This Privacy Policy applies to the collection, storage, use, and disclosure by CINGULUM HEALTH PTY LIMITED (ABN 90 636 435 875) in Australia and Cingulum USA LLC (EIN 99-3794837) in the United States (together, “Cingulum,” “we,” “us,” “our”). This Privacy Policy complies with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) and the Health Insurance Portability and Accountability Act (HIPAA), and other applicable US privacy regulations. It also provides information on how you can access or seek correction of your personal information.

By providing us with your personal information when you contact us, use the https://cingulumhealth.com website (Website), complete an assessment form, or book an appointment, you consent to the collection and use of your personal information in accordance with this Privacy Policy. We may change this Privacy Policy from time to time to reflect updates in our practices or legal obligations.

Types of Personal Information We Collect

The types of personal information we collect include (but are not limited to):

• Identification Information: Name, postal address, billing address, email address, contact phone numbers, date of birth, driver’s licence number, or other government-issued identification information.

• Payment Information: Credit or debit card details (for payment purposes only).

• Health Information: Medical history, brain imaging, biometric information (e.g., height and weight), current medications, and details of health conditions. This may also include sensitive health information as defined under the Privacy Act and HIPAA.

Collection of Your Personal Information

Cingulum may collect personal and health information when you:

• Complete an assessment form, booking form, or any other form, whether in person or online.

• Provide personal information through email or other communication channels.

• Interact with our Website or visit our clinic locations.

• Become a patient or engage in any of our services.

We may collect:

• Information that personally identifies you (e.g., email address, name, telephone number) but only when you voluntarily provide it.

• Sensitive health information (e.g., health conditions, medical history) when required to offer our services.

• Usage Data that does not personally identify you but helps us improve the Website and tailor our services to your preferences.

The collection of this information is necessary for us to deliver high-quality services and to tailor our treatments based on your health needs.

Purpose of Collecting Your Personal Information

The purpose of collecting your personal information is to enable us to provide specialised healthcare services related to neurological and psychiatric conditions, including but not limited to:

• Neurological disorders (e.g., movement disorders, stroke, Parkinson’s disease).

• Psychiatric disorders (e.g., depression, anxiety, PTSD, OCD).

• Chronic pain, tinnitus, memory loss, and dementia.

We also collect, hold, use, and disclose your personal information to:

• Manage and administer healthcare services, including account-keeping.

• Collaborate with neuroimaging companies, such as Omniscient Neurotechnology, to tailor treatments.

• Communicate with you, including sending invoices and treatment plans.

• Send marketing or promotional information related to Cingulum or our business partners.

• Comply with legal and regulatory obligations.

• Manage our business operations.

Use and Disclosure of Your Personal Information

Cingulum will use and disclose your personal and health information to provide the services requested. We do not share, sell, or disclose your personal information for purposes other than as outlined in this Privacy Policy unless required by law or with your explicit consent.

We may disclose personal information to:

• Third-party service providers (e.g., neuroimaging companies, IT service providers, payment processors) to support our business.

• Health professionals and neuroimaging centres involved in your care.

• Marketing and research partners to communicate updates or collect feedback.

If we disclose your information to a third party, we generally require that the third party protect your information to the same extent that we do.

Storage and Security of Your Personal Information

From time to time we may hold personal information in any combination of data storage facilities, cloud computing facilities (which may be located overseas), or secure paper-based files which may be operated or held by us or by third-party service providers under a contractual arrangement.  

We will use all reasonable endeavours to maintain the security of your personal information from unauthorised access, modification, or disclosure.  

We cannot ensure or warrant that your personal information will always be secure during transmission or protected from unauthorised access during storage therefore you provide your personal information to us at your own risk. 

Please contact us immediately if you become aware or have reason to believe there has been any unauthorised use of your personal information in connection with the Website. 

We will take all reasonable steps to destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.

Cross-Border Disclosures

We operate in Australia and the USA and may engage overseas recipients to store data (e.g., cloud-based storage solutions). By providing us with your personal information, you consent to its storage on overseas servers and acknowledge that if an overseas recipient breaches applicable privacy laws, you may not have the same protections and rights as under Australian or US laws.

Storage and Security of Your Personal Information

We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification, or disclosure. Your information may be stored in data storage facilities, cloud-based services, or secure paper-based files operated by us or our service providers.

While we strive to protect your personal information during transmission and storage, we cannot guarantee absolute security, and you provide your personal information at your own risk. If you become aware of any unauthorised use of your personal information, please contact us immediately.

Access, Amendment, and Deletion of Your Personal Information

You may request access to or correction of your personal information by contacting us. We will provide access or make corrections where required by law, and we may ask for identification to verify your request.

If you would like to delete your personal information, please contact us info@cingulumhealth.com. We will delete or de-identify your records unless we are required by law to retain them. If there are legal reasons preventing us from deleting the information, we will inform you of these reasons.

Data Breach Notifications

We will notify you and the appropriate regulatory bodies in accordance with the Australian Notifiable Data Breaches (NDB) scheme and US data breach laws if a breach occurs that may result in harm to you.

Anonymity

You may choose to remain anonymous or use a pseudonym when dealing with us. However, this may limit our ability to provide services to you.

Marketing and Communication

By providing your personal information, you consent to receiving marketing communications from us. If you wish to opt out, please contact us at info@cingulumhealth.com.

Links to Other Websites

Our Website may contain links to external websites. We are not responsible for the privacy practices of other websites. Please read the privacy policies of any third-party websites you access.

Disclaimer - Further Disclosure

We will only collect, use, or disclose your personal information in accordance with this Privacy Policy, unless required to do so by law or if we believe that such disclosure is necessary to protect our rights or the safety of any person.

Governing Law

This Privacy Policy will be governed by and construed in accordance with the laws of New South Wales, Australia and the relevant US state where Cingulum USA LLC operates. You agree to submit to the exclusive jurisdiction of the courts of these regions.

Contact Us

For any questions or concerns, please reach out to us at info@cingulumhealth.com.

Making a Complaint

If you have concerns about how we manage your personal information, please contact us at info@cingulumhealth.com.

We will endeavour to provide a response within 30 days.

• Australia: You may also contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

• USA: For concerns under US law, you may contact the Department of Health and Human Services (HHS) at www.hhs.gov.