Privacy Policy

1Who we are

J & T Consortium Pty Ltd (ABN 94 654 852 810), trading as Real Women’s Health is responsible for the personal information it collects and holds in connection with its services.

Email: hello@realwomenshealth.au
Website: Our official Real Women’s Health website

We handle personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles and applicable Victorian health privacy requirements, including the Health Records Act 2001 (Vic). Where another law provides additional protections, we comply with the applicable requirements.

2The information we collect

The information we collect depends on how you interact with RWH. It may include:

Contact and account information: name, email address, telephone number, location, date of birth where relevant, account details and communication preferences.

Enquiries and program information: quiz responses, enquiry forms, messages, consultation bookings, consultation notes, enrolment details, selected program, start date, attendance, check-ins and feedback.

Health and other sensitive information: health history, symptoms, diagnoses you disclose, current care, medication and supplements, allergies, menstrual and reproductive health, pregnancy-related information, digestive health, sleep, stress, nutrition, lifestyle, exercise, medical and pathology reports and health goals. This may include information you provide through written questionnaires, food diaries, photographs, recordings or consultations.

Payment and administrative information: products or services purchased, invoices, amounts paid, payment plans, transaction status, billing contact information and records of your agreement. Card payments may be processed by a third-party payment provider; we do not need to collect or store your complete card details for ordinary payment processing.

Website and digital-use information: device and browser information, IP address, pages viewed, links clicked, website interactions, cookies and similar identifiers, where collected by our website or approved technology providers.

Community and communication information: messages you send us, communications in private client groups, questions raised in group calls and any photographs, videos, reviews or testimonials you choose to submit.

We seek to collect only information reasonably necessary for our activities. We do not require you to disclose irrelevant personal details.

3How we collect information

We generally collect information directly from you when you:

• visit our website or complete a health quiz, assessment, enquiry, application or intake form;
• book a call, speak with our team or communicate by email, telephone, SMS, social media or messaging;
• enrol, make a payment or access the client portal;
• submit pathology results, health questionnaires, food diaries or weekly check-ins;
• attend individual consultations or group sessions; or
• provide feedback or separately agree to share a testimonial.

With your authority or as otherwise permitted by law, we may also receive relevant information from a pathology provider, your GP or another health professional, a referral source or a person you authorise to communicate with us.

If you send us information about another person, please ensure you are entitled to share it. If we receive information we do not need, we will assess whether it should be retained or securely deleted.

You can make general enquiries without identifying yourself where practical. To provide individualised coaching, manage payments and review pathology, we need sufficient accurate information to identify and support you.

4Why we collect, use and disclose your information

We use personal information for purposes reasonably connected with our services, including to:

1. respond to enquiries and explain available services;
2. evaluate whether our program may be appropriate for you and explain our scope of practice;
3. administer enrolment, booking, billing, payments, refunds and client accounts;
4. review information you supply, develop and adapt personalised coaching recommendations and document your progress;
5. coordinate pathology processes and communicate with relevant providers where you have authorised us or the law permits;
6. communicate about appointments, weekly program activities, results received, support requests and important safety information;
7. deliver your online portal, educational resources, group calls and community access;
8. maintain appropriate business, health, financial and consent records;
9. investigate complaints, address service issues, meet legal or regulatory obligations and protect clients or others where legally authorised; and
10. improve our services using feedback and aggregated or de-identified information where practicable.

We do not use your identifiable health information for unrelated marketing, public case studies or testimonials merely because you have enrolled.

5Consent and health information

Health information is sensitive information. We request the informed consent required by law before collecting it, unless another lawful exception applies. At the point of collection, our separate health information collection notice explains what information is sought, why it is needed and who may receive it.

You may choose not to provide requested information. However, without information necessary for safe and personalised coaching, we may be unable to assess your suitability, review results or provide particular services. We will explain relevant consequences when they arise.

You can contact us to withdraw consent for an optional use or disclosure. Withdrawal applies prospectively, subject to legal obligations and other lawful reasons to retain or use information. If consent is essential to a particular service, withdrawing it may affect our ability to provide that service.

6Pathology and communication with other health professionals

Depending on the offer you purchase, RWH may pay for pathology request forms on your behalf through iMedical, or you may arrange testing privately or with your GP. Pathology and laboratory services are provided by independent providers under their own privacy and clinical arrangements.

Where you use iMedical, iMedical may send pathology results directly to RWH for your coaching review, as well as communicating with you under its own procedures. For other pathology pathways, you may provide us with your report through an approved private channel. We may share information with iMedical, your GP or another treating practitioner with your authority or where another lawful basis applies, including when needed to respond to a serious safety concern.

We do not assume that a pathology report has been sent to us unless we have received it. We are not an emergency or continuous pathology monitoring service. Where we identify a potentially concerning result, we may recommend timely medical assessment and communicate relevant information as permitted by law. The pathology provider and any treating medical practitioner remain separately responsible for their own services.

7Who may access or receive information

We share information only where reasonably necessary, authorised by you or permitted or required by law. Recipients may include:

• Our practitioners and authorised team: people who need information to deliver your coaching, client support, scheduling, financial administration or other approved responsibilities, subject to appropriate confidentiality requirements.
• Technology and administration providers: systems used to manage contacts, forms, appointments, program delivery, records, messages and payments. Depending on the activity, these include GoHighLevel, Google Workspace and Google Drive, Jotform, ScoreApp, Zoom, Meta/Facebook/Messenger, ManyChat, Stripe and Mailgun. Mailgun processes information such as email addresses and email delivery metadata to send our emails.
• Content production and testimonial editing: where a client has separately authorised the relevant use of their image, recording, words or testimonial, we may use CapCut, Riverside and Canva to edit and prepare that material. These providers may process uploaded recordings, images, audio and related information.
• AI-assisted administration and resource development: we use ChatGPT (OpenAI) and Claude (Anthropic) for administrative support, organising notes, scheduling-related preparation and developing educational resources. We aim to use de-identified information where practicable and restrict identifiable health information to arrangements that have been assessed as appropriate and authorised for that use. These tools do not replace practitioner judgement.
• Pathology and relevant health providers: iMedical, laboratories, your GP or another professional, when applicable and lawfully authorised.
• Professional advisers, insurers and authorities: where necessary for legal advice, insurance, accounting, dispute resolution, safeguarding or compliance obligations.

ScoreApp and GoHighLevel: When you complete a ScoreApp quiz, your contact details are transferred to GoHighLevel for enquiry management and relevant follow-up. RWH does not intentionally transfer your quiz answers or health information from ScoreApp to GoHighLevel through this integration or share those answers with advertising platforms. ScoreApp itself processes the information you submit in the quiz in order to provide that service.

We do not sell your health records or intentionally provide identifiable client health information to advertising platforms for their marketing purposes.

The providers above may process information on our behalf or act as independent organisations under their own privacy terms. We aim to limit each provider’s access to information needed for its role. The precise providers in use may change as we update our systems, and material changes will be reflected in this Policy or relevant collection notices.

8Website analytics, cookies and advertising

Our website and marketing systems may use cookies, analytics tools, conversion measurement or advertising technologies, including tools associated with Meta and other platforms. These technologies may collect information about website visits, devices and interactions to help us measure performance and show relevant advertising.

Our ScoreApp integration with GoHighLevel transfers contact details only, not quiz answers or health information. We do not intentionally transmit pathology reports, completed health questionnaires or other sensitive health information to advertising platforms. Separately, website cookies and tracking tools may collect information about pages visited, devices and interactions. We review these tools to minimise any risk that information suggesting a person’s health concerns is disclosed to advertising providers and obtain consent where required by law.

You can manage some cookies and tracking through your browser or through controls we provide on our website. Disabling them may affect some website functions. Where consent is legally required, we will provide an appropriate choice before activating the relevant technology.

9Marketing communications

If you request information or subscribe to communications, we may send relevant program information, educational content and promotional messages where we have the consent or other lawful basis required. We do not use sensitive health information to target marketing without the consent required by law.

You can opt out of promotional emails and messages using the unsubscribe instructions provided or by emailing hello@realwomenshealth.au. We will action requests within the time required by law. Opting out of marketing does not prevent necessary communications relating to an active enrolment, payment, consultation or important service matter.

We seek separate permission before publishing identifiable testimonials, client photographs, private progress updates or health stories. You may withdraw that permission for future use. We will take reasonable steps to stop new use and remove materials from channels we control, recognising that material already independently shared may not always be recoverable.

10Individual consultations and group sessions

Individual consultations: If we propose to record, transcribe or use an AI-assisted note-taking tool in an individual consultation, we will explain the purpose, provider and handling of the information and obtain any consent required before use. Where recording is optional, declining does not prevent you attending the underlying consultation. We will not assume consent from your acceptance of program terms alone.

Group sessions: Some educational group calls may be recorded for replays accessible within the client program. Participants will be informed when recording is taking place. We make reasonable efforts to focus on presenters and to exclude identifying participant contributions from replays, but cannot promise that all names, comments, images or audio will be excluded. Please do not disclose sensitive health information or third-party details in group sessions or group chats. Use the private channels we nominate for personal medical information.

Social platforms: Facebook communities and social messaging platforms are not suitable locations for detailed medical histories or pathology reports. Other participants may see content you post in group spaces, and platform operators have their own data practices. Please contact us privately if a post or replay contains information you believe should be removed. We will assess and respond appropriately.

11Overseas storage and disclosure

RWH is an Australian business and manages its client records from Australia. We use third-party online services to collect, communicate, store and process information. Some of these providers, their support personnel or subcontractors may be located overseas, so information may be stored, accessed or processed outside Australia even when our team accesses it from Australia.

We are confirming the locations relevant to the specific provider services and account settings we use. The likely locations of overseas recipients depend on the services and account configurations in use. We will identify the relevant countries where practicable by reviewing provider information and update this Policy when those details are confirmed. You may contact us for information about the overseas processing arrangements relevant to your records.

Where the Australian Privacy Principles require it, we take reasonable steps before disclosing personal information to overseas recipients to ensure appropriate privacy protections apply, unless a legal exception is available. We assess the relevant provider arrangements and safeguards rather than assuming that using an established technology provider eliminates privacy risks.

12How we protect information

We take reasonable administrative and technical steps to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure. These include appropriate access permissions, authentication, staff confidentiality expectations, approved recordkeeping processes, restricted sharing, system maintenance and review of providers and access permissions.

Access to identifiable health records is intended to be limited to authorised staff and providers with a legitimate role. We review permissions for cloud records, including Google Drive, and seek to avoid public or unrestricted sharing links for client health records.

No website or digital storage system can guarantee absolute security. If an incident occurs, we will investigate, contain and assess it, take remedial action and notify affected people and the Office of the Australian Information Commissioner where required by the Notifiable Data Breaches scheme or other applicable law.

Please notify us if you believe information has been sent to the wrong person, a client record has been exposed or your account has been compromised.

13How long we retain information

We retain information for as long as reasonably necessary for its purpose and to meet our legal, professional, insurance, accounting and dispute-resolution obligations.

We retain client health records for at least seven years after the last health service, or longer where law or another legitimate requirement applies. Where applicable, records relating to a person who received services while under 18 may need to be kept until that person turns 25. Certain records may need to be retained longer where another legal requirement or an ongoing matter applies.

Enquiry records, marketing preferences, payment records and website analytics may have different retention periods. When information is no longer required, we take reasonable steps to securely destroy or de-identify it, subject to applicable law and any necessary backup processes. Ending your program or withdrawing a marketing consent does not automatically require deletion of records we are legally obliged to retain.

14Accessing or correcting your information

You may request access to personal or health information we hold about you or ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading.

Please email hello@realwomenshealth.au and describe your request. We may need to verify your identity before disclosing information. We will respond within the timeframe required by applicable law and explain any lawful reason why access or correction cannot be provided. Where a lawful access fee applies, we will explain it in advance; we do not charge a fee simply to request a correction.

If we do not agree to amend a record, you may be entitled to have a statement of your requested correction associated with it.

15Automated systems and AI-assisted processing

Some of our forms, quizzes and administration systems may automatically calculate responses, assign scores, organise enquiries, trigger reminders or help us manage your program. A quiz or automatically generated score is an informational or administrative tool and is not a medical diagnosis.

Personalised coaching recommendations, clinical referrals and decisions about whether an individual service is appropriate are intended to involve a human team member rather than being determined solely by an automated quiz score.

We will review our automated decision-making arrangements as privacy requirements change, including requirements commencing on 10 December 2026.

We do not use AI tools as a substitute for professional assessment of your health information. Where AI-assisted tools are used to organise notes or assist with resource preparation, we seek to minimise personal information shared with those tools, apply appropriate access and security controls and obtain any consent required by law. We do not use identifiable client health information to train our own AI model. Use of a provider’s service may be subject to that provider’s separate processing terms and settings.

We do not authorise optional AI recording or transcription of an individual consultation without the explanation and consent required for that activity. Any authorised use must comply with our confidentiality and privacy obligations.

16Links and third-party platforms

Our website and client resources may link to independent websites, booking pages, social media or other providers. Their privacy practices may differ from ours. We encourage you to read their privacy information when providing data directly to those organisations.

17Privacy concerns and complaints

If you have a question, believe your information has been handled incorrectly or wish to make a privacy complaint, contact:

Privacy Contact, Real Women’s Health
Email: hello@realwomenshealth.au

Please describe the concern, relevant dates and the outcome you are seeking. We will acknowledge your complaint, investigate it and aim to provide a substantive response within 30 days, or update you if additional time is reasonably required.

If you are dissatisfied with our response, you may be entitled to complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or, for matters within its jurisdiction under Victorian health privacy legislation, the Victorian Health Complaints Commissioner at hcc.vic.gov.au.

18Changes to this Policy

We may update this Privacy Policy to reflect changes in our services, providers, privacy practices or legal requirements. The current version will be available on our website with its last updated date. Where a change requires a fresh collection notice or consent, we will provide it before the relevant collection, use or disclosure.