Privacy Policy

Cognevity Pty Ltd ('Cognevity', 'we', 'us') provides cognitive health services for adults. This policy explains how we handle your personal information, including your health information.

Because we provide a health service and hold health information, we're bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles in full.

• Contact details: your name, email address, phone number and time zone.
• Booking details: what you tell us when you book a call with us.
• Health information: your medical history, current health, lifestyle and environment, cognitive health concerns, cognitive assessment results and any other medical data you choose to share. This includes genetic information, such as an APOE4 result, only if you choose to share it.
• Session notes: notes made during and after our coaching sessions.
• Healthcare provider details: where we’re coordinating with your doctor or specialist.
• Payment details: to process your fees.
• Website usage information: collected through cookies when you visit our website.
• Newsletter details: your email address, if you subscribe to our updates.

Health information is sensitive information under the Privacy Act. We collect it only with your consent, which you give when you share health information in a booking form or call, and when you complete our intake assessment and accept our Coaching Services Agreement.

You can deal with us anonymously, or under a pseudonym, for general enquiries. For coaching itself we need to know who you are. We can't deliver the service or meet our health record obligations otherwise.

If you share genetic information, we use it only to support your coaching. We don’t keep copies of genetic test reports.

We collect information directly from you through intake assessments, coaching sessions, email, and website booking and contact forms.

• Cookies and analytics. Our website uses cookies, including Google Analytics, to understand visitor behaviour. Cookies don’t give us access to information stored on your device. You can reject cookies through your browser settings, though this may affect site functionality.
• Session transcription. We use Heidi, an AI transcription tool, to transcribe our sessions so we can prepare your session notes. Heidi stores data in Australia. Transcripts are deleted once your notes are ready. You can ask us not to use Heidi in your sessions.
• Storage. Your session notes and Action Plan are sent to you by email. We use Google Drive only for Cognevity resources, not for your health information. You accept your Coaching Services Agreement electronically when you book. These services store data overseas (see Section 5). We hold no paper records.
• Retention. We keep your health information for 7 years from your last session, as required by the Health Records and Information Privacy Act 2002 (NSW). After that, we securely destroy or de-identify it.
• Security. We take reasonable steps to protect your information from misuse, loss and unauthorised access. No system is completely secure, and sending information over the internet carries some risk.

We use your personal information to:

• Deliver and personalise your coaching, including your action plan and progress monitoring.
• Coordinate with your healthcare providers, where you’ve agreed to this. We send updates or assessment results to your doctor only with your written consent.
• Communicate with you about scheduling and administration.
• Process your payments.
• Meet our legal obligations.

If you subscribe, we send newsletters and updates. You can unsubscribe at any time. Coaching clients are not automatically subscribed. We never use health information for marketing and never sell personal information.

We publish testimonials only with your written consent.

In group sessions, we ask all members to keep what others share confidential. We can’t guarantee this, so please share only what you’re comfortable with.

We share your personal information only as set out below, or with your consent.

Independent GP (with your consent): when you choose blood testing through an independent GP, we share your contact details and relevant health information with them.

Service providers we use

• Heidi (Australia): transcribes our sessions so we can prepare your notes. Transcripts are deleted once your notes are complete.
• Google (global): delivers our email, including your session notes and Action Plan, stores Cognevity resources in Google Drive and provides website analytics. These services are hosted in Google’s data centres outside Australia.
• Squarespace and Acuity Scheduling (United States): host our website, manage bookings and enquiries, and send our newsletter.
• Zoom (United States): delivers your sessions. We don’t record sessions.
• CNS Vital Signs (United States): delivers the Cognevity Cognitive Baseline assessment and holds your assessment results.
• WhatsApp (Meta, United States): used for brief between-session messaging. Messages are end-to-end encrypted. Please don’t use messaging for urgent or medical issues.
• Stripe (United States): processes your payments. We don’t see or store your full card details.
• Apollo Health (United States): for Apollo Health members who request a ReCODE Report, your lab data is handled under Apollo Health’s own privacy policy.

Where information is disclosed overseas, we take reasonable steps to ensure it is handled consistently with the Australian Privacy Principles. Overseas recipients may not be subject to the same privacy protections as in Australia.

We may also disclose information where required by law, for example court orders, warrants or law enforcement requests. We are legally required to report child abuse, abuse of a vulnerable adult, or a risk of serious harm.

If our practice is sold or merged, your information may transfer to the new owner under this policy. We will notify you if this occurs.

You can ask us for a copy of the personal information we hold about you, or ask us to correct it, at any time. Email rachel@cognevity.com.au and we'll respond within 30 days. If we can't give you access or make a correction, we'll explain why in writing.

Please tell us if your contact details or health information change, so we can keep our records accurate and up to date.

If you're concerned about how we've handled your personal information, please email rachel@cognevity.com.au. We'll acknowledge your concern within 7 days, look into it, and respond in writing within 30 days.

If you're not satisfied with our response, you can raise the matter with the Office of the Australian Information Commissioner at oaic.gov.au, or, for health records, the NSW Information and Privacy Commission at ipc.nsw.gov.au.

If a data breach happens that's likely to cause you serious harm, we'll notify you and the Office of the Australian Information Commissioner, as the Notifiable Data Breaches scheme requires.

We may update this policy from time to time. The current version is always on our website, with the date it was last updated.

For any question about this policy, contact us at rachel@cognevity.com.au.