

  • Provide, support, and improve the Luna App;
  • Generate transcripts, clinical notes, and other documentation from recorded consultations;
  • Enable secure access to user accounts;
  • Conduct analytics and improve product performance (using de-identified data);
  • Comply with legal obligations.

We do not use personal information to provide medical advice, nor do we share patient data for marketing or advertising purposes.

6. DISCLOSURE OF INFORMATION

We may disclose personal or health information to:

  • Clinicians or authorised users (e.g. health service staff);
  • Our contracted service providers (e.g. cloud storage, transcription, and AI processing providers);
  • Legal, regulatory, or law enforcement authorities where required;
  • Other parties with your consent or as permitted by law.

We ensure that all third-party service providers adhere to strict privacy and security standards, including compliance with HIPAA and other relevant obligations.

7. DATA STORAGE AND SECURITY

We take reasonable steps to protect personal and health information from unauthorised access, use, or disclosure. These measures include:

  • Encryption of data in transit and at rest;
  • Access controls and authentication protocols;
  • Regular audits and security reviews.

Data may be stored on secure servers located in Australia or other jurisdictions that provide equivalent data protection. Any cross-border transfers are conducted in compliance with applicable privacy laws.

8. RETENTION AND DE-IDENTIFICATION

We retain personal information only as long as necessary to provide our Services or comply with legal obligations. Where information is no longer required, we will securely delete or de-identify it.

We may use de-identified and aggregated data for research, analytics, and product improvement purposes.

9. COOKIES AND ANALYTICS

We use cookies and similar technologies to:

  • Recognise returning users;
  • Remember user preferences;
  • Analyse usage of the Luna App and website.

You can control cookie preferences through your browser settings. Some features of the Services may not function properly without cookies.

We may use Google Analytics or similar tools to collect non-identifiable usage data. These platforms do not identify individuals or associate your IP address with other data.

10. ACCESS, CORRECTION, AND COMPLAINTS

You have the right to:

  • Request access to your personal information;
  • Correct or update inaccurate or incomplete information;
  • Lodge a complaint if you believe your privacy has been breached.

To make a request or complaint, please contact us at legal@lunaclinical.com. We will respond within a reasonable time (usually 30 days). If you're unsatisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC).

11. THIRD-PARTY LINKS

Our Services may contain links to third-party websites or tools. We are not responsible for the privacy practices or content of those third parties.

12. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. When we do, we will post the updated version on our website and update the effective date above. Continued use of our Services constitutes your acceptance of the revised policy.

13. CONTACT US

If you have any questions or concerns about this Privacy Policy, please contact:

Luna Clinical Pty Ltd

Email: legal@lunaclinical.com

Website: www.lunaclinical.com