Privacy Policy

Longevo Pty Ltd (“Longevo”, “we”, “us”, “our”) operates the Longevo application and associated services (the “Service”). This Privacy Policy explains how we collect, use, store, disclose, and protect your personal information, including sensitive health information, in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

By using the Service, you agree to the collection and use of your information as described in this Privacy Policy. We will not use or share your information except as set out in this Policy.

2.1 Personal Information

• Identity information: first name, last name, date of birth, biological sex
• Contact information: email address
• Location information: postcode, used for the allied health finder and geographic analytics
• Insurance information: Medicare number and Individual Reference Number (IRN), collected solely to link your My Health Record for clinical verification of health behaviours — not for billing or claims purposes; and private health insurer and life insurer names and policy numbers

2.2 Sensitive Health Information

Longevo collects sensitive health information as defined under the Privacy Act 1988 (Cth). This includes:

• Physical activity data via connected wearable devices: step count, active minutes, heart rate, workout type and duration, and sleep duration and quality
• Self-reported health behaviours: hydration, nutrition quality, allied health visits, and preventive screening completions
• My Health Record data (Phase 2, subject to separate consent): blood pathology results, GP visit records, preventive screening history, and medication records
• Declared health conditions: self-declared chronic conditions (optional)

2.3 Device and Technical Information

• Device type, operating system version, and app version
• Connected wearable device type and identifiers
• Anonymised app usage data, used for product improvement only

3.1 Core Service Purposes (APP 6.1)

• Calculating your PHOS score and determining your tier
• Displaying your health behaviour data and score history in the app
• Generating your PHOS Tier Certificate for sharing with insurers
• Sending relevant notifications, including goal progress, screening reminders, and streak alerts
• Providing the allied health finder service

3.2 Research and Analytics Purposes (With Consent)

• De-identified, aggregated population health analytics for research and health system analytics. This may be shared with government agencies, research institutions, and insurer partners under data-sharing agreements. Data is aggregated and de-identified before sharing, and no individual can be identified from it.
• Clinical evidence validation studies — de-identified cohort analysis used to generate actuarial evidence for insurer partners
• We will seek separate consent for any research use beyond the core Service

4.1 Insurer Partners

When you choose to share your PHOS score with an insurer, we disclose only your PHOS tier classification and the period it covers. We do not disclose the underlying behaviours, pathology results, or wearable data used to generate the score. You control when, and with whom, you share your certificate.

4.2 Service Providers

We share information with trusted third-party service providers who help operate the Service, including cloud infrastructure (AWS), push notification services (Firebase), and analytics platforms (Mixpanel). All service providers are contractually bound to use data only for the purposes for which it was shared, and to maintain appropriate security.

4.3 My Health Record

If you consent to link your My Health Record, we access MHR data solely to verify health behaviours for PHOS scoring. We do not upload data to your MHR. MHR data access is governed by the My Health Records Act 2012 (Cth) and our MHR System Operator Agreement with the Australian Digital Health Agency.

4.4 Legal Requirements

We may disclose information where required by law, court order, or regulatory authority. Where possible, we will notify you before making such a disclosure.

• All data is stored on Australian servers (AWS Sydney, ap-southeast-2) in compliance with Australian data sovereignty requirements
• Data is encrypted at rest using AES-256 and in transit using TLS 1.3
• Access controls: row-level security ensures each user can only access their own data
• Annual third-party penetration testing
• Staff access to personal data is limited to the minimum necessary for service delivery
• Data breach response: in the event of an eligible data breach under the Notifiable Data Breaches scheme, we will notify affected users and the Office of the Australian Information Commissioner (OAIC) as soon as practicable, and no later than 30 days after we become aware of the breach

6.1 Access and Correction (APP 12 and 13)

You have the right to access the personal information we hold about you and to request correction of any inaccurate information. To make an access or correction request, contact us at privacy@longevo.com.au.

6.2 Data Portability

You may request an export of all personal data we hold about you, in CSV or JSON format. We will provide this within 30 days of your request.

6.3 Data Deletion (Right to Erasure)

You may request deletion of your account and all associated personal data at any time, through the app settings or by contacting privacy@longevo.com.au. We will delete your data within 30 days, except where retention is required by law.

6.4 Consent Withdrawal

Where we rely on your consent to process sensitive health information, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

6.5 Complaints

If you have a complaint about how we handle your personal information, please contact our Privacy Officer at privacy@longevo.com.au. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

We retain your personal information only for as long as necessary to provide the Service and comply with our legal obligations. The following schedule applies to active accounts:

When your account is deleted, all personal data is removed within 30 days, except where a longer retention period is required by law. De-identified aggregate data derived from your information may be retained indefinitely as part of population health analytics.

Your PHOS score is calculated automatically using an algorithm that weighs your health behaviour data against predefined targets. This score determines your tier classification (Bronze through Diamond) and the insurance premium discount you are eligible to receive from participating insurer partners. The scoring algorithm does not generate clinical diagnoses, medical recommendations, or individual health risk assessments — it is a health engagement indicator.

You have the right to request a human review of your PHOS score if you believe it has been calculated incorrectly due to a data error. To request a review, contact privacy@longevo.com.au with details of the behaviour data you believe has been incorrectly captured or omitted. We will review and respond within 14 days.

All personal and health information is stored on Australian servers (AWS ap-southeast-2, Sydney). We do not transfer your personal data outside Australia as part of normal operations. Some third-party service providers — including Firebase Cloud Messaging (push notifications) and Mixpanel (analytics) — may process limited technical data (device identifiers and app usage events, with no health information) on servers outside Australia. These providers are contractually bound to comply with data protection standards substantially equivalent to the Australian Privacy Principles. No sensitive health information or PHOS score data is transferred outside Australia.

The Longevo Service is not directed at persons under 18 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately.

We may update this Privacy Policy from time to time. We will notify users of material changes via in-app notification and email, at least 30 days before the changes take effect. Continued use of the Service after the effective date constitutes acceptance of the updated Policy.