Privacy Policy

Spinal Health Hub Pty Ltd — ACN 697 698 490 | ABN 51 697 698 490

Last updated: 1 July 2026

Spinal Health Hub Pty Ltd ("SHH", "we", "us", "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and disclose your personal information when you use our website, mobile applications, programs, AI Chat, and related services (collectively, the "Platform"). This Policy is governed by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). We comply with our obligations as an APP entity.

Service positioning: The Platform provides general health education, movement guidance, and an AI-supported chat feature. It does not provide individualised clinical care and does not establish a clinician-patient relationship between you and SHH or any of its staff or affiliates.

What we do not do: We do not sell your personal information. We do not share health information with third parties for marketing purposes. We do not use AI Chat conversations to train third-party AI models. We do not use your personal information for any purpose not described in this Policy.

If you have questions about this Policy or your personal information, contact us at admin@spinalhealthhub.com or by post at 733 Brunswick Street North, Fitzroy North VIC 3068.

1. Who we are and how to contact us

Entity: Spinal Health Hub Pty Ltd

ACN: 697 698 490

ABN: 51 697 698 490

Email: admin@spinalhealthhub.com

Postal address: 733 Brunswick Street North, Fitzroy North VIC 3068

If you wish to make a complaint about how we have handled your personal information, you can contact us using the details above. You also have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

2. Personal information we collect

We collect the following categories of personal information:

Information you provide directly:

• Identity and contact information — name, email address, account credentials.

• Quiz responses — your answers to the Back-Type Quiz, including responses about your back pain, movement patterns, and motivations. Your quiz responses are processed by an automated classification algorithm that matches you to one of four movement patterns. The result is informational only and does not involve clinical judgment by an individual practitioner. You can request information about how this classification works by contacting us.

• Payment information — handled by our payment processor (Stripe). We do not store full card numbers; payment details are tokenised by Stripe.

• Communications — emails, support messages, and any other content you submit through the Platform.

• AI Chat conversations — messages you send through our AI Chat feature, including any information you choose to share with the AI.

Information collected automatically:

• Technical and usage data — IP address, device type, browser, operating system, pages viewed, session timestamps, click and scroll behaviour.

• Cookies and tracking pixels — including the Meta Pixel, Google Analytics, and similar technologies (see section 6 below).

Information collected from third parties:

• Payment confirmation data from Stripe.

• Email engagement data from ActiveCampaign (opens, clicks, deliverability).

• Aggregate audience data from Meta advertising platforms.

3. Health information (sensitive information)

Health information is treated as "sensitive information" under the Privacy Act and is subject to additional protections. Some information you provide through the Platform may constitute health information. This includes:

• Your back pain symptoms and patterns as described in the quiz.

• Your responses to questions about pain, movement, and discomfort.

• Any health-related details you choose to share through AI Chat or other communications.

How we handle health information:

• We collect health information only with your consent, which you give by providing the information through the quiz, AI Chat, or other channels.

• We use health information only for the purposes you have consented to, principally to match you to a back-type classification and provide you with educational content appropriate to that pattern.

• We do not use health information for marketing purposes without your explicit additional consent.

• We do not disclose health information to third parties except as set out in section 7 of this Policy, or where required or authorised by law.

4. AI Chat data handling

Our Platform includes an AI Chat feature ("Spiney"). Spiney is an artificial intelligence character — not a real person — built to answer questions about our program and the four back-type framework.

• Conversations are stored on Chatbase infrastructure (hosted in the United States on AWS). The AI model is provided by Anthropic (Claude Sonnet), accessed via Chatbase.

• Conversations may be reviewed by SHH staff to monitor quality, identify gaps, and improve responses.

• Conversations may be analysed in aggregate, with personal identifiers removed.

• We do not use AI Chat conversations to train any AI model. Anthropic API data is not used for training unless explicitly opted in (we have not opted in).

• Retention period is up to 90 days.

• You may request deletion at any time via admin@spinalhealthhub.com. Requests are processed within 30 days.

• By using AI Chat, you consent to cross-border data transfer to the United States.

AI Chat is not a clinician and does not provide medical advice. It does not create a clinician-patient relationship.

5. How we use your personal information

We collect and use personal information only where reasonably necessary:

To provide the Platform:

• Creating and managing your account.

• Delivering quiz and classification results.

• Providing program content and AI Chat.

• Processing payments and subscriptions.

• Customer support.

To improve the Platform:

• Usage analysis and UX improvement.

• AI Chat quality review.

• De-identified research.

To communicate:

• Transactional emails.

• Marketing emails (with consent and opt-out).

• Policy and service updates.

Legal purposes:

• Compliance with laws.

• Fraud prevention and security.

• Legal enforcement.

6. Cookies and tracking technologies

We use cookies, pixels, and similar technologies:

• Essential cookies — platform functionality.

• Analytics cookies — Google Analytics.

• Advertising cookies — Meta Pixel.

7. Who we share your personal information with

Service providers:

• Stripe — payments (stripe.com/au/privacy)
• Kajabi — content delivery (kajabi.com/policies/privacy)
• ActiveCampaign — email marketing (activecampaign.com/legal/privacy-policy)
• Webflow — hosting (webflow.com/legal/privacy)
• Chatbase — AI Chat (chatbase.co)
• Anthropic — AI model (anthropic.com/legal/privacy)
• Meta — advertising (facebook.com/privacy/policy)
• Google — analytics (policies.google.com/privacy)

We do not sell personal information.

8. International data transfers

Your data may be transferred outside Australia, including the United States, where service providers operate.

9. How long we keep your personal information

• Account data — life of account + 24 months
• Payment records — 7 years
• Quiz data — account duration
• AI Chat — 90 days
• Support data — 24 months
• Marketing data — until consent withdrawn + 24 months
• Backups — up to 90 days

Anonymised data may be retained indefinitely.

10. Security

We use encryption, access controls, monitoring, and secure providers. No system is fully secure.

11. Marketing communications

Marketing emails are sent only with consent and include unsubscribe options.

12. Your rights

• Access personal information
• Correct information
• Request deletion (subject to law)
• Withdraw consent
• Make complaints

Contact: admin@spinalhealthhub.com

13. Children

Platform is for users 18+. We do not knowingly collect children’s data.

14. International users

Users outside Australia are responsible for local laws. GDPR/CCPA rights may apply.

15. Third-party links

We are not responsible for third-party privacy practices.

16. Changes to this Policy

We may update this Policy. Material changes will be notified where required.

17. Contact us

Spinal Health Hub Pty Ltd
ACN 697 698 490
ABN 51 697 698 490
admin@spinalhealthhub.com
733 Brunswick Street North, Fitzroy North VIC 3068