Positive Medicine Ltd - Privacy Policy
1. Introduction
Positive Medicine Ltd ("Positive Medicine", "we", "us", "our") is committed to protecting the privacy of our clients, programme participants, website users and business contacts.
We comply with the New Zealand Privacy Act 2020 and the Health Information Privacy Code 2020. Where we provide services to individuals in Australia, we also seek to comply with applicable Australian privacy laws, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles where relevant.
This policy explains how we collect, use, disclose, store and protect personal information and health information.
2. Definitions
Personal Information means information about an identifiable individual.
Health Information includes information relating to physical health, mental health, symptoms, diagnoses, treatment, medications, wellbeing, nutrition, exercise, lifestyle factors, assessments, programme participation and other health-related information.
3. Information We Collect
We may collect:
• Identity and contact information;
• Billing and payment information;
• Programme enrolment information;
• Health and wellbeing information;
• Assessment and questionnaire responses;
• Coaching notes and progress records;
• Website usage information;
• Communications with us;
• Marketing preferences; and
• Any other information you voluntarily provide.
4. How We Collect Information
We collect information directly from you through enrolment forms, questionnaires, assessments, coaching sessions, emails, telephone calls, website forms and programme participation.
We may also collect information from authorised third parties, healthcare professionals (where authorised), referral partners, payment providers and publicly available sources where lawful.
5. Health Information
Because our services relate to health, wellbeing and behaviour change, we may collect health information that is reasonably necessary to deliver our services.
Where required, we will obtain your consent before collecting sensitive health information and explain:
• why it is being collected;
• how it will be used;
• who may receive it;
• where it will be stored; and
• how long it may be retained.
6. Purposes of Collection and Use
We may use information to:
• provide programmes and services;
• assess suitability for participation;
• personalise coaching and educational content;
• monitor progress and outcomes;
• communicate with participants;
• administer accounts and payments;
• improve services;
• conduct internal analytics;
• comply with legal obligations;
• manage risk and safety; and
• protect legal rights and interests.
7. Marketing Communications
We may send programme updates, newsletters, educational content and marketing communications where permitted by law.
You may unsubscribe at any time using the unsubscribe mechanism provided or by contacting us directly.
8. Disclosure of Information
We may disclose information to:
• technology providers;
• cloud hosting providers;
• payment processors;
• professional advisers;
• contractors and service providers;
• regulators and government agencies where required;
• emergency contacts or healthcare providers where necessary to address a serious risk to health or safety; and
• other parties authorised by you.
We do not sell personal information.
9. Overseas Disclosure
Some service providers may be located outside New Zealand, including Australia.
Before transferring information overseas, we take reasonable steps to ensure recipients provide protections comparable to those required under New Zealand law or otherwise satisfy legal requirements for cross-border disclosure.
10. Data Security
We implement reasonable administrative, technical and physical safeguards including access controls, password protection, secure storage practices and restricted access to sensitive health information.
No internet transmission or storage system is completely secure and we cannot guarantee absolute security.
11. Data Breach Response
If a privacy breach occurs, we will investigate promptly and take appropriate containment and remediation steps.
Where required by law, we will notify affected individuals and relevant regulators.
12. Retention of Information
We retain information only for as long as reasonably necessary to:
• provide services;
• comply with legal obligations;
• resolve disputes;
• maintain business records; and
• enforce agreements.
Information that is no longer required will be securely deleted, destroyed or de-identified where practicable.
13. Access and Correction
You may request access to personal information we hold about you and request correction of inaccurate information.
Requests may be sent to [email protected]. We may require identity verification before responding.
14. Children and Young Persons
Our programmes are generally intended for adults unless otherwise specified.
Where services are provided to minors, consent may be required from a parent or legal guardian where required by law.
15. Website Analytics, Cookies and Tracking
We use cookies and similar technologies to:
• operate the website;
• remember user preferences;
• understand website performance;
• improve user experience; and
• support marketing activities.
Users may manage cookie preferences through their browser settings.
16. Third-Party Platforms
Our services may utilise third-party software, communication platforms, survey tools, scheduling systems and payment processors.
Use of those services may also be subject to the privacy policies of the relevant provider.
17. Research and De-Identified Data
We may use aggregated or de-identified information for service evaluation, programme improvement, research and reporting purposes where permitted by law.
18. Educational Programmes and Coaching Disclaimer
Positive Medicine's programmes, coaching and educational services are designed to support understanding, behaviour change, and the development of skills that promote health and wellbeing.
These services are educational and supportive in nature. They are not intended to diagnose, treat, cure or prevent any medical condition, and they are not a substitute for assessment, diagnosis, or treatment provided by a qualified healthcare professional.
Participation in a Positive Medicine programme or coaching relationship does not replace the advice or care provided by your own doctor or other healthcare professionals. You should continue to seek appropriate medical advice regarding any symptoms, concerns, or changes in your health.
Unless expressly agreed otherwise in writing, participation in a Positive Medicine programme, or engagement with a Positive Medicine health coach, doctor, or other trained practitioner, does not establish a doctor-patient relationship or any other formal therapeutic relationship.
Where coaching or programme support is provided by a doctor or other regulated health professional trained in the Positive Medicine model, the educational components of the programme remain distinct from any clinical services they may provide within their professional scope and under applicable professional and regulatory standards.
If you have concerns about your health, or experience new or worsening symptoms, you should seek advice promptly from your usual doctor or another appropriately qualified healthcare professional.
19. Privacy Complaints
If you believe we have breached applicable privacy laws, please contact us first.
We will investigate and endeavour to respond within a reasonable timeframe.
If you remain dissatisfied, you may contact the Office of the Privacy Commissioner (New Zealand). Australian individuals may also have rights to complain to the Office of the Australian Information Commissioner where applicable.
20. Contact Details
Positive Medicine Ltd
Email: [email protected]
Last Updated: June 2026