Legal

Privacy Policy

Last updated: 9 September 2026

Propagator is committed to protecting your privacy. This Privacy Policy has been developed in accordance with the Privacy Act 1988 (Australia) and the Privacy Act 2020 (New Zealand), and sets out how we collect, hold, use and disclose information that relates to you.

1. Definitions

The following terms have the following meanings in this Privacy Policy:

  • "information" may include Personal Information.
  • "Personal Information" means any information or opinion about an identified individual, or an individual who is reasonably identifiable.
  • "Propagator", "us" or "we" means Propagator Limited, NZBN 9429051613419.
  • "Propagator Products" means the Propagator website, app, software and any related systems owned, sold or licensed by Propagator.
  • "Propagator Website" means the website operated by Propagator at www.propagator.health.
  • "you" and "your" means any individual, company, association or organisation, including any employee, director, agent or representative, that uses Propagator Products or services, including clinics and their staff or administrators.
  • "Third-Party Software" means any software, application or system developed and operated by a party other than Propagator that has been approved for installation through Propagator Products.

2. The kind of Personal Information we collect and hold

Propagator provides a platform that allows clinics to connect approved third-party software. Propagator collects information about clinic accounts and their staff, locations or administrators, not about clinics' patients or clients. We may collect and hold the following information:

  • Name, address, email address and telephone number of clinic staff, administrators or account contacts.
  • IP addresses, browser type, device identifiers and usage data.
  • Account login details such as usernames and passwords for Propagator Products.
  • Details of your subscription with Propagator.
  • The number of users, staff or contractors linked to your account.
  • The location(s) of the business from which your account is operated.
  • Records of your use of Propagator Products, including which third-party software you connect or install.
  • Authentication and connection details (such as access tokens) needed to link your account to third-party software you choose to install.
  • Who accessed your patients' information, when and what data they saw (but not the sensitive data itself).

Propagator does not directly collect or store payment card or bank account details. Payments are processed by a third-party payment provider, and any financial information you provide is collected and held by that provider subject to its own privacy policy.

Propagator does not collect, view, or store information about your patients or clients, including any health or clinical records. Propagator's role in respect of third-party software is limited to facilitating the connection between your account and that software, as set out below.

3. Third-party software and integrations

Propagator allows clinics to browse and install third-party software through our platform. We review and approve third-party software before it is made available for installation, but each provider remains responsible for its own product and for how it collects, holds, uses and discloses any information, including patient or client data, that passes through it.

When you install third-party software through Propagator, we facilitate the connection and authentication between your Propagator account and that software. We do not access, view, or store the data that flows between you and the third-party software once that connection is established, including any patient or client information. Nor does the third-party software run or store their data on Propagator's infrastructure.

We recommend you review the privacy policy and terms of the third-party software before installing it, as your use of that software will be governed by the provider's own terms. Propagator is not responsible for the privacy or data handling practices of third-party software providers.

4. How we collect and hold Personal Information

We collect your Personal Information when you use a Propagator Product or correspond with us.

When you create an account on the Propagator Website or app, we ask for and you may provide Personal Information, which we then collect and store.

If you correspond with us, we may retain the information contained in that correspondence, along with information used to transmit it.

We may use cookies and similar technologies to collect data about how you navigate and use Propagator Products. See our Cookie Policy for more detail on how we use them.

We may also receive information about you from other sources, such as social media, referrals and public data platforms, or through use of the Propagator web application by you or your end users.

Information we collect is stored electronically or in hard copy. Electronic information is stored by a third-party cloud service provider.

5. Purposes for which we collect, hold, use and disclose Personal Information

We collect, hold, use and disclose your Personal Information to provide Propagator Products to you, administer and perform any subscription agreement between you and Propagator, communicate with you, and process payments between Propagator and its subscribers. This information helps us understand how our products are used so we can develop, improve and refine them, provide customer support, and inform our marketing to support the growth of Propagator.

We may disclose Personal Information to business partners and third parties that provide services to us, including website hosting, cloud storage and payment facilitation. Where you choose to install Third-Party Software, we disclose the connection and authentication information necessary to establish that link, but we do not disclose your other Personal Information to the provider beyond what is needed for that connection. We may also disclose information to suppliers, subcontractors, and to comply with legal obligations.

We may disclose or transfer your information to a third party for the purpose of obtaining legal, accounting, marketing, analytical or business advice, or to cloud hosting providers, payment processors, technical support providers and legal authorities where required by law. We may also transfer your information if we sell, merge, or transfer the assets of Propagator to another entity. All service providers we engage are required to comply with appropriate privacy and security standards.

6. Cross-border disclosure

Propagator's servers and infrastructure are located in Australia, and your Personal Information is primarily processed there. Because Propagator also operates in New Zealand and elsewhere, your Personal Information may be transferred between Australia, New Zealand and other jurisdictions where our infrastructure providers operate. We take reasonable steps to ensure overseas recipients protect Personal Information consistent with the Privacy Act 2020 (New Zealand) and the Privacy Act 1988 (Australia).

7. Data security

We implement reasonable technical and organisational safeguards, including:

  • Encryption of data in transit and at rest, where appropriate.
  • Secure access controls.
  • Two-factor authentication (2FA) for account access.
  • Regular security reviews.
  • Monitoring for unauthorised access.

8. How you may access and correct your Personal Information

You may contact Propagator and request, in writing, access to Personal Information we hold about you. We will use our best endeavours to respond within a reasonable time and will provide access by way of a copy of that information, unless we are prohibited by law from doing so. We reserve the right to charge a reasonable fee for processing an access request.

If, after receiving access to your Personal Information, you consider it is incorrect, you may notify us in writing, identifying the information you say is incorrect and the correction you are requesting. Propagator will consider your request and, in its discretion, decide whether to add or substitute the corrected information.

9. How you may complain about a breach of your privacy rights

You may complain to Propagator about an alleged breach of the Australian Privacy Principles, or a registered APP Code that binds Propagator, by contacting us in writing and setting out the details of the alleged breach.

We will use our best endeavours to investigate any complaint and respond to you in writing within a reasonable time. If we accept that a breach occurred, we will advise you of the steps we intend to take to address it and prevent further breaches.

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner online at oaic.gov.au, by mail to GPO Box 5288, Sydney, New South Wales 2001, or by fax to +61 2 6123 5145.

For New Zealand users, you may request access to or correction of your personal information by contacting our Privacy Officer. These rights are provided under the Privacy Act 2020 (New Zealand). If you believe your privacy rights have been breached and the matter remains unresolved, you may lodge a complaint with the Office of the Privacy Commissioner New Zealand.

10. Overseas disclosure

Propagator intends to grow into a company operating in multiple countries. At this stage, Propagator has no intention of disclosing Personal Information to overseas recipients beyond those described under Cross-Border Disclosure above, and such disclosure is otherwise unlikely to occur.

By creating an account, subscribing to, or otherwise using any Propagator Product, you consent to the collection of your Personal Information as described in this Privacy Policy, and you acknowledge that this collection is reasonably necessary for Propagator's functions and activities.

If you do not agree to this Privacy Policy, you should not use Propagator Products.

12. Consequences if information is not collected

If you do not provide the information Propagator requests, we may not be able to:

  • Allow you to subscribe to or otherwise use Propagator Products.
  • Perform or enforce the terms of your subscription.
  • Monitor your use of our products.
  • Develop, improve and refine our products.

13. Changes to this policy

We may update this Privacy Policy from time to time. Where changes are material, we will take reasonable steps to notify you, such as by posting a notice on the Propagator Website or by email.

14. Contact us

If you have any questions about this Privacy Policy, please contact us:

Name: Propagator Limited
Email: support@propagator.health