Privacy Policy
Last updated: 30 September 2026
1. Who we are and who this notice covers
House of Praxi Pty Ltd (ABN 75 693 330 522, ACN 693 330 522) provides the Praxi software and associated services. This notice covers personal information we handle about website visitors, prospective customers, practitioners and practice staff, clients and authorised representatives using connected services, suppliers and people who contact us. The product processing described here covers Praxi Web, associated practitioner iOS applications and the included client portal and iOS application. Pathway and Couples require separate feature-specific privacy notices and are outside this product scope. This boundary does not remove our obligations for information we actually hold.
Practices have their own obligations and privacy notices for healthcare and recordkeeping. We have obligations for our own handling of information. Calling us a software provider does not transfer all responsibility to the practice or remove rights against us. This notice should be read with a feature-specific collection notice where one is provided. Our Terms of Service govern a Practice subscription; this notice is not a waiver of privacy rights.
Contact the Privacy Officer at hey@praxi.au, or House of Praxi Pty Ltd, 493 Swan Street, Richmond VIC 3121, Australia. We will provide this policy in a reasonable accessible format on request. Use general email to request a secure privacy-request process without including clinical records or identifiable health details. We will explain a suitably protected method before requesting that material; privacy obligations still apply to information inadvertently received.
2. Information collected, and where it comes from
| Context | Information and usual source |
|---|---|
| Enquiries and demonstrations | Contact details, practice details, requests and correspondence supplied by you. Please do not put client health information in a sales enquiry. |
| Practitioner and staff accounts | Identity, contact, role, professional registration where relevant, practice, authentication and billing information supplied by the account holder or practice; relevant professional information may be checked against an appropriate register. |
| Practice services | Client identity and contact details, guardian/referrer details, appointments, clinical notes, assessments, forms, communications, documents, billing/funding information and approved outputs supplied by the practice, client or authorised representative. |
| Recording and AI features | Authorised audio, transcripts, prompts, source documents and generated outputs for enabled functions; consent and audit records. |
| Optional connections | The email, calendar, file, accounting, payment or telehealth data covered by the permissions and features the practice enables. |
| Security and support | Account activity, access logs, device/browser and network information, error information and support correspondence needed for the relevant purpose. |
We collect information directly where reasonably practicable and appropriate, and also through the sources above. A practice may provide information before a client opens a portal account. We require consent for collecting sensitive information where the law requires it, unless a relevant legal exception applies. Unsolicited information is assessed and handled under the applicable requirements, including lawful destruction or de-identification where required.
You can make a general enquiry anonymously or under a pseudonym where practicable. Some services require identification for security, professional verification, billing or lawful health-record handling. We will explain material consequences if required information is not supplied; these may include being unable to create an account, verify authority, provide a requested feature or process a transaction.
3. Why information is used and disclosed
We handle information to provide the functions a practice or individual requests, manage accounts and subscriptions, support users, maintain records and permitted connections, secure and recover the service, investigate faults or incidents, respond to rights requests and comply with legal obligations. Clinical processing is confined to the agreed service purposes and lawful instructions, subject to our own legal duties.
Access by Praxi personnel is limited to authorised people with a need to know. Routine support requiring clinical content needs appropriate recorded practice authorisation. Necessary incident investigation or legally required access may occur without advance permission, with appropriate controls and records. A consent to receive treatment does not automatically permit recording, unrelated research or marketing.
We do not sell client health information. We do not obtain a general right to exploit clinical information because it was uploaded or because feedback was given. A proposed secondary use must be assessed separately for the authority, information and consent required. De-identifying information is itself an activity that requires a lawful basis; a label such as “anonymous” does not prove re-identification is impossible.
4. AI, recording and automated actions
Depending on the functions actually enabled, software may transcribe authorised recordings; use selected transcripts, notes, assessments and collateral information for summaries, documented themes and professional reflection; retrieve and synthesise evidence; draft notes, reports, worksheets and other documents; assist with billing-item lookup; or perform configured administrative communications and workflows. Practitioner-supplied diagnoses and plans may appear in source-grounded drafts. AI is not supplied to originate diagnoses, differential diagnoses or prescribed treatment plans. Client-facing assistants have a separate administrative scope. Outputs can contain errors, omissions or bias. Qualified practitioners must independently review clinical content before use and remain responsible for their healthcare decisions. Praxi remains responsible for its own conduct and obligations.
Practice Data is not used to train or fine-tune any AI model, or for unrelated model evaluation, clinical benchmarking or product development. Producing and checking the requested output and necessary fault/security investigation are distinct.
Recording and AI-processing choices must explain the feature, participants, purpose, recipients and retention before use, with alternatives where available. The practice must establish the authority required in the relevant jurisdictions. Withdrawal stops future processing dependent on that consent; it may not require deletion of an existing lawful clinical record or audit trail. Audio, transcripts, approved notes and logs have different retention rules, which must be disclosed for the particular feature.
Configured administrative reminders can run automatically. Account identity, role, authentication and security activity can be used to grant or restrict software access, including a security restriction pending review. Plan, trial dates, payment status and verified Student-eligibility status are used to calculate subscription access and limits; eligibility verification is a separate process from the automatic access calculation. These are access and administration decisions, not clinical diagnoses or care decisions. A restriction can affect access to a function. Contact us to question an outcome or request review; we will explain the relevant process and respond under applicable law. Human review requirements differ by function, and we do not promise that every restriction receives review within a fixed number of hours.
Automated decisions (APP 1.7–1.9). Some decisions are made by Praxi's software without a person deciding each case. The personal information used is account identity and role; sign-in and security activity (such as failed sign-in attempts, device and network signals, and unusual access patterns); and plan, trial, payment and verified Student-eligibility status. The decisions made this way are: temporarily locking a sign-in after repeated failed attempts; restricting an account or ending sessions when a likely security incident is detected, pending review; and moving a practice's subscription to read-only or suspended access when payment is overdue. Praxi does not use software to decide anyone's assessment, diagnosis, treatment or eligibility for care. Some automated functions, such as waitlist offers, cancellation fees, saved-card charges and the AI receptionist, are switched on and configured by a practice, and the practice describes them in its own privacy notice.
5. Email, calendar and other practice connections
A connection is optional and its access depends on the provider permissions and the functions enabled. Data may include messages and attachments, sender/recipient details, calendar events and account identifiers. It is used for the connected functions, such as displaying or sending messages, linking a relevant message to a record, or an expressly enabled AI function. Do not assume every provider or feature shown in a roadmap is available.
Disconnecting prevents future access within our control, subject to the provider's revocation process. It does not automatically erase a message already incorporated into a clinical record or a copy held independently by another provider. Ask us or the practice about the relevant copy and retention basis. We do not impose a blanket seven-year retention period on every connected mailbox item.
Use of data obtained through Google APIs must comply with the applicable Google API Services User Data Policy, including Limited Use requirements. Provider-specific restrictions and additional authorisation may limit processing even where a feature is otherwise available.
6. Recipients and locations
We use suitable hosting, communications, payment and other service providers. The maintained recipient and processing-location register identifies relevant recipients, purposes, categories and locations, distinguishing Praxi suppliers from services a practice engages itself. The register supplements this notice; it does not authorise a new purpose simply because a row is added.
The following providers may handle information for their stated purposes, according to the services and connections enabled:
| Recipient or function | Purpose of disclosure |
|---|---|
| AWS | Core hosting, storage and enabled processing and communications services in Australia. |
| Anthropic's Claude via Amazon Bedrock (AWS) | Clinical and client-portal AI inference by Anthropic's Claude models, run through Amazon Bedrock in Sydney, Australia, under the approved processing locations, retention settings and no-training arrangements for that service. |
| Stripe | Praxi subscription billing and optional practice payments, using relevant billing and contact information. Processing arrangements include Australia and the United States, with the applicable Stripe contractual entities and safeguards recorded in the recipient register. |
| Google Workspace | Praxi corporate/support correspondence; global processing. Do not email clinical content to general support or sales. Request a verified secure support method first. Unsolicited information still attracts applicable privacy duties. |
| Twilio | Enabled telephone and receptionist functions may handle caller contact details, call audio and submitted information. Twilio handling and access locations must be stated in the recipient register; an Australian telephone number or edge does not establish exclusively Australian processing. |
| ElevenLabs | Enabled voice services, including support, sales or a separately assessed receptionist configuration, may process caller speech and call context. The recipient register must identify the actual enabled provider, purpose and locations. Clinical use must satisfy the Practice Terms and required consent and location safeguards before it is enabled. |
| Practice-connected providers | Only enabled email/calendar, accounting, payment and video providers and the permissions actually granted. Identify their relevant locations when offered. |
A service that is not enabled does not receive information through that disabled connection. Optional connections are disclosed when enabled. Self-hosted software is not automatically an independent recipient; the relevant hosting and access arrangements still apply. Where native push notifications are enabled, Apple handles device/push identifiers and notification delivery. Push messages are designed to use generic text and limited routing information rather than clinical records; obtain the underlying content through authorised app access. Enabled email-delivery and diagnostic/error services also handle the information needed for those functions and must be identified with their relevant locations in the recipient register.
The Practice Terms require Australian storage of core clinical information and clinical AI processing, including protected copies in backups and logs. Other business information and optional connections can involve overseas recipients.
We must comply with applicable overseas disclosure obligations, including APP 8 and accountability under section 16C where applicable. Victorian HPP 9 also concerns transfers outside Victoria, including elsewhere in Australia. The actual recipient, control/access arrangements and applicable exception or safeguard require assessment. Acceptance of this policy is not a generic consent to avoid those protections. Neither Australian hosting nor a supplier's foreign headquarters alone resolves every question.
We may make disclosures required or authorised by law, including appropriately assessed court and regulatory processes. A business transfer does not provide an unrestricted permission to disclose health records. Professional advisers receive only information appropriate to their functions and legal duties.
7. Security, incidents and retention
We use reasonable technical and organisational safeguards appropriate to the information, including access controls, encryption, audit logging, supplier controls and backup/recovery arrangements. No system is risk free. We do not represent a supplier's certification as Praxi's certification or a planned audit as completed.
We investigate suspected incidents, take containment and remediation action, and make required notifications. Under the NDB scheme, the assessment standard includes taking all reasonable steps to complete the assessment within 30 days; that is not a general period during which notification may be delayed. An eligible breach is notified as the applicable law requires. My Health Record has a separate reporting regime and relevant exceptions to NDB; automatic double reporting is not a universal rule. Contractual notice to a practice may arise earlier than final statutory classification.
Retention depends on the purpose, record type, applicable law, legal holds and arrangements with the lawful custodian. Clinical records, communications, temporary recordings, account information and audit records do not all share one deadline. The Practice Terms provide for at least seven years of relevant security/access audit records, separately from clinical payloads; this does not require retaining all clinical payloads or general correspondence for that period. Practice closure requires a lawful handover/disposal process and does not transfer every practice duty to Praxi indefinitely. Company financial, employment and clinical records must be assessed under their respective rules.
The internal retention schedule must identify periods, triggers, lawful exceptions and backup treatment. We destroy or de-identify personal information when required by law and no permitted retention basis remains. We restrict use of retained records and reapply relevant restrictions after restoring backups. Contact us for the treatment of a particular record; a request to close an account is not automatically a request or legal authority to erase clinical records.
8. Cookies, telemetry and marketing
Necessary session/security cookies support access and fraud prevention. Preference storage may remember settings such as theme. Disabling necessary cookies can prevent a function working.
Any additional analytics, advertising cookies or marketing pixels require an accurate disclosure and any required choice or consent before they are enabled. Performance telemetry may include personal information, such as network metadata, identifiers or route information, and is handled under this policy.
Creating an account, making an enquiry, completing a trial, joining the Student learning programme or retaining record access does not by itself subscribe you to marketing. Praxi offers a separate optional, unchecked choice for product news, learning resources and promotional invitations. Declining or withdrawing that choice does not remove included account or learning access. Where marketing is sent, we use the required authority, identify the sender and provide a working unsubscribe mechanism without requiring account sign-in. We act on electronic-marketing unsubscribe requests within the applicable legal period, generally five working days under the Spam Act. Required service and security messages are treated separately and must not conceal marketing.
9. Access, correction and complaints
Contact hey@praxi.au to request access to or correction of information we hold about you, or to raise a privacy complaint. We may reasonably verify identity and authority and work with the practice responsible for the clinical record. We will not refer you away where we have our own duty to respond.
We respond within applicable legal timeframes. If information is inaccurate, out of date, incomplete, irrelevant or misleading, the applicable correction process may involve an amendment or associated statement while preserving a required audit history. A locked clinical record does not remove legal rights. Portal download scope does not determine your statutory entitlement. There is no fee to make a request; any permitted charge for providing access must be reasonable and explained in advance. We do not charge for correction.
If access or correction is refused, we give reasons and complaint information to the extent required by law. Legal grounds differ by right and jurisdiction; the mere fact that information is clinical or held for litigation does not establish every possible exception.
We acknowledge and investigate complaints promptly and explain any further information or time needed. You may complain to the Office of the Australian Information Commissioner at oaic.gov.au, or the relevant State/Territory authority, including the Victorian Health Complaints Commissioner at hcc.vic.gov.au. Contract dispute clauses do not remove those pathways.
10. Changes and document control
We will date the published policy and make material changes reasonably accessible. Updating this notice does not retrospectively authorise a new use or replace a consent or contract variation required by law. Preserve the prior notice and the associated contract/consent version.