Legal
Privacy Policy
Effective date: 01/10/2025
Clarity Laboratories Pty Ltd (ACN 689 290 426) trading as Clarity Labs ("we", "us”, “our” or “Clarity Labs”) is committed to privacy protection. Clarity Labs operates within the health and wellness sector, providing technology-enabled services that help individuals understand their blood test results through clear, data-driven insights. While we facilitate referrals to pathology services and use advanced tools (including artificial intelligence) to transform health-related data, we are not a healthcare provider, and we do not offer medical advice, diagnosis, or treatment.
At https://www.claritylabs.com.au (the “Platform"), we understand the importance of keeping Personal Information and Sensitive Information (such as health data) private and secure. This privacy policy ("Privacy Policy") describes generally how we manage your information and safeguard privacy. If you would like more information, please don't hesitate to contact us.
For our most up-to-date contact information, please visit us at our Contact Us page, located at https://www.claritylabs.com.au/contact. For privacy-related inquiries, you can email us at privacy@claritylabs.com.au. We are committed to responding within thirty (30) days.
This Privacy Policy forms part of, and is subject to the provisions of, our Website Terms and Conditions, located at https://www.claritylabs.com.au/terms.
We care about your privacy:
We will never rent, trade or sell your email address to anyone.
We will never publicly display your email address or other personal details that identify you.
The Australian Privacy Principles
We will treat all Personal Information in accordance with any and all obligations that are binding upon us under the Privacy Act 1988 (Cth) (“Privacy Act”). The Privacy Act lays down 13 key principles in relation to the collection and treatment of Personal Information, which are called the “Australian Privacy Principles” (“APPs”).
Personal Information that we collect
"Personal Information" held by Clarity Labs may include your:
name and date of birth;
company ACN or ABN numbers, full name, email address and mobile number for individuals using the Platform;
residential and business addresses, telephone or mobile numbers and email addresses;
bank account and/or credit card details for agreed billing purposes;
any information that you provided to us by you during your account creation process;
password for using this Platform and your computer and connection information;
lifestyle information, including professional status, activity levels, and life stage indicators;
health service preferences and general categories of previous testing history;
website usage patterns, including test selection preferences, to support tailored service recommendations;
responses to questionnaires relating to wellness goals and health interests;
communication preferences, including those related to educational content and partner recommendations; and
any information that you otherwise share with us.
Please note that we do not collect or process Medicare numbers. All services are provided on a direct-pay basis, with no Medicare rebates available.
How we may collect your Personal Information
At this Platform, we only collect Personal Information that is necessary for us to conduct our business.
Information that you provide to us
We may collect Personal Information that you provide to us about yourself when you:
use this Platform, including (without limitation) when you:
create a User account;
add information to your User profile;
purchase any Services through this Platform;
complete an online contact form to contact us; or
contact us via email or other communication.
Sensitive Information (including health information) that we collect
In the course of providing our services, we may collect "Sensitive Information" as defined in the Privacy Act. This may include information or an opinion about your health, medical history, pathology referrals, or other health-related data that is relevant to facilitating your access to third-party blood testing and pathology services.
Sensitive Information that we collect may include (but is not limited to):
General information or opinions about your health, medical history, or pathology referrals;
Health focus areas and wellness goals, such as energy optimisation, stress management, cardiovascular health, hormonal balance, and nutritional concerns;
Lifestyle factors that may influence health recommendations, including professional stress levels, activity patterns, and life stage indicators;
General categories of past health services or testing preferences (excluding specific test results unless explicitly provided);
Symptoms or health concerns you disclose for the purpose of tailoring test recommendations; and
Responses to health-related questionnaires, used to personalise both educational content and suggested tests.
Although we do not provide medical services, medical advice or treatment, we understand the sensitive nature of the information that may be collected through your use of our Platform. As such, we treat all Sensitive Information with the highest standard of confidentiality and in strict accordance with the APPs.
We will only collect Sensitive Information:
With your express consent (for example, when you voluntarily enter or upload information in relation to a pathology referral request);
Where it is reasonably necessary for us to carry out our functions and activities, such as facilitating referrals to third-party Laboratory Partners; or
Where required or authorised by law.
We will never use Sensitive Information for purposes unrelated to the services we provide, and we will not disclose it to third parties except:
To Laboratory Partners or other third parties directly involved in the fulfilment of your request;
To our trusted technology or operational partners, strictly on a need-to-know basis and subject to binding confidentiality obligations;
Where legally required, such as in response to a court order or statutory authority; or
Where you otherwise provide your express consent.
You may withdraw your consent for us to collect or retain your Sensitive Information at any time by contacting us (see Contacting Us About Privacy section). However, please note that doing so may limit or prevent us from providing certain services to you.
Cookies
This Platform uses "cookies" to help personalise your online experience. A cookie is a text file or a packet of information that is placed on your hard disk by a web page server to identify and interact more effectively with your computer. There are two types of cookies that may be used at this Platform: a persistent cookie and a session cookie. A persistent cookie is entered by your web browser into the "Cookies" folder on your computer and remains in that folder after you close your browser, and may be used by your browser on subsequent visits to this Platform. A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut down your computer. Cookies cannot be used to run programs. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. In some cases, cookies may collect and store Personal Information about you. Clarity Labs extends the same privacy protection to your Personal Information, whether gathered via cookies or from other sources.
You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. Please refer to your internet browser’s instructions to learn more about these functions. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of this Platform.
Why we use cookies
This Platform uses cookies in order to:
remember your preferences for using this Platform;
manage the signup process when you create an account with us;
recognise you as logged in while you remain so. This avoids your having to log in again every time you visit a new page;
facilitate e-commerce transactions, to ensure that your order is remembered between pages during the checkout process;
show relevant notifications to you (e.g., notifications that are relevant only to users who have, or have not, created an account or subscribed to newsletters or email or other subscription services); and
remember details of data that you choose to submit to us (e.g., through online contact forms or by way of comments, forum posts, reviews, ratings, etc).
Many of these cookies are removed or cleared when you log out, but some may remain so that your preferences are remembered for future sessions.
Third party cookies
In some cases, third parties may place cookies through this Platform. For example:
Google Analytics, one of the most widespread and trusted website analytics solutions, may use cookies de-identified data about how long users spend on this Platform and the pages that they visit;
Google AdSense, one of the most widespread and trusted website advertising solutions, may use cookies to serve more relevant advertisements across the web and limit the number of times that a particular advertisement is shown to you; and
third party social media applications (e.g., Instagram, Facebook, Twitter, LinkedIn, Pinterest, YouTube, Tiktok, etc) may use cookies in order to facilitate various social media buttons and/or plugins in this Platform.
IP addresses
This Platform may also collect Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. Clarity Labs collects and manages IP addresses as part of the service of providing internet session management and for security purposes. Clarity Labs may also collect and use web log, computer and connection information for security purposes and to help prevent and detect any misuse of, or fraudulent activities involving, this Platform.
How we may use your Personal Information
Your Personal Information may be used in order to:
verify your identity;
assist you to place orders through this Platform;
process any purchases of Services that you may make through this Platform, including charging, billing and collecting debts;
make changes to your account;
respond to any queries or feedback that you may have;
prevent and detect any misuse of, or fraudulent activities involving, this Platform;
conduct research and development in respect of our products and/or services;
gain an understanding of your information and communication needs or obtain your feedback or views about our products and services in order for us to improve them; and/or
maintain and develop our business systems and infrastructure, including testing and upgrading of these systems;
and for any other purpose reasonably considered necessary or desirable by Clarity Labs in relation to the operation of our business.
Use of De-Identified or Aggregated Information
We may collect, use and disclose de-identified or aggregated data (i.e., data that does not identify you personally) for analytical, research, service improvement, or reporting purposes.
De-identification is performed in accordance with the Australian Government’s De-identification Decision-Making Framework. De-identified data cannot reasonably be used to identify individuals and is therefore not subject to the Privacy Act’s restrictions.
Information provided to payment gateway providers
All purchases that are made through this Platform are processed securely and externally by one or more third-party payment gateway providers, including Stripe (our current payment gateway provider), and may also include other providers such as Afterpay, PayPal, Google Pay, or Apple Pay from time to time. Unless you expressly consent otherwise, we do not see or have access to any Personal Information that you may provide to such third-party payment gateway providers, other than information that is required in order to process your order and deliver your purchased items to you (e.g., your name, phone number, email address and billing/delivery address).
Marketing and Communications
We may contact you periodically with information about our Services or relevant updates concerning pathology referrals and related health and wellness offerings. We may also share information about trusted partners whose services may be relevant to your health interests or needs.
We do not use test results, health outcomes, or other sensitive health information for marketing segmentation or targeted advertising without your explicit consent. Any marketing communications are based solely on general website activity or your opted-in preferences, and never on health data.
Your privacy and the sensitive nature of health-related information are paramount to us. We handle your Personal Information in strict accordance with applicable privacy laws and only communicate with you where legally permitted. You may opt out of receiving marketing communications at any time by following the unsubscribe instructions included in our messages or by contacting us directly. We will respect your request promptly.
Re-marketing
To help us provide relevant information about our Services, we may use re-marketing tools such as Google AdWords or Facebook Ads. These services allow us to display advertisements to previous visitors of our Platform based on their activity on our site, ensuring the ads you see are relevant to your interests.
We are committed to protecting your privacy and ensure that any data collected by these third-party services is handled according to their privacy policies. We do not receive Personal Information from these providers through re-marketing activities.
You have control over the advertising you receive: you can manage your Google ad preferences at Google Ads Settings (located at: https://www.google.com/settings/ads) and opt out of Facebook targeted advertising via the AdChoices link provided by Facebook.
When we may disclose your Personal Information
In order to deliver the Services you require or for the purposes set out above, Clarity Labs may, only where necessary, disclose your Personal Information to organisations outside Clarity Labs.
Your Personal Information may be disclosed to these organisations only in relation to this Platform, and Clarity Labs endeavours to take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your Personal Information.
These organisations may carry out or provide:
customer enquiries;
mailing systems;
billing and debt-recovery functions;
information technology services;
marketing, telemarketing and sales services;
market research; and
website usage analysis.
In addition, we may disclose your Personal Information to:
your authorised representatives or legal advisers (when requested by you to do so);
our professional advisers, including our accountants, auditors and lawyers;
government and regulatory authorities and other organisations, as required or authorised by law;
organisations who manage our business strategies, including those involved in a transfer/sale of all or part of our assets or business (including accounts and trade receivables) and those involved in managing our business risk and funding functions; and
the police or other appropriate persons where your communication suggests possible illegal activity or harm to others.
Disclosure to Pathology Providers and Trusted Partners
To deliver our Services, we may disclose your Personal Information and Sensitive Information on a need-to-know basis to our NATA-accredited Laboratory Partners and technology service providers as listed on our Current Partners page (available at: https://www.claritylabs.com.au/partners) from time to time.
The entities referred to above are independent data controllers and have their own privacy obligations. We take reasonable steps to ensure they:
Use your information only for the purpose of providing diagnostic services;
Implement security protocols in line with healthcare industry standards; and
Comply with relevant privacy legislation and best practices.
We encourage you to review their individual privacy policies for more information on how your data is handled.
Corporate Wellness Programs
Where Services are provided as part of a corporate wellness program, we only disclose de-identified, aggregated reporting to the employer. Identifiable personal information will not be disclosed to the employer unless the employee has provided their explicit written consent.
Storage and security of your Personal Information
We are committed to maintaining the confidentiality of the information that you provide us and we will take all reasonable precautions to protect your Personal Information from unauthorised use or alteration. In our business, Personal Information may be stored both electronically (on our computer systems and with our website hosting provider) and in hard-copy form. Firewalls, anti-virus software and email filters, as well as passwords, safeguard and protect all of our electronic information. Likewise, we take all reasonable measures to ensure the security of hard-copy information.
Storage and security of your Sensitive Information
We treat Sensitive Information, including any health-related data you provide, with the highest level of care and confidentiality. In addition to the general data security measures applied to all Personal Information, we implement enhanced safeguards for Sensitive Information. These include:
Role-based access controls, ensuring only authorised personnel can access this information;
Encryption of data in transit and at rest using industry-standard protocols;
Secure storage on servers with continuous monitoring and intrusion detection systems; and
Routine internal audits and penetration testing to maintain security integrity.
We also ensure that third parties handling Sensitive Information on our behalf are contractually required to uphold equivalent or greater security and privacy standards.
Data Retention
We retain Personal Information and Sensitive Information for as long as is necessary to provide our services and to comply with our legal and regulatory obligations. Health records are retained in accordance with applicable state Health Records Acts, which generally require retention for a minimum of seven (7) years from the date of last entry, or until the individual turns twenty-five (25), whichever is later. De-identified data may be retained for longer periods for quality improvement purposes.
All health records are stored at rest in Australian data centres with appropriate health data compliance certifications, in accordance with Australian health data residency requirements. Limited encrypted processing may occur offshore where necessary, subject to strict contractual safeguards and vendor certification requirements.
Access, Correction, Deletion and Portability of Your Personal and Sensitive Information
You have the right to request access to Personal Information or Sensitive Information that we hold about you. We will handle all requests in accordance with the APPs and will aim to respond within thirty (30) calendar days. If you request access, we may ask you to verify your identity or confirm your request in writing for security purposes.
You may request:
Access to your Personal Information or Sensitive Information at no charge;
Correction of any information that you believe is inaccurate, incomplete, or out of date, also at no charge;
Deletion of your Personal Information or Sensitive Information, including in connection with account closure, subject to any legal or contractual obligations we may have to retain certain information (e.g. under applicable state Health Records Acts);
Portability of your Personal Information or Sensitive Information, meaning that you may request to receive your data in a structured, commonly used, and machine-readable format (such as PDF or CSV), or have it transferred directly to another service provider, where technically feasible. Where applicable, we will use recognised interoperability standards such as FHIR.
To make a request, please contact us at privacy@claritylabs.com.au with your full name, contact details, and the nature of your request. We may ask you to verify your identity or confirm your request in writing for security purposes.
If we decline your request, we will provide written reasons and explain the options available to lodge a complaint.
Data Breach Notification
We are committed to protecting your Personal Information and Sensitive Information. In the event of a data breach, we will comply with the requirements of the Notifiable Data Breaches (NDB) scheme under the Privacy Act.
An “eligible data breach” occurs when:
There is unauthorised access to or disclosure of Personal or Sensitive Information (or it is lost in circumstances likely to result in unauthorised access or disclosure); and
The breach is likely to result in serious harm to one or more individuals.
If we suspect that a data breach has occurred, we will:
Promptly assess the situation to determine whether it qualifies as an eligible data breach;
Take immediate steps to contain the breach and minimise any risk of harm;
Notify affected individuals and the Office of the Australian Information Commissioner (OAIC) within seventy-two (72) hours where serious harm is likely to result;
Provide free identity monitoring services where there is a risk of identity theft; and
Take action to prevent future breaches, including reviewing and updating our security practices where necessary.
If you believe that your Personal or Sensitive Information has been compromised, please contact us immediately at privacy@claritylabs.com.au.
Third party websites
You may click-through to third party websites from this Platform, in which case we recommend that you refer to the privacy statement of the websites you visit. This Privacy Policy applies to this Platform only and Clarity Labs assumes no responsibility for the content of any third-party websites.
Cross-Border Disclosure of Personal Information and Sensitive Information (Including AI Processing)
Health records are stored at rest in Australian data centres that hold relevant health data compliance certifications. Limited encrypted processing may occur in the United States, United Kingdom, Singapore, and India. Any additional jurisdictions will be listed on our Data Locations page (available at: https://www.claritylabs.com.au/data-locations) at least thirty (30) days prior to their first use.
Where we engage AI-based tools to assist in processing user information, such as optimising referrals or automating secure communications, this processing is conducted in encrypted environments using industry-standard protocols (including encryption of data in transit and at rest, and access control restrictions). Any AI processing of Sensitive Information (e.g., health-related data) is subject to strict security safeguards and privacy controls.
We take all reasonable steps to ensure that overseas recipients of your Personal Information and Sensitive Information do not breach the APPs. These steps include:
Executing data processing agreements that incorporate binding privacy and confidentiality clauses;
Implementing ongoing privacy risk assessments and monitoring for international data transfers; and
Requiring all service providers to maintain encryption standards consistent with Australian security expectations.
By using our services, you expressly consent to the transfer and processing of your Personal Information and Sensitive Information outside Australia, including through secure, encrypted AI-based systems, as described in this Privacy Policy.
Use of AI and Automated Tools
We use artificial intelligence (AI) systems as an essential part of our Service offering. These tools assist in providing educational context to help you better understand your pathology data.
Educational content undergoes quarterly evidence reviews drawing from multiple authoritative sources, including RACGP, NCCIH, WHO TCIM, and others. Content may be updated without prior notice. We maintain ‘last reviewed’ dates for transparency and audit purposes.
AI processing may occasionally generate inaccuracies known as "hallucinations"; therefore, all outputs are for educational purposes only and include mandatory disclaimers. Vendors are contractually prohibited from using your data to train AI models. You may opt out of AI-enhanced summaries while continuing to access your raw laboratory reports.
The AI tools we use may process both Personal Information and Sensitive Information (including health information). This processing occurs in secure, encrypted environments and is subject to strict privacy and data protection controls, including:
Role-based access restrictions and human oversight;
Encryption of data in transit and at rest;
Internal audits and validation procedures to ensure accuracy and fairness; and
Regular reviews to assess data protection impacts in line with evolving AI governance standards.
By using our Services, you consent to the use of AI technologies to process your Personal Information and Sensitive Information in the ways described above. If you have any questions about our AI use or wish to opt out of certain types of processing (where feasible), please contact us.
Critical Value Notifications
We use your contact information (such as email and phone number) to deliver critical value notifications via dashboard banners, email, and SMS during business hours. Please note that delivery depends on third-party services and may be affected by technical issues. For detailed information on notification delivery and related limitations, please refer to our Terms and Conditions.
Changes to this Privacy Policy
From time to time, it may be necessary for us to revise this Privacy Policy. Any changes will be in accordance with any applicable requirements under the Privacy Act and the Australian Privacy Principles. We may notify you about changes to this Privacy Policy by posting an updated version on this Platform.
Contacting us & Complaint Handling
If you have any questions, concerns, or complaints about your privacy, please contact us at privacy@claritylabs.com.au. We aim to acknowledge and respond to all complaints within thirty (30) calendar days.
If you are not satisfied with our response or how we have handled your complaint, you may escalate the matter to the Office of the Australian Information Commissioner (OAIC) by visiting www.oaic.gov.au or calling 1300 363 992.
If you require any further information about the Privacy Act and the Australian Privacy Principles, you can visit the Office of the Australian Information Commissioner at www.oaic.gov.au.
