Version 1.0 – October 2025
ABN: 96 674 505 465
Address: 93-97 York Street, Subiaco WA 6008
Email: info@clean-pillptyltd.com.au
Website: www.cleanpill.com.au

Purpose of Data Processing

Clean-Pill collects and processes personal and biometric data to:

• Deliver personalised mental-wellness programs and neuro-feedback sessions.

• Operate our platform, applications, and technologies (VR, EEG, AI dashboards).

• Monitor progress and track user wellbeing metrics.

• Enhance our research and program design.

• Meet our legal and regulatory obligations in Australia.

How We Get Data

Data enters Clean-Pill’s system through one or more of the following:

1. Through VR headsets and EEG devices (e.g. Healium, Apollo Neuro).

2. Through wearable devices that transmit biometric signals such as heart rate or sleep patterns.

3. Through user inputs in our Clean-Pill platform, portal, or questionnaires.

4. Through clinician data entry during therapy sessions or assessments.

5. Through our secure cloud servers for data storage and retrieval.

Legal Basis for Data Processing

Clean-Pill operates in compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
Our legal basis for data processing includes:

• Consent: We collect and process data only with your informed consent.

• Contractual Obligation: To deliver the services you have purchased or subscribed to.

• Legitimate Interest: To improve product performance and safeguard security.

• Legal Requirement: To comply with Australian laws and healthcare record-keeping standards.

Clean-Pill does not collect data from individuals under 18 years of age without explicit parental or guardian consent.

Location of Data

Data is stored in:

• Secure cloud servers located in Australia and, where applicable, the United States, via our partners (Healium, HubSpot, Google Cloud).

• Encrypted databases accessible only to Clean-Pill-authorised staff and clinicians.

All storage providers comply with ISO 27001 and ACSC recommendations.

Use of Data After Processing

• Personal and biometric data is used only for therapeutic, educational, and operational purposes.

• Anonymised aggregated data may be used for research and innovation within Clean-Pill’s open-source mental-wellness hub.

• Data is never sold, rented, or shared for marketing purposes.

• Upon account deletion or written request, all identifiable data is erased within 30 days (subject to legal retention requirements).

Rights of Individuals

Under the Australian Privacy Principles, you have the right to:

• Access – Request a copy of your personal information.

• Correction – Request that we amend inaccurate or outdated data.

• Deletion (“Right to be Forgotten”) – Request that your data be permanently deleted.

• Data Portability – Receive a digital copy of your data in CSV or PDF format.

• Complaint – Lodge a complaint directly with us or the Office of the Australian Information Commissioner (OAIC).

Requests should be sent to info@clean-pillptyltd.com.au.

Contacting Clean-Pill

Questions or concerns about how we collect, use, or store your data can be sent to:

Privacy Officer
Clean-Pill Pty Ltd
93-97 York Street, Subiaco WA 6008
📧 info@clean-pillptyltd.com.au
🌐 www.cleanpill.com.au/privacy

Updates to This Privacy Policy

Clean-Pill may update this policy from time to time to reflect new technologies or legal requirements.
The latest version will always be available at www.cleanpill.com.au/privacy-policy.

Effective Date: October 15, 2025 | Version: 1.0