Version 1.0 — Effective 26 July 2026
This Privacy Policy explains how ProxiBlue collects, holds, uses, and discloses personal information when you use the ProxiBlue voice-AI booking agent (the Service), and when your patients or callers interact with the Service on your behalf.
ProxiBlue is committed to handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This policy should be read together with our [Terms of Service](terms-and-conditions.md).
2.1 You are the APP entity for Patient Data. When the Service handles calls for your clinic, you remain the entity responsible under the Privacy Act for the personal and health information of your patients. You control why the information is collected and how it is used in your practice.
2.2 We are your service provider. ProxiBlue processes Patient Data as your service provider, on your instructions, solely to deliver the Service. We do not use Patient Data for our own independent purposes except as permitted in clause 5 (operating and improving the Service) and clause 8 of the Terms of Service.
2.3 We are the controlling entity for account data. For information about you and your staff as Client account holders, and about visitors to our website, ProxiBlue is the entity responsible under the Privacy Act.
2.4 Patient requests. Because you are the APP entity for Patient Data, patients exercising privacy rights over their information should contact your clinic directly. Where a patient contacts us, we will refer the request to you within a reasonable time (see clause 11).
Names, business name, email addresses, phone numbers, billing details, practice details (practitioners, appointment types, business hours), login credentials, and support correspondence.
The Service may incidentally collect health information as part of a booking conversation. We treat all such information as sensitive information and process it only on your instructions as your service provider. We do not use it for any secondary purpose.
Website analytics, cookies, device and browser data, IP addresses, system and access logs, and AI performance metrics used to operate and improve the Service.
4.1 Call recording notice. Calls are recorded. You are responsible for ensuring your greeting and privacy notices comply with the call-recording law of your State or Territory (see Terms of Service clause 4.4).
4.2 Not for emergencies. The AI cannot triage medical emergencies. It is configured to direct callers with an emergency to contact emergency services (000 in Australia). You must maintain your own emergency guidance for patients.
4.3 Human alternative. A caller who does not wish to interact with the AI may request to be handled by your staff. You are responsible for providing an alternative contact pathway for callers who object to AI processing.
4.4 AI limitations and verification. The AI can mishear, misinterpret, or produce inaccurate output. To reduce this risk, the ProxiBlue system automatically verifies each AI call multiple times to confirm the captured information is correct, so that mistakes are mostly eliminated. Information captured by the AI should nonetheless be treated as requiring verification. See Terms of Service clause 3 for the full acknowledgement of AI limitations.
We use personal information to:
We do not sell personal information. We do not use Patient Data for marketing, profiling, or any purpose unrelated to delivering the Service.
6.1 Sub-processors. We disclose personal information to the Third-Party Services required to run the Service. We name each sub-processor explicitly below, rather than by generic category, because APP 8 (cross-border disclosure) favours identifying the actual entity that processes your data. Each provider is bound by a data processing agreement (or equivalent) and may only use the information to perform services for us. Our voice provider, Retell AI, processes call data as our sub-processor under a data processing addendum and holds SOC 2 Type I and Type II, HIPAA, and GDPR compliance.
| Sub-processor | Patient data category received | Hosting / jurisdiction |
|---|---|---|
| Retell AI | Voice/LLM conversation layer — call audio and the patient's name / first name injected as conversation context. | United States. |
| Google Gemini (default) or OpenAI (fallback provider, used if Gemini is not configured) — the transcript-analysis LLM provider | The full call transcript, analysed after the call to verify booking accuracy (see TranscriptAnalyzer.php). |
United States. |
| Telnyx | Call routing / phone numbers — the caller's phone number and call-signalling metadata needed to carry the call. | United States, with carriage into Australia. |
| Cliniko | Practice management system integration — patient records, appointments. | Held in your own Cliniko account, which you control. |
| Pin Payments | Payment processing — billing details. | Australia. |
| DigitalOcean | Cloud hosting and infrastructure. | Australia (Sydney region). |
Identity-verification control. Before the Service discloses or acts on an existing patient record (for example, reading appointment history or making changes on a caller's behalf), it requires the caller to verify their identity (date of birth and/or phone number match). If verification fails, the matched patient record is locked for the remainder of the call and no further patient data is disclosed to that caller, regardless of what they subsequently claim.
A current list of sub-processors is available to Clients on written request to sales@proxiblue.com.au.
6.2 Legal disclosure. We may disclose information where required by law, court order, or a lawful request by a regulator or enforcement body.
6.3 Business transfers. If ProxiBlue is involved in a merger, acquisition, or asset sale, personal information may transfer to the successor entity under equivalent privacy protections.
Some Third-Party Services store or process data outside Australia — in particular, our voice provider (Retell AI) processes call recordings, transcripts, and associated data in the United States. Before disclosing personal information overseas, we take reasonable steps to ensure the recipient handles it consistently with the APPs, through contractual protections (such as a data processing addendum) or an applicable exception under APP 8. A summary of the countries in which data may be processed is available on request. ProxiBlue remains accountable to you under Australian law for information disclosed to its sub-processors.
8.1 We protect personal information with technical, organisational, and physical safeguards, including:
8.2 No system is perfectly secure. We cannot guarantee absolute security, but we take reasonable steps to protect information and to respond promptly to any incident.
We retain personal information only as long as necessary for the purposes described in this policy or as required by law. Indicative retention periods:
| Data | Retention |
|---|---|
| Call recordings and transcripts | Stored by our voice provider (Retell AI) under a data-retention setting that automatically deletes recordings and transcripts after a configured number of days. Retell supports retention from 1 day up to 2 years; the Service is configured to 90 days. Recording download links delivered by webhook expire 10 minutes after each call. |
| Appointment and booking data | Held in your practice management system (Cliniko), which you control; retained by us only as needed to deliver the Service |
| Client account information | Duration of the account plus 90 days |
| Billing and payment records | 7 years for tax and audit compliance |
| Website analytics | 26 months |
PII minimisation. Retell AI supports automatic redaction of personal identifiers (names, addresses, dates of birth, phone numbers, PINs) from stored transcripts and recordings, and a metadata-only mode that stores no transcript or recording at all. The Service's configured storage level is redact PII.
On termination, we delete Patient Data (except records legally required to be retained) within the period stated in Terms of Service clause 8.5.
If we become aware of a data breach that is likely to result in serious harm, we will act in accordance with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act. Where the breach concerns Patient Data for which you are the APP entity, we will notify you without undue delay so that you can meet your own notification obligations to affected individuals and to the Office of the Australian Information Commissioner (OAIC).
11.1 Access (APP 12) and correction (APP 13). You may request access to, or correction of, the personal information we hold about you as an account holder. We will respond within a reasonable time (generally 30 days). We do not charge for making a request; a reasonable fee may apply to providing access where significant work is required, and we will tell you in advance.
11.2 Patient rights. Patients seeking access to, or correction of, their information should contact your clinic, as you are the APP entity for that information. We will support you in responding to such requests and will forward any request received directly by us to you within a reasonable time.
11.3 How to make a request. Email sales@proxiblue.com.au with the details of your request. We may need to verify your identity before acting.
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The Service and website are intended for use by clinics and their staff, not by children directly. The Service may process a minor patient's information where your clinic instructs it to as part of a booking; that information is handled under your clinic's own privacy obligations.
14.1 Contact us first. If you have a privacy concern, contact us at sales@proxiblue.com.au. We will acknowledge your complaint promptly and aim to resolve it within a reasonable time (generally 30 days).
14.2 Escalation. If you are not satisfied with our response, you may complain to the OAIC at www.oaic.gov.au or 1300 363 992.
We may update this policy from time to time. The current version, with its effective date, is published on our website. Material changes will be notified to Clients by email or via the client dashboard.
Privacy enquiries: sales@proxiblue.com.au Entity: ProxiBlue ABN: 30 550 620 048 Effective date: 26 July 2026