Privacy Policy

1. We respect your privacy

1.1. Pause Health Pty Ltd (ABN: 85 699 629 288) (Pause Health, we, us, our) respects your right to privacy and is committed to safeguarding the privacy of our customers, members and website visitors. This policy sets out how we collect and treat your personal information.

1.2. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and, where applicable, the EU General Data Protection Regulation (GDPR), the UK GDPR, and other applicable data protection laws.

1.3. "Personal information" is information we hold that is identifiable as being about you. This includes information such as your name, email address, identification number, or any other type of information that can reasonably identify an individual, either directly or indirectly.

1.4. You may contact us in writing at [email protected] for further information about this Privacy Policy.

2. What personal information is collected

2.1. Pause Health will, from time to time, receive and store the personal information you submit to our Website, or provide to us directly or in other forms.

2.2. You may provide basic information such as your name, phone number, address, Pharmacy details and email address, to enable us to send you information, provide updates, and process your Program purchase or other order.

2.3. We may collect additional information at other times, including but not limited to, when you provide feedback, provide information about your personal or business affairs, change your content or email preferences, respond to surveys and/or promotions, provide financial or credit card information, complete a Program (including any assessment or completion data), or communicate with our customer support.

2.4. Additionally, we may collect any other information you provide while interacting with us.

2.5. The Foundation Module and Menopause Masterclass use training footage featuring actors and/or de-identified case studies. Pause Health does not require or seek to collect identifiable health information about any third party (such as a patient of your Pharmacy) in the course of providing the Services. If this changes in the future, we will update this Privacy Policy and seek any consents required by law before doing so.

3. How we collect your personal information

3.1. Pause Health collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our Website or Member Portal, and when we engage in business activities with you. We may receive personal information from third parties (for example, a Payment Gateway Provider or the Member Portal). If we do, we will protect it as set out in this Privacy Policy.

3.2. By providing us with personal information, you acknowledge that we will handle that information subject to the terms of this Privacy Policy.

4. How we use your personal information

4.1. Pause Health may use personal information collected from you to provide you with information about our Programs or Services. We may also make you aware of new and additional products, services and opportunities available to you.

4.2. Pause Health will use personal information for the purposes set out in this Privacy Policy, which may include to:

• (a) provide you with the Programs and Services during the usual course of our business activities;
• (b) administer our business activities;
• (c) manage, research and develop our Programs and Services;
• (d) provide you with information about our Programs and Services;
• (e) communicate with you by a variety of means, including but not limited to telephone, email, SMS or mail; and
• (f) investigate any complaints.

4.3. If you withhold your personal information, it may not be possible for us to provide you with our Programs and Services, or for you to fully access our Website or Member Portal.

4.4. We may disclose your personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, legal proceedings, or in response to a law enforcement agency request.

4.5. If there is a change of control of our business, or a sale or transfer of business assets, we will notify you and ensure that any transfer of your personal information is conducted in compliance with applicable data protection laws.

5. Disclosure of your personal information

5.1. Pause Health may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors (including the provider of our Member Portal and any Payment Gateway Provider) insofar as reasonably necessary for the purposes set out in this Privacy Policy.

5.2. If we disclose your personal information to a third party, we will take reasonable steps to ensure that the third party handles it in accordance with this Privacy Policy and applicable data protection laws.

6. General Data Protection Regulation (GDPR) for the European Union (EU)

6.1. Where the GDPR applies to our processing of your personal information, we will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency and lawful data collection and use.

6.2. We process your personal information as a Processor and/or, to the extent applicable, as a Controller as defined in the GDPR.

6.3. We must establish a lawful basis for processing your personal information under Article 6 of the GDPR. We will clearly inform you of the specific legal basis we rely on for each processing activity, which may include consent, contractual necessity, legal obligations, vital interests, legitimate interests, or public task.

6.4. We will collect your personal information on the basis of an applicable lawful ground (such as your consent, contractual necessity, or our legitimate interests), and any data collected will be limited to what is necessary and not excessive for that purpose. We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including encryption, access controls and regular security assessments.

6.5. We will also process your personal information if it is necessary for our legitimate interests, or to fulfil a contractual or legal obligation.

6.6. We do not generally seek to collect or process personal information from you that is considered "Special Categories of Personal Data" under the GDPR (including health data, genetic data, biometric data, or data about racial or ethnic origin, political opinions, religious beliefs, trade union membership or sexual orientation). Where any data we collect could be considered a Special Category, we will ensure we have obtained your explicit consent, or that another legal basis exists under the GDPR.

6.7. You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children.

7. Your rights under the GDPR

7.1. If you are an individual residing in the EU or the UK, you have certain rights as to how your personal information is obtained and used. Pause Health complies with your rights under the GDPR (and, where applicable, the UK GDPR) as to how your personal information is used and controlled if you are an individual residing in the EU or the UK.

7.2. Except as otherwise provided in the GDPR, you have the following rights:

• (a) to be informed how your personal information is being used;
• (b) to access your personal information (we will provide you with a free copy of it);
• (c) to correct your personal information if it is inaccurate or incomplete;
• (d) to delete your personal information (also known as "the right to be forgotten");
• (e) to restrict the processing of your personal information;
• (f) to retain and reuse your personal information for your own purposes;
• (g) to object to your personal information being used; and
• (h) to object to automated decision-making and profiling.

7.3. Please contact us at any time to exercise your rights under the GDPR, using the contact details in this Privacy Policy.

7.4. We may ask you to verify your identity before acting on any of your requests.

8. Hosting and international data transfers

8.1. As Pause Health expands its Services nationally and internationally, information that we collect may from time to time be stored, processed in, or transferred between parties or sites located in countries outside of Australia, including where our Member Portal or other service providers host data overseas.

8.2. You acknowledge that personal data that you submit for publication through our Website or Services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

8.3. Where we transfer personal information overseas, we will take reasonable steps to ensure the overseas recipient handles that information in a manner consistent with the Australian Privacy Principles. Where the GDPR applies, we will ensure that appropriate safeguards are in place for such transfers, such as standard contractual clauses, adequacy decisions, or other mechanisms recognised under applicable data protection law.

9. Security of your personal information

9.1. Pause Health is committed to ensuring that the information you provide to us is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information, and to protect it from misuse, interference, loss, and unauthorised access, modification and disclosure. We will retain your personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected, or as required by applicable law, after which it will be securely destroyed or de-identified.

9.2. Where we engage data processors to process personal information on our behalf (including our Member Portal and Payment Gateway Providers), we only do so on the basis that those data processors comply with applicable data protection requirements and have adequate technical measures in place to protect personal information against unauthorised use, loss and theft.

9.3. While we implement appropriate security measures to protect your information, electronic transmission of information over the internet carries inherent risks. We use industry-standard encryption and security protocols to protect data in transit and at rest, but you should be aware of these inherent risks when transmitting information online. Although we take measures to safeguard against unauthorised disclosure of information, we cannot assure you that personal information we collect will not be disclosed in a manner inconsistent with this Privacy Policy.

10. Access to your personal information

10.1. You may request details of the personal information that we hold about you in accordance with the Privacy Act 1988 (Cth) and, to the extent applicable, the EU GDPR. If you would like a copy of the information we hold about you, or believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at [email protected].

10.2. We may only refuse to provide you with information we hold about you in specific circumstances permitted by law, such as where an exemption applies under the Privacy Act or the GDPR. We will always inform you in writing of any refusal, the reasons for it, and your right to complain to the relevant supervisory authority.

11. Complaints about privacy

If you have any complaint about our privacy practices, please send details of your complaint to [email protected]. We take complaints seriously and will respond promptly after receiving written notice of your complaint. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or, if you are in the EU, to your local data protection authority.

12. Changes to this Privacy Policy

We may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion. We will notify you of material changes by posting the updated Policy on our Website or by other reasonable means. All modifications will be effective upon posting unless otherwise stated. Please check back from time to time to review our Privacy Policy.

13. Website

13.1. When you visit our Website at www.pausehealth.com.au, we may collect certain information such as browser type, operating system, and the website visited immediately before coming to our site. This information is used in an aggregated manner to analyse how people use our site, so that we can improve our Services.

13.2. We may from time to time use cookies on our Website. Cookies are small files that a website uses to identify you when you return to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies, but you can choose to reject cookies by changing your browser settings. This may prevent you from taking full advantage of our Website.

13.3. Our Website uses cookies to analyse website traffic and improve your experience. We use both essential cookies necessary for the operation of the Website, and optional analytical and advertising cookies. Where required by applicable law, we will obtain your consent before placing non-essential cookies. You can manage your cookie preferences through our cookie consent tool and/or your browser settings.

13.4. Our site may from time to time have links to other websites not owned or controlled by us. These links are for your convenience only. Links to third-party websites do not constitute sponsorship, endorsement or approval of those websites. Pause Health is not responsible for the privacy practices of other websites. We encourage you, when you leave our Website, to read the privacy statement of each website that collects personally identifiable information.

Last updated: 3 September 2026