Clinician Privacy Policy

This Clinician Privacy Policy explains how Anchr Digital Health Pty Ltd (ACN 696 944 537) ("Anchr", "we", "us", "our") handles personal information in connection with Anchr for Clinicians: the clinician portal, telehealth, AI features, billing tools, Anchr Connect and related services ("the Platform").

It applies to clinicians who apply for or use the Platform, their practice staff, and people who contact us about the Platform. It also explains how we handle information about clinicians' clients that we hold in the Platform on clinicians' behalf. People who use the Anchr app are covered by our Privacy Policy for app users at https://anchr.health/privacy-policy.

This policy forms part of the Clinician Agreement, together with the Clinician Terms of Service (https://anchr.health/clinician-terms). Words defined in the Terms, such as "Practice Data", "Client Data", "AI Features" and "Recording", have the same meaning here.

We are an Australian company and we handle personal information under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, and health information under state and territory health records laws, including the Health Records and Information Privacy Act 2002 (NSW), the Health Records Act 2001 (Vic) and the Health Records (Privacy and Access) Act 1997 (ACT).

Our privacy officer can be reached at privacy@anchr.health. Use the subject line "Privacy" for questions, requests or complaints. We may ask you to confirm your identity before acting on a request, usually by confirming the email address on your account.

Please do not email us Client Data. If you need help with a client's record, tell us what you need and we will help you through the Platform.

• For your own personal information (your account, registration, practice and billing details), we are responsible for it under the Privacy Act, and this policy explains how we handle it.
• For Practice Data you enter or create in the Platform, such as session notes, treatment plans, appointments, documents, Recordings and AI drafts you save, we handle it on your behalf as your service provider, under the Clinician Terms of Service. You remain responsible to your clients for that information, and your own privacy policy applies to it as well as ours.
• Information a client gives Anchr through the Anchr app is handled by Anchr under our Privacy Policy for app users. We share it with you only to the extent the client allows. Once you receive it, it also forms part of your records.

4.1 Account and Identity

• Your name, title, email address and phone number
• Your password, which we store only as a secure hash and never see, and your two-step sign-in settings
• Sign-in records: when you sign in, your IP address, and your browser and device type

4.2 Professional and Practice Details

• Your profession, Ahpra registration number or professional association membership number, and what the public register shows about you, including any conditions, undertakings or notations
• The outcome of our verification checks, and any information you give us to support them
• Your practice name, ABN or ACN, practice address, and the branding you upload (such as a logo and colours)
• Profile information you choose to publish to clients, such as in your booking page or a Find a Clinician listing
• Images, audio and PDFs you add to your media library. If you record audio in the portal, this includes your voice.

4.3 Plan and Billing

• Your plan, subscription status, AI credit purchases and balance, included sessions used, invoices and tax invoices
• Card brand, last four digits and expiry (your full card details are held by Stripe, not us)
• If you take client payments through Anchr, your Stripe connected account status and the platform fees charged. Stripe collects and holds the identity and bank details it needs to verify your business.

4.4 Your Clinician Agreement

• The version of the Clinician Agreement you accepted, the acknowledgements you ticked, the name you typed to sign, the date and time, and the IP address and browser you signed from

4.5 Use of the Platform

• Security audit logs recording when you view, create, change, export or delete client information
• AI usage records: which AI Feature was used, when, how much it cost and whether it succeeded. These records do not contain the content of your notes or transcripts.
• Technical logs and error reports needed to keep the Platform running and secure

4.6 Communications

• Emails and messages you send us, feedback you give (for example, rating a Brainstorm or a draft), and our replies
• Your name as shown to clients in telehealth calls, and emails sent on your behalf

Depending on the features you use, Practice Data can include:

• Client identity and contact details, emergency contacts, referral and Medicare details you record
• Appointments, attendance, invoices and payment status
• Session notes, treatment plans, goals, letters, reports, intake forms, outcome measures and documents
• Recordings, transcripts and AI Output, such as draft notes, summaries, continuity briefs and suggestions
• Modules, activities and worksheets you assign, and your clients' progress with them
• Messages and emails you send to clients through the Platform
• Information your clients choose to share with you from the Anchr app, such as mood check-ins, Guide conversations or safety plans, as described in our Privacy Policy for app users

• From you and your Personnel, when you apply, sign up and use the Platform
• From your clients, when they use the Anchr app, complete intake forms, join a telehealth session or pay you
• From public registers, such as the Ahpra register of practitioners, and from professional associations when we verify you
• From Stripe, about payments, and from Halaxy, if you use Anchr Connect
• Automatically, through the Platform's security and audit logs
• Generated by the Platform, such as transcripts, AI Output and usage records

• To create and run your account, and provide the Platform and support
• To verify your identity, registration, membership and insurance, before turning on AI Features, telehealth and paid plans, and from time to time after that
• To bill you, manage your plan and AI credit, process client payments and issue tax invoices
• To keep the Platform and your clients' information secure, detect misuse and fraud, and keep audit records
• To send you service messages, such as security alerts, verification outcomes, billing notices and changes to our terms. You cannot opt out of these while you have an account.
• To send you news about Anchr features relevant to your practice. You can unsubscribe at any time.
• To improve the Platform using usage records, error reports and feedback, but not the content of Practice Data
• To respond to complaints, regulators and legal requests, enforce the Clinician Agreement, and meet our legal obligations

We use and disclose Practice Data only:

• to provide the Platform to you and your clients, as you direct through the Platform
• to process it with AI Features, transcription and telehealth, as described in sections 9 and 11
• to keep the Platform secure and investigate misuse or Security Incidents
• to help you when you ask for support
• where the law requires or permits it, such as to lessen or prevent a serious threat to someone's life, health or safety

Our personnel only access Practice Data when you ask us to help, to investigate a security issue or misuse, or where the law requires, and only those who need to. They are bound by confidentiality.

AI Features use Claude models, developed by Anthropic, which we access through Amazon Bedrock, a service of Amazon Web Services, in the Sydney region of Australia.

• What is sent: only the information a feature needs to produce its output. For example, a note draft uses the session transcript and any notes you add; Brainstorm uses the client information and question you give it; a continuity brief uses recent notes and what the client has chosen to share with you.
• Where: requests are processed by Amazon Bedrock in Australia. They are not sent to Anthropic, and Anthropic has no access to them.
• No retention by the AI service: Amazon Bedrock does not store prompts or outputs after it responds, does not share them with Anthropic or any other model provider, and does not use them to train models.
• Outputs: AI Output is saved with your Practice Data in our database in Australia, where you can review, edit or delete it.
• Human review: every AI Output is a draft for you to check. The Clinician Terms of Service require you to review it before relying on it.

Some decisions about your account are made by computer programs, using your account, verification, plan, billing and AI credit information:

• Decisions made solely by computer programs: whether AI Features and telehealth are available to your account at a given time (based on your verification status, plan, payment status and AI credit balance); pausing AI Features and telehealth when a payment fails or credit runs out; applying your plan's limits; and blocking a sign-in or a password for security reasons (for example, a password found in a known data breach, a failed bot check or too many attempts).
• Decisions where a program does something substantially related to the decision: none for your account. A person at Anchr decides whether your registration is verified, using the information you give us and the public register.

About your clients, AI Features produce drafts, summaries, observations, screening estimates and safety flags that may help you make decisions. Those decisions are yours. If you use AI Features in a way that substantially helps you make decisions that could significantly affect a client, your own privacy policy may need to describe this from 10 December 2026.

You can ask for a person to review any automated decision about your account by emailing privacy@anchr.health.

• Live video and audio for telehealth sessions are carried by Daily, through servers in Australia. They are encrypted in transit.
• A session is recorded only when AI note drafting is on for that session and the client has agreed. For in-person sessions and dictation, the clinician is responsible for obtaining consent before recording.
• Recordings are written directly to Anchr's private, encrypted storage on Amazon Web Services in Sydney. Daily does not keep them.
• Recordings are transcribed in Australia, and the transcript is used to draft your note.
• Each Recording is deleted automatically once you sign the note for that session, and within 7 days of the session at the latest.
• Transcripts and AI drafts are stored with the session record in Australia, and are deleted when that record is deleted.

Some information is processed outside Australia by the providers in section 13 that do not handle client records:

• Payment information, processed by Stripe in Australia and the United States
• Emails sent by the Platform, delivered by Postmark in the United States. This includes the email addresses, names and appointment details in them, and anything you choose to send a client, such as a session summary.
• Participant display names and technical call information held by Daily in the United States (no audio, video or transcripts)
• IP address and browser information checked by Cloudflare's bot protection, on its global network
• Notifications to the Anchr app, delivered by Apple, Google and Expo in the United States (they never contain health details)
• Messages you send to our support mailbox, which is hosted by Microsoft and may be stored outside Australia

These countries include the United States and other countries where those providers operate. Before disclosing personal information to an overseas recipient, we take reasonable steps, including written agreements, to make sure it is handled in line with the Australian Privacy Principles, and we remain accountable for it. Overseas laws may not protect personal information in the same way, and authorities there may be able to access it in some circumstances.

We will not move the storage of Practice Data, or AI, transcription or recording processing, outside Australia without giving you at least 30 days' notice, as the Clinician Terms of Service explain.

Each provider may use information only to provide its service to us, under a written agreement.

13.1 Supabase (Database, Sign-In and File Storage)

• Stores all Practice Data and account information, on Amazon Web Services infrastructure
• Location: Sydney, Australia
• Privacy policy: https://supabase.com/privacy

13.2 Amazon Web Services (AI, Recordings and Transcription)

• Runs Amazon Bedrock for AI Features, stores Recordings, and transcribes them
• Location: Sydney, Australia
• Privacy notice: https://aws.amazon.com/privacy

13.3 Anthropic (AI Model Developer)

• Develops the Claude models we use through Amazon Bedrock. Anthropic does not receive Practice Data or personal information from us.
• Privacy policy: https://www.anthropic.com/legal/privacy

13.4 Daily (Telehealth Video)

• Carries live video and audio, writes Recordings to our storage in Australia, and keeps participant display names and technical call information
• Location: video servers in Australia; account and call information in the United States
• Privacy policy: https://www.daily.co/legal/privacy

13.5 Vercel (Portal Hosting)

• Hosts the clinician portal. Its application servers for the portal run in Sydney, and pages are delivered, encrypted, through its global network.
• Location: Sydney, Australia
• Privacy policy: https://vercel.com/legal/privacy-policy

13.6 Stripe (Payments)

• Processes your subscription and AI credit payments, and client payments made through your connected account, and verifies connected accounts
• Location: Australia and the United States
• Privacy policy: https://stripe.com/au/privacy

13.7 Postmark (Email Delivery)

• Delivers account, security, billing and appointment emails, and emails you send to clients through the Platform
• Location: United States
• Privacy policy: https://postmarkapp.com/privacy-policy

13.8 Cloudflare Turnstile (Bot Protection)

• Checks that sign-ups and sign-ins come from a person, using your IP address and browser information
• Location: global network
• Privacy policy: https://www.cloudflare.com/privacypolicy

13.9 Have I Been Pwned (Password Safety)

• Checks whether a new password appears in a known data breach. Only the first 5 characters of a scrambled (hashed) form of the password are sent, never the password itself or anything that identifies you.

13.10 Halaxy (Anchr Connect Only)

• Exchanges the information you choose with your Halaxy account, if you use Anchr Connect. Halaxy's own privacy policy applies to the information it holds for you.
• Location: Australia

13.11 Apple, Google and Expo (App Notifications)

• Deliver notifications to your clients' Anchr app. Notifications never contain health details.
• Location: United States

13.12 Changes to Providers

We will update this list when we add or change a provider. We will give you at least 14 days' notice before a new provider starts handling Client Data.

• To your clients: the information you choose to share with them, your practice details and branding, and your name in telehealth sessions and emails
• To Ahpra, a National Board, a health complaints body, the police or another authority, where the law requires or permits it, including where we reasonably believe it is necessary to lessen or prevent a serious threat to someone's life, health or safety
• To a court, tribunal or regulator, in response to a lawful request or order. Where it is lawful and practical, we will tell you first.
• To our professional advisers and insurers, in confidence, where needed to obtain advice or manage a claim
• To a business that takes over Anchr, which must protect information as this policy describes. We will tell you before that happens.

• Encryption in transit (TLS 1.2 or higher) and at rest (AES-256), including Recordings and backups
• Two-step sign-in for every clinician account, a 12-character minimum password, checks against known breached passwords, and automatic sign-out after inactivity
• Database access rules that limit each clinician to their own clients, and a client's app information to the categories the client allows
• Append-only audit logs of access to client information
• Least-privilege access for our systems and personnel, and private, access-controlled storage for documents and Recordings
• Automatic deletion of Recordings, as described in section 11

No system is completely secure. If you find a security issue, please tell us at privacy@anchr.health with the subject "Security". We will not take legal action against good-faith security research that follows responsible disclosure.

16.1 Practice Data

• Kept while your account is open and, for each client, while your link with that client exists in Anchr. You can delete records yourself, subject to your own record-keeping obligations.
• Recordings are deleted once you sign the note, and within 7 days of the session at most.
• If a client deletes their Anchr account, the records held in Anchr for your link with that client, including your session notes, are deleted from Anchr. Keep your own copy of records you must retain.
• When your account closes, Practice Data is deleted after the export period described in the Clinician Terms of Service. Encrypted backups are cleared within a further 30 days.

16.2 Your Information

• Account, practice and profile information: while your account is open, then deleted when it closes
• Invoices, payments, platform fees and other tax records: 5 years after the transaction, as Australian tax law requires
• The record of your acceptance of the Clinician Agreement, and of our verification of you: 7 years after your account closes, so we can show what was agreed if a claim arises
• Security audit logs: at least 6 years. When your account is deleted, we keep them in a form that no longer directly identifies you, where the law allows.
• Support emails: as long as needed to resolve the matter and any related claim

When information is no longer needed for any purpose permitted by law, we delete or de-identify it.

• Access: you can see most of your information in the Platform, and ask us for a copy of the rest. We will respond within 30 days.
• Correction: you can update your details in Settings, or ask us to correct information that is wrong. Changes to verified registration details may need to be checked again.
• Export: you can export your Practice Data at any time.
• Marketing: you can unsubscribe from product news at any time. Service messages continue while you have an account.
• Anonymity: because we must verify who you are, you cannot use the Platform anonymously or under a pseudonym.
• Deletion: you can ask us to close your account. Export your records first, because closing your account deletes your Practice Data.

If we refuse a request, we will tell you why, unless it would be unlawful or unreasonable to do so, and how to complain.

• If one of your clients asks us for access to, or correction of, records you hold about them, we will refer them to you, because you are responsible for those records. We will help you retrieve information from the Platform to respond.
• If a client asks about information they gave Anchr through the Anchr app, we handle that request under our Privacy Policy for app users.
• If a client complains to us about how their information was handled in the Platform, we will tell you, unless the law prevents us, and work with you to resolve it.

If we suspect a data breach, we act quickly to contain it and assess it. Under the Notifiable Data Breaches scheme, if a breach is likely to result in serious harm, we notify the Office of the Australian Information Commissioner and the people at risk as soon as practicable.

If a breach affects Practice Data, we tell you without undue delay, and where practicable within 72 hours of becoming aware of it. We coordinate the assessment with you and, where the breach arose in our systems, lead the notification to the regulator and to affected clients in consultation with you, so that clients hear one clear message.

The clinician portal uses only cookies that are needed for it to work: to keep you signed in, complete two-step sign-in, protect against attacks, let clients join telehealth sessions from a link, and remember small display choices (such as a banner you have hidden). It does not use analytics, advertising or tracking cookies, and it does not track you across other websites.

Our website (anchr.health) does not use cookies or analytics. It loads fonts and scripts from public content delivery networks, which receive your IP address and browser details when serving those files.

We will update this policy when our practices or the law change, and update the effective date above. For a material change, such as a new provider handling Client Data or a change to where information is stored, we will tell you by email and in the Platform at least 14 days before it takes effect, or 30 days for a change to where Practice Data is stored or processed. Where the Clinician Terms of Service require it, we will ask you to accept the new version.

Anchr Digital Health Pty Ltd (ACN 696 944 537)

• Privacy enquiries, requests and complaints: privacy@anchr.health (subject "Privacy")
• Security issues: privacy@anchr.health (subject "Security")

We acknowledge complaints within 5 Business Days and aim to resolve them within 30 days. If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (oaic.gov.au, 1300 363 992). For health information, you can also contact the NSW Information and Privacy Commission (ipc.nsw.gov.au), the Health Complaints Commissioner in Victoria (hcc.vic.gov.au), or the ACT Human Rights Commission (hrc.act.gov.au).