Privacy Policy

W Life Australia Pty Limited · Last reviewed September 2026

1. Introduction

This Privacy Policy provides information on how your personal information, which includes your sensitive information and your health information, is collected and used by W Life Australia Pty Limited (ACN 695 776 160) trading as W Life (ABN 22 695 776 160), and the circumstances in which we may share it with third parties.

This Privacy Policy applies to personal information provided to us or otherwise collected by us online or offline, including through our website at wlife.co, our patient dashboard, associated applications, communications and other services we make available from time to time.

This Privacy Policy applies to the W Life programme as delivered in Australia by W Life Australia Pty Limited. Any programme delivered in another jurisdiction, or by another entity, is governed by the arrangements applicable to that jurisdiction and entity and is outside the scope of this policy.

We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).

2. Why and how your consent is necessary

When you register for the W Life programme, you provide consent for us, including our employees, agents, contractors and other representatives, to access and use your personal information so that the treating practitioner can provide you with the best possible healthcare. Only persons who need to see your personal information will have access to it. If we need to use your information for any other purpose, we will seek additional consent from you to do so.

Because the W Life programme involves genetic testing and testing for notifiable conditions, we seek specific, separate consent for those tests rather than relying on your general consent to the programme. You may decline any of them without affecting the rest of your assessment.

3. Why we collect, use, hold and share your personal information

We collect your personal information to facilitate the provision of the W Life assessment and associated healthcare services to you, and to assist in the management of your health. We also use your personal information for directly related business activities, such as payments, practice audits, and business processes including staff training.

We may also collect, use and hold personal information to operate, maintain and improve our services, conduct analytics and internal reporting, communicate with you about our services, and to comply with legal and regulatory obligations.

4. What personal information we collect

The information we collect about you includes your:

• name, date of birth, address, contact details including emergency contact and next of kin;
• demographic information, including gender and cultural background;
• medical information including medical history, medications, allergies, adverse events, immunisations, social history, family history and risk factors;
• results of pathology, imaging, body composition and genetic testing undertaken as part of your assessment;
• genetic information, which is sensitive information attracting a higher level of protection under the Privacy Act;
• Medicare number, where available, and other healthcare identifiers, for identification and claiming purposes;
• payment and financial information;
• records of consents and preferences, including consent or decline recorded against optional testing and against recording of your consultation;
• recordings and transcripts of your consultation, where you have consented to these;
• information provided by you through surveys or feedback; and
• limited technical information relating to your use of our website or dashboard, such as IP address, device type, browser information and usage data.

5. Dealing with us anonymously

You have the right to deal with us anonymously or under a pseudonym unless it is impracticable for us to do so, or unless we are required or authorised by law to deal only with identified individuals.

Because the W Life programme involves pathology, imaging and genetic testing performed by accredited third-party laboratories, and the accurate matching of results to the correct individual, it is generally not practicable for us to deliver the programme on an anonymous basis.

Please also be aware that Medicare rebates, where they apply to clinically indicated testing outside the programme fee, are only available where Medicare details are provided.

6. How we collect your personal information

We may collect your personal information in several different ways:

• directly from you when you register for the programme, complete your intake questionnaire, communicate with us, or attend your consultation;
• from the treating practitioner in the course of providing healthcare services to you;
• from the accredited laboratories, imaging providers and genetic testing providers who perform your testing;
• from My Health Record, where you have one and where you consent, including via a Shared Health Summary, Event Summary or Discharge Summary;
• from previous results you choose to provide to us; and
• in some circumstances, from other sources where it is not practical or reasonable to collect it directly from you, including from your guardian or responsible person, other involved healthcare providers, or Medicare.

7. When, why and with whom we use and share your personal information

We collect, use and disclose your personal information to facilitate the provision of the W Life assessment and associated healthcare services to you.

We may also share your personal information:

• with the accredited pathology, imaging and genetic testing providers who perform your testing;
• with other healthcare providers, including your usual general practitioner and any specialist to whom you are referred, where you consent;
• when it is required or authorised by law, including where a laboratory is required to notify a positive result for a notifiable condition to the relevant State health authority;
• when it is necessary to lessen or prevent a serious threat to your life, health or safety, or to public health or safety;
• to assist in locating a missing person;
• to establish, exercise or defend a claim;
• for the purposes of confidential dispute resolution processes;
• for the purposes of uploading that information to your My Health Record, where you consent; and
• with third parties who work with us for business and operational purposes, including professional advisers, payment processors, analytics providers, service providers and information technology providers, provided that such parties are required to comply with the Australian Privacy Principles and this policy.

Only people who need to access your information will be able to do so. Other than in the course of providing healthcare services or as otherwise described in this policy, we will not share your personal information with any third party without your consent.

De-identified data may be used for teaching, education and research purposes. We will take reasonable steps to ensure any such data is not re-identified and is handled in accordance with applicable laws and ethical standards.

8. Our service providers

We use the following third-party providers in connection with the delivery of the programme:

The current names of the service providers we use, described by category above, are available from us on request.

Your identifiable health records are stored on servers located in Australia.

You acknowledge that some of our service providers, or their subcontractors, may be located or may process limited personal information outside Australia. Where this occurs, we will only disclose personal information where reasonably necessary to support the delivery of the programme and associated healthcare services to you, and we will take reasonable steps to ensure that any overseas recipient handles your personal information in a manner consistent with the Australian Privacy Principles, or a substantially similar law or binding scheme in their jurisdiction.

In particular: your genetic testing provider analyses samples through an international network of laboratories, including laboratories located in Germany and Finland; and the AI assisted platform we use to help assemble and draft your report may rely on AI sub-processors located outside Australia.

9. Use of artificial intelligence

We use AI supported tools to assist in assembling and organising your data, transcribing your consultation where you have consented, and preparing a draft of your report.

AI does not make clinical decisions. Every result is reviewed by a physician, and your report is reviewed, edited where necessary and signed off by the treating practitioner before it is provided to you.

You will be asked to provide informed consent before your consultation is recorded or transcribed, and you may decline or ask for recording to stop at any time without affecting your care.

We do not make any warranties, guarantees or undertakings as to how a third-party AI provider will collect, store or use data. You may request a copy of the relevant provider's privacy policy.

10. How we store and protect your information

Your personal information is stored as electronic records, including via cloud-based services, and where applicable as visual records and archived paper records.

We store all personal information securely through the use of access controls, passwords, multi-factor authentication, encrypted back ups, confidentiality agreements for staff and contractors, and secure storage.

Genetic information and results relating to notifiable conditions are treated as sensitive information, with access restricted to the treating practitioner and those directly involved in your care.

All records will be retained until the later of seven years from your last contact with us, or until you reach the age of twenty five. We take steps to destroy or de identify information that we no longer require.

If we experience a data breach involving your personal information that we reasonably believe is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner in accordance with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth), and take reasonable steps to reduce the risk of harm to you.

11. Where your information is held

When you reserve a place or enrol, your name, email address, mobile number and state pass through our website form and email delivery providers, which are based in the United States. This includes the messages we send about your reservation and your assessment, such as confirming we have received your questionnaire or that something is ready for you to view. These messages do not contain results or clinical information. Each provider is bound by contract to use your information only to deliver that service.

12. How you can access and correct your personal information

You have the right to request access to, and correction of, your personal information. You can lodge a request by email to contact@wlife.co. We will acknowledge your request within three business days. If we are required to process a request for your records, we may charge our reasonable costs incurred in complying with your request.

We will take reasonable steps to correct your personal information where it is not accurate or up to date. There is no fee for making corrections.

13. How you can lodge a privacy related complaint

We take complaints and concerns regarding privacy seriously. Please express any privacy concerns in writing to:

• Name: Privacy Officer
• Email: contact@wlife.co
• Address: PO Box 435, Manly NSW 1655

We will acknowledge your complaint within three business days and provide a response within thirty business days.

You may also contact the Office of the Australian Information Commissioner. Generally the OAIC will require you to give us time to respond before they will investigate. For further information visit www.oaic.gov.au or call 1300 363 992.

14. Marketing communications

We may use your contact details to send you information about W Life services, offers or programmes that may be of interest to you, including by email or SMS. You can opt out of receiving marketing communications at any time by using the unsubscribe link in any message we send you, or by contacting us at contact@wlife.co. Opting out of marketing communications will not affect our ability to send you communications that are necessary for the delivery of your assessment and associated healthcare services.

15. Privacy and our website

If you like or comment on our social media pages, we will have your social media name.

Our website uses cookies. A cookie is a small file stored on your browser which assists in managing customised settings and delivering content. We collect certain information such as your device type, browser type, IP address and pages accessed. You can use your browser settings to control how cookies are handled, though in doing so you may be unable to access certain content.

Our website may contain links to third-party websites. We are not responsible for the content or privacy practices of those websites.

16. Privacy policy review

This Privacy Policy will be reviewed annually to ensure it accords with any changes that may occur.

Last reviewed: September 2026.