Wellshare X — Privacy Policy

Version 1.1 | Effective Date: 7th February 2026

  1. About This Policy

This Privacy Policy explains how Wellshare Pty Ltd (ABN 52 630 278 894) (“Wellshare”, “we”, “us”, “our”) collects, uses, stores, discloses, and protects personal information in connection with the Wellshare X platform (“Platform”) available at search.wellshare.com.au.

We are bound by the Australian Privacy Principles (“APPs”) contained in the Privacy Act 1988 (Cth) (“Privacy Act”). This Policy applies to all users of the Platform, including health, beauty, and wellness practitioners (“Practitioners”) and clinic owners or room providers (“Clinic Owners”).

We collect personal information directly from users when they submit inquiries, create or manage listings, communicate with us, or otherwise use the Platform, and indirectly through automated technologies as described below.

  1. What Personal Information We Collect 2.1 Information from Practitioners

When a Practitioner submits an inquiry through the Platform, we collect:

Full name

Email address

Phone number

Type of room use sought (as described by the Practitioner)

Any additional information voluntarily provided in the inquiry message

2.2 Information from Clinic Owners

When a Clinic Owner registers on the Platform, or an account is created on their behalf, we collect:

Full name

Email address

Phone number

Business name and clinic details

Clinic address (suburb and state)

Clinic type

Room details, including descriptions, pricing, availability, amenities, and images

Records of acceptance of our Terms and Conditions (including version accepted, date, time, and method of acceptance)

2.3 Information Collected Automatically

When you use the Platform, we may automatically collect:

IP address

Browser type and version

Device type

Pages visited and time spent on pages

Referring website or source

General location data derived from IP address

2.4 Information from Third Parties

We may receive personal information from third parties where:

A Clinic Owner or their representative provides Practitioner or staff details; or

We receive information through integrated services such as email providers or infrastructure services used to operate the Platform.

2.5 Sensitive Information

We do not intentionally collect sensitive information (as defined under the Privacy Act). However, users may choose to include information relating to their professional qualifications, services, or areas of practice in inquiry messages or listing content.

By voluntarily providing this information, you consent to its collection, use, and disclosure in accordance with this Privacy Policy.

  1. How We Use Personal Information

We use personal information for the following purposes:

3.1 Core Platform Functions

To facilitate introductions between Practitioners and Clinic Owners

To provide Practitioner inquiry details to Clinic Owners

To manage Clinic Owner accounts, listings, and room details

To process and track inquiries

To administer acceptance of Terms and Conditions and compliance with them

To calculate, administer, and enforce Introduction Fees

3.2 Communication

To send transactional emails (including account verification, inquiry notifications, listing updates, and invitations)

To notify Clinic Owners of new inquiries

To communicate updates to our Terms and Conditions or policies

To respond to support requests and user enquiries

3.3 Platform Improvement and Security

To analyse usage patterns and improve the Platform

To monitor, maintain, and secure the Platform

To identify, diagnose, and fix technical issues

3.4 Legal and Compliance

To comply with applicable laws and regulatory obligations

To enforce our Terms and Conditions

To verify whether Rental Arrangements have been entered into following Introductions

To resolve disputes

To protect the rights, property, and safety of Wellshare, our users, and the public

  1. How We Share Personal Information 4.1 Practitioner Information Shared with Clinic Owners

When a Practitioner submits an inquiry, the Practitioner’s name, email address, phone number, use-type preferences, and inquiry message are provided to the relevant Clinic Owner. This disclosure is a core function of the Platform.

By submitting an inquiry, the Practitioner consents to this disclosure.

4.2 Clinic Owner Information

Clinic Owner identities are not disclosed to Practitioners through the Platform. Listings are displayed under a “Wellshare X [Suburb]” format. Clinic Owner contact details are not published on the Platform.

4.3 Service Providers

We may share personal information with trusted third-party service providers who assist us in operating the Platform, including:

Supabase — database hosting and authentication

Resend — transactional email delivery

Vercel — website hosting

Cloud storage providers — image and file storage

These providers are given access only to information necessary to perform their services and are subject to their own privacy obligations.

4.4 Legal Requirements

We may disclose personal information where required or authorised by law, including to:

Comply with a court order, subpoena, or legal process

Respond to requests from law enforcement or regulatory agencies

Protect the safety of any person

Enforce our Terms and Conditions

4.5 Business Transfers

In the event of a merger, acquisition, restructure, or sale of all or part of our business, personal information may be transferred to the acquiring entity. We will take reasonable steps to notify affected users where required by law.

  1. How We Store and Protect Personal Information 5.1 Storage

Personal information is stored on secure servers provided by our hosting and database providers. Data may be stored in Australia and in overseas locations where our service providers operate, including the United States and Asia-Pacific regions.

5.2 Security Measures

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification, and disclosure. These steps include:

Encryption of data in transit (HTTPS/TLS)

Encryption of data at rest

Secure authentication with hashed passwords

Role-based access controls

Regular review of security practices

5.3 Data Retention

We retain personal information only for as long as necessary for the purposes described in this Policy or as required by law. In particular:

Practitioner inquiry data is retained for the duration of the Introduction Period (six months) and a reasonable period thereafter for record-keeping and dispute resolution

Clinic Owner account data is retained for the duration of the account and a reasonable period after account closure

Terms and Conditions acceptance records are retained indefinitely for evidentiary and legal purposes

Automatically collected data (such as IP addresses and usage data) is retained for up to 24 months

5.4 Data Breaches

In the event of an eligible data breach under the Notifiable Data Breaches scheme, we will notify the Office of the Australian Information Commissioner (“OAIC”) and affected individuals as required by law.

  1. Cookies and Tracking 6.1 Essential Cookies

We use essential cookies to maintain user sessions and authentication. These cookies are necessary for the Platform to function and cannot be disabled.

6.2 Analytics

We may use analytics tools to understand how the Platform is used. Analytics data is collected in aggregate and is not used to identify individual users. Third-party analytics providers, if used, operate under their own privacy policies.

6.3 Advertising Cookies

We do not currently use advertising cookies, retargeting pixels, or third-party tracking for advertising purposes.

  1. Your Rights

Under the Australian Privacy Principles, you have the right to:

7.1 Access

Request access to the personal information we hold about you. We will respond within 30 days.

7.2 Correction

Request correction of personal information that is inaccurate, out-of-date, incomplete, irrelevant, or misleading.

7.3 Complaints

Lodge a complaint if you believe we have breached the APPs. We will investigate and respond within 30 days.

If you are not satisfied with our response, you may contact the OAIC:

Website: www.oaic.gov.au

Phone: 1300 363 992

Email: enquiries@oaic.gov.au

7.4 Account Deletion

Clinic Owners may request deletion of their account and associated personal information. We will delete or de-identify personal information within a reasonable timeframe, subject to our legal and regulatory obligations, including record-keeping and enforcement of contractual rights.

Practitioners may request deletion of inquiry data. Once inquiry data has been provided to a Clinic Owner, we cannot retrieve or control that information.

7.5 Opt-Out

You may opt out of non-essential communications at any time using the unsubscribe link in emails or by contacting us.

  1. Cross-Border Disclosure

Some of our service providers operate outside Australia. By using the Platform, you consent to the disclosure of your personal information to overseas recipients, including in the United States.

You acknowledge that overseas recipients may not be subject to Australian privacy laws and that we may not be able to enforce the APPs against them. We take reasonable steps to ensure overseas recipients handle personal information in a manner consistent with this Policy.

  1. Children

The Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected such information, we will take reasonable steps to delete it.

  1. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be published on the Platform with a revised effective date.

Continued use of the Platform after changes constitutes acceptance of the updated Policy. For material changes, we will make reasonable efforts to notify affected users directly.

  1. Contact Us

For questions, access or correction requests, or privacy complaints, contact:

Wellshare Pty Ltd ABN: 52 630 278 894 Email: support@wellshare.com.au