1. About this policy
Hinterflow Pty Ltd ("Hinterflow", "we", "us", "our") is an Australian company committed to handling personal information responsibly and in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
This policy explains what information we collect, why we collect it, how we use and protect it, and when it may be disclosed — including to overseas recipients. Because Hinterflow is used in the context of health and aged care assessments, much of the information we handle qualifies as sensitive information (specifically health information) under the Privacy Act. We treat all such information with the heightened obligations that applies.
By using Hinterflow you agree to the collection and use of information as described in this policy. If you do not agree, please do not use the platform.
2. Who we are
Hinterflow Pty Ltd is an Australian proprietary company. Our Privacy Officer can be contacted at privacy@hinterflow.com.
We are the data controller for account information and usage data. For interview transcripts and assessment content, we act as a data processor on behalf of the organisation or individual using our platform (the assessor or their employer).
3. Information we collect
Account information
Name, email address, organisation name, and professional role when you register an account.
Voice interview audio
Audio recorded during a voice interview session. Audio is streamed in real time to our voice processing service for transcription. Raw audio is not stored after the session ends. Only the transcript is retained.
Interview transcripts
Text transcribed from voice interviews. Transcripts may contain health information about the person being assessed — including medical history, functional status, care needs, medications, diagnoses, and other sensitive personal information shared during the interview.
Extracted assessment data
Structured data mapped from the transcript to specific form fields. This is derived from the transcript and may contain the same categories of sensitive information.
Usage data
Log data including IP addresses, browser type, pages visited, and timestamps — used for security monitoring and service operation. This data does not include assessment content.
What we do not collect
We do not collect My Health Record data. We do not independently collect information about clients being assessed — all such information enters the platform through the interview conducted by the assessor.
4. How and why we collect information
We collect information to provide the Hinterflow service. Specifically:
- Account information is collected to authenticate users and operate the platform
- Voice audio is collected to enable real-time transcription
- Transcripts and extracted data are collected to support the assessment workflow and form-filling functionality
- Usage data is collected for security, reliability, and operational monitoring
We collect health information about clients only because it is inherent to the assessment workflow. Assessors are responsible for ensuring they have appropriate authority and consent to use Hinterflow during a client interview. See Section 9 (Consent obligations) below.
We do not use assessment data for any purpose other than providing the service to the assessor who conducted the interview.
5. Health information — heightened obligations
Health information is sensitive information under the Privacy Act 1988 (Cth). This means we are subject to stricter obligations in how we collect, use, and disclose it:
- We collect health information only where it is reasonably necessary for the direct provision of our service
- We do not use health information for any secondary purpose without consent
- We do not disclose health information to any party other than those necessary to operate the service, as described in this policy
- We do not use or disclose health information for direct marketing
- We do not use client health information for AI model training
6. Data storage and sovereignty
All account data, interview transcripts, extracted assessment data, and associated records are stored in Australia on Amazon Web Services infrastructure in the Sydney region (ap-southeast-2). This is a structural commitment: the database, file storage, and all persistent data reside in Australia.
Backups are also retained within ap-southeast-2.
7. Overseas processing — AI inference
While all data is stored in Australia, some AI processing involves sending data to services operating in the United States. This is an overseas disclosure under APP 8. We disclose it fully here.
Voice transcription (Amazon Nova Sonic)
Voice audio from interviews is streamed in real time to Amazon's Nova Sonic AI model, which operates in AWS infrastructure in the United States (us-east-1). This service transcribes the audio and returns the text transcript. The audio is not stored by AWS after transcription. This processing is governed by the AWS Service Terms and our AWS Data Processing Addendum, under which AWS is contractually prohibited from using customer data to train or improve AI models.
AI field extraction (Anthropic Claude)
Transcript text is sent to Anthropic's Claude API for structured data extraction — identifying and mapping information to form fields. This processing may occur on infrastructure outside Australia. Anthropic's API terms prohibit using customer data for model training. Processing is transient; the result is returned and the source data is not retained by Anthropic.
Your rights and APP 8
Under APP 8, before disclosing personal information overseas we are required to take reasonable steps to ensure the overseas recipient does not breach the APPs. We have done this by:
- Executing an AWS Data Processing Addendum covering all AWS services including Bedrock
- Using Anthropic's API under terms that prohibit data retention and training use
- Limiting what data is sent — only the transcript or relevant excerpt, not full account records
- Ensuring processing is transient — data is sent for inference and the result returned; it is not persisted by these providers
By using Hinterflow, you acknowledge that AI inference processing occurs in the United States under these contractual protections. If your organisation's policies prohibit any overseas processing of health information, you should not use Hinterflow without first seeking independent legal advice.
8. Disclosure of information
We do not sell, rent, or trade personal information. We disclose information only as follows:
- Amazon Web Services: cloud infrastructure (storage, compute, voice transcription) — covered by our AWS Data Processing Addendum
- Anthropic: AI text processing — covered by Anthropic's API terms prohibiting data retention and training use
- Law enforcement or regulators: where required by Australian law, a court order, or to protect the rights and safety of individuals
We do not disclose client assessment data to any other third party for any purpose.
9. Consent obligations for assessors
Hinterflow is a tool for professional assessors. If you use Hinterflow in a client interview, you are responsible for:
- Informing the client that the interview is being recorded and transcribed
- Informing the client that AI processing — including overseas processing — will be used to assist with their assessment
- Obtaining the client's consent (verbal or written, as appropriate to your professional context) before starting a Hinterflow session
- Complying with any consent obligations under your professional registration, employer policy, or applicable legislation (including aged care, disability, or health privacy laws)
We provide guidance on how to explain Hinterflow to clients. You remain responsible for obtaining and documenting consent.
10. Data retention
Interview transcripts and extracted data are retained for as long as your account is active or as required by applicable law. You may delete individual sessions or your entire account at any time through the platform. Deletion permanently removes the associated transcript and extracted data from our systems.
Encrypted backups may retain deleted records for up to 30 days before permanent removal. Usage logs are retained for 90 days.
We do not retain raw voice audio after a session ends.
11. Security
We implement technical and organisational measures to protect personal information against unauthorised access, disclosure, alteration, or destruction. These include:
- Encryption in transit (TLS) for all data sent between your browser, our platform, and AI services
- Encryption at rest for stored data
- Authentication controls and role-based access
- Web Application Firewall and rate limiting
- Infrastructure contained within a private network
No method of transmission or storage is completely secure. In the event of a data breach likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required under the Notifiable Data Breaches scheme.
12. Your rights
Under the Australian Privacy Principles, you have the right to:
- Know what personal information we hold about you
- Access personal information we hold about you
- Correct inaccurate, out-of-date, or incomplete information
- Request deletion of your data (subject to legal retention obligations)
- Complain about a breach of the APPs
To exercise these rights, contact our Privacy Officer at privacy@hinterflow.com. We will respond within 30 days.
Note: client data is held on behalf of the assessor or their organisation. If a client wishes to access or correct their information, they should contact the assessor directly. We will assist with any such request where we are able.
13. Cookies and tracking
We use essential session cookies to maintain your authenticated state. We do not use third-party tracking cookies, advertising cookies, or analytics services that send data to third parties.
14. Changes to this policy
We may update this policy from time to time. We will notify registered users of material changes by email at least 14 days before they take effect. The date at the top of this page reflects when the policy was last updated. Continued use after changes take effect constitutes acceptance.
15. Contact and complaints
For privacy enquiries or to exercise your rights, contact our Privacy Officer:
Email: privacy@hinterflow.com
Organisation: Hinterflow Pty Ltd, Australia
If you are unsatisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC).