In this Privacy Policy, ‘us’ ‘we’ or ‘our’ means FreshClaim Pty Ltd - ACN 662 233 749. We are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store and disclose your Personal Information.
When you provide Personal Information to us (or, in the case of a Patient, where your Health Practitioner provides your Personal Information to us), we process your Personal Information in accordance with this Privacy Policy.
We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.
Definitions
In this Privacy Policy, the following capitalised terms have the following meanings:
- Eclipse means the Electronic Claim Lodgement and Information Processing Service Environment, operated by Services Australia, used to submit claims and process payments for Medicare and private health fund benefits.
- Health Data means information or an opinion about an identified individual, or an individual who is reasonably identifiable, that relates to their health, disability, medical history, medical treatment, or health services provided to them, and includes any information collected to provide, or in providing, a health service.
- Health Fund means a private health insurer registered under the Private Health Insurance (Prudential Supervision) Act 2015 (Cth) with which a Patient holds membership, and to which claims may be submitted via the Services.
- Health Practitioner means a medical practitioner (or authorised practice staff) who registers for and uses the Services.
- Medicare means the Australian government scheme, administered by Services Australia, that provides for the payment of benefits in respect of certain health and medical services.
- Non-Personal Information means information that does not relate to a person and/or cannot be used to identify a person.
- Patient means an individual who receives medical services from a Health Practitioner, whose Personal Information is processed via the Services.
- Patient Data means information about a Patient provided to us by a Health Practitioner via the Services, including Health Data, procedure/claim details, and information captured by scanning a patient label.
- Personal Information means any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be Personal Information regardless of whether it is true, and includes Patient Data and Health Data.
- Privacy Act means the Privacy Act 1988 (Cth).
- Service means the provision of our medical billing solution.
- Services Australia means the Australian government agency responsible for administering Medicare and delivering government payments and services, including the operation of Eclipse.
- User, you or your means any person using our Service whatsoever, including a Health Practitioner, and also Patients, as the context requires.
What Personal Information do we collect?
Information you voluntarily provide to us: We collect information about you and your interactions with us, for example, when you purchase or use any of our Service, call us, or otherwise visit our website. We also collect information about a Patient that is provided to us by their Health Practitioner, for the purpose of submitting claims and processing payments via the Services.
If you are a Patient then we may be provided with the following from your Health Practitioner, and the verifications or confirmations from the Eclipse or private health fund systems, so that we can provide our billing services to the Health Practitioner:
- information captured by the Health Practitioner when using our Service, eg by scanning your patient label;
- your Medicare card, number and/or Health Fund membership details;
- details of any procedure or service and related billing or claim information constituting Health Data (as provided to us by your Health Practitioner); and
- any payment details necessary to process any gap payments you make via the Service.
If you are a Health Practitioner then we will collect the data we receive about you and other information required to provide our Service, including:
- your name and contact information such as email address and phone number;
- name of your organisation (if applicable);
- demographic or geographic information such as postal code;
- history of purchases and use of our Services and details of enquiries or complaints you make;
- login credentials for third-party websites (if you use such third-party accounts to log into our Service); and
- your AHPRA registration and/or Medicare provider number.
Information we automatically collect: We also automatically collect certain technical data that is sent to us from the computer, mobile device and/or browser through which you access the Service (Automatic Data). Automatic Data, includes without limitation, a unique identifier associated with your access device and/or browser (including, for example, your Internet Protocol (IP) address), characteristics about your access device and/or browser, statistics on your activities on the Service, details of the Services we have supplied to you or that you have enquired about, including any additional information necessary to deliver those Services and respond to your enquiries, or information about how you came to our website.
Information we obtain from others: We may also collect or receive Personal Information from third-party sources, such as Eclipse and Services Australia, the relevant Health Fund, and our payment processor (currently Stripe), in connection with our Service, the claims and payments described in this Privacy Policy.
Non-Personal Information: When you interact with the Services, we may collect Non-Personal Information. The limitations and requirements of this Privacy Policy on our collection, use, disclosure, transfer and storage/retention of Personal Information do not apply to Non-Personal Information. When you register to the Services or otherwise submit Personal Information to us, we may associate other Non-Personal Information (including Non-Personal Information we collect from third parties) with your Personal Information. At such instance, we will treat any such combined data as your Personal Information until such time as it can no longer be associated with you or used to identify you.
Why do we collect, use and disclose Personal Information?
We may collect, hold, use and disclose your Personal Information for the following purposes:
- where you are a Patient, to submit claims on your Health Practitioner’s behalf to Medicare, Services Australia and/or the relevant Health Fund via Eclipse, and to process any gap payment owed by you (Gap Fee) via our payment processor; in each case, we act as a conduit that receives your Health Data from your Health Practitioner and passes it on for this purpose, and we do not use it for any other purpose;
- where you are a Health Practitioner:
- provide you with Services, and manage our relationship with you;
- to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- to operate, protect, improve and optimise our Services, business and our users’ experience, such as to perform analytics and conduct research, including to improve the accuracy of our patient label scanning technology and to identify patterns in claim underpayment or rejection, using Health Data only in a de-identified and aggregated form for this purpose;
- to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting (this paragraph does not apply to Health Data, which we will never use for marketing purposes);
- to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners; and
- to comply with our legal obligations, resolve any disputes that we may have with any of our users or customers, and enforce our agreements with third parties.
The information we collect is not distributed, sold or leased to third parties for commercial purposes, except to provide Services you have requested or for other purposes when we have your permission or when we are obliged to do so. We will never sell or lease Health Data.
Automated Processing: we will extract data using automated technology from stickers or other files uploaded by the Health Practitioner and then submit that data to the Eclipse system or directly to your Health Funds as part of the claim information. We merely use that automated processing to assist the Health Practitioner make funding claims through the Eclipse system. We are not making any decisions on your behalf.
To whom do we disclose your Personal Information?
We may disclose Personal Information for the purposes described in this Privacy Policy to:
- our employees and staff members;
- our related bodies corporate;
- third-party suppliers and service providers who are relevant for our provision of the Services to our Health Practitioners, including our cloud hosting providers and our accounting software provider, for the purpose of operating the Services and administering Health Practitioner accounts and invoicing;
- Medicare, Services Australia and/or the relevant Health Fund, via Eclipse, for the purpose of submitting claims on behalf of a Health Practitioner;
- our payment processor (currently Stripe), for the purpose of processing Gap Fee payments;
- our professional advisers, dealers, stakeholders and agents;
- our sponsors or promoters of any competition that we conduct via our Services;
- anyone to whom our assets or businesses (or any part of them) are transferred;
- anyone you have specifically agreed can receive Personal Information, or where such consent can be reasonably inferred from the circumstances; and/or
- other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
Health Data is only disclosed for the purposes set out in paragraphs (c) and (d) above, and to any other person to the extent required or authorised by law. We do not disclose Health Data for any other purpose, including marketing.
Do we use your Personal Information for marketing?
We will use the contact information of Health Practitioners to offer them Services we believe may interest them, but we will not do so if they tell us not to. These Services may be offered by us, our related companies, our other business partners or our service providers.
Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.
For the avoidance of doubt, this clause does not apply to Health Data. We will never use Health Data for marketing purposes.
Using our Services, website and cookies
We may collect Personal Information about you when you use and access our Service and website. While we do not use browsing information to identify you personally, we may record certain information about your use of our Service and website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.
We also use cookies, web beacons and other tracking technologies to collect certain information about your equipment, browsing actions, and patterns. Below we describe what are cookies and web beacons, why we use cookies and web beacons, the types of cookies and web beacons that we use as well as what you can do in order to manage and delete cookies and web beacons.
What are cookies and web beacons?
- Cookies are small text files that websites often store on computer hard drives or mobile devices of visitors to their websites. A cookie contains a unique number, which is used to recognise your computer or mobile device when you return to our Service and website. Cookies can remain on your computer or mobile device for different periods of time. The cookies can be either “persistent” cookies or “session” cookies. Persistent cookies are stored by a web browser and remain valid until a set expiration date. Session cookies only exist while your internet browser is open and are automatically deleted once you close your browser.
- Web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) are small electronic files contained on pages of websites that permit companies to count users who have visited certain webpages on a website and are used for other related website statistics (e.g., recording the popularity of certain website content and verifying system and server integrity).
What do we use cookies and web beacons for?
We use a variety of cookies, web beacons and other tracking technologies for different purposes. Specifically, we use cookies and web beacons to enhance the experience of our visitors to our Service and website (for example, by remembering your preferences and letting you navigate between pages efficiently) and to better understand how our Services and website are used. Cookies may tell us, for example, whether you have visited our Service and website before or whether you are a new visitor.
We may also use cookies to enable us to collect data that may include Personal Information. For example, where a cookie is linked to your account, it will be considered Personal Information under the Privacy Act. We will handle any Personal Information collected by cookies in the same way that we handle all other Personal Information as described in this Privacy Policy.
What types of cookies and web beacons are used by us?
We use both first-party and third-party cookies and web beacons. First-party cookies and web beacons are cookies and web beacons that are served directly by us to your computer or mobile device. Third-party cookies and web beacons are served by a third-party service provider on our behalf. Third-party cookies are most commonly used for advertising and analytics purposes.
There are four categories of cookies and web beacons used by us. Specifically, we use essential, performance, functionality and advertising cookies and web beacons.
- Essential cookies, web beacons and other tracking technologies are necessary for the operation of our Services and website. These tracking technologies enable you to move around on our Services and website and use our Service features. You may not opt out of these types of cookies because they are required to operate our Services and website.
- Performance cookies, web beacons and other tracking technologies collect information about how you have used our Services and website. We use performance cookies, web beacons and other tracking technologies to improve the user experience with our Services and website.
- Functionality cookies, web beacons and other tracking technologies allow us to remember how you are logged into our Service, when you logged in or out and the actions you have taken while you have been logged into our Services.
- Advertising cookies, web beacons and other tracking technologies are used by our third-party service providers to deliver advertising to you on other third-party websites as well as help measure the effectiveness of our advertising campaigns. We also use these types of cookies to analyse our Services’ and website’s visits and ad conversions from third-party websites.
What are your choices about cookies?
It is your choice as to whether or not to accept cookies. Most browsers allow you to configure the browser settings so that cookies from websites cannot be placed on your computer or mobile device. If you choose not to accept cookies, then you may be able to continue browsing our Services but we may not be able to provide you with certain features. If you would like further information about cookies and how to manage and delete them, please visit www.allaboutcookies.org or www.youronlinechoices.eu.
How do we store and hold Personal Information?
We may hold your Personal Information in either electronic or hard copy form. We take reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your Personal Information. However, we cannot guarantee the security of your Personal Information.
We protect Health Data using industry-standard security measures, including encryption in transit and at rest, restricted and role-based access controls, and continuous system monitoring. Please see our security page for more information. Our data is hosted within Australia in secure data centres, with redundancy across multiple availability zones and regular backups. Health Data is stored on servers located in Australia.
Location of your Personal Information
Your information, including Personal Information, is processed at our operating office in Australia and we will not transfer or access any Personal Information of Patients outside of Australia.
Retention
Ordinarily, we will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. If you are a registered user for any Service, then we usually will retain your Personal Information as long as you maintain your account and for up to 7 years following the account’s closure. You can ask us to close your account and delete data earlier. This subclause applies to Health Practitioners.
For Patients: we retain claim data (item numbers, billing information etc) for up to 7 years from the date it is collected, to meet our record-keeping obligations in connection with Medicare and Health Fund claims, and to allow for any dispute, audit or compliance requirement relating to those claims.
You may close your account by contacting us. However, we may sometimes retain Personal Information for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Information it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.
Exclusions
Links: Our Services and website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.
Personal Information Provided to Others: This Privacy Policy does not apply to any Personal Information that you provide to another user or visitor through the Service or through any other means.
Accessing or correcting your Personal Information
You can access the Personal Information we hold about you by contacting us. Sometimes, we may not be able to provide you with access to all of your Personal Information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your Personal Information.
If you think that any Personal Information we hold about you is inaccurate, please email us and we will take reasonable steps to ensure that it is corrected.
We will consider and respond to all requests in accordance with all applicable laws.
Where a request under this clause relates to Health Data, we may refer you to your Health Practitioner, who holds your primary medical record and may be better placed to assist with your request, in addition to (not instead of) actioning your request ourselves.
Making a complaint
If you think we have breached the Privacy Act or any other relevant privacy law, or you wish to make a complaint about the way we have handled your Personal Information, you can contact us. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available.
Contact Us
For further information about our Privacy Policy or practices, or to access or correct your Personal Information, or make a complaint, please contact us at support@freshclaim.com.au
Version 1.1
Effective: 21 August 2026