Eat Well Health — Privacy Policy

Effective date: 30 May 2026

Version: v2026-05-30

1. Who we are

Eat Well Health is operated by Eat Well Health Pty Ltd (ABN 52 678 935 638), a registered Australian business with its registered office at 111 Sturt Street, Adelaide SA 5000. We provide clinically-governed nutrition screening, nutrition products and dietitian access to older Australians and the providers who care for them. Eat Well Health and Optimal Essentials are sister brands under common ownership; Optimal Essentials formulates the nutrition products and Eat Well Health operates the Support at Home service model.

Eat Well Health is a private-sector health service provider under the Privacy Act 1988 (Cth). We are covered by the Australian Privacy Principles regardless of our size or revenue, and we treat all health information we hold as sensitive personal information.

We are also subject to the Health Records Act 2001 (Vic), the Health Records and Information Privacy Act 2002 (NSW), and the Health Records (Privacy and Access) Act 1997 (ACT) for clients resident in those jurisdictions.

This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, who we share it with, when it leaves Australia, how long we keep it, and how you can access, correct or complain about how we handle your information.

2. What this policy covers

This Privacy Policy applies to anyone whose personal information is held by Eat Well Health — clients, Support at Home program participants, provider and clinical staff who hold Eat Well Health accounts, and visitors to our websites. It does not cover third-party websites we may link to, or information held by Support at Home provider partners about their clients other than information shared with Eat Well Health.

If you are unsure whether this policy applies to you, contact us at hello@eatwellhealth.com.au.

3. What personal information we collect

If you are a client

We collect:

Identifying information — name, date of birth, address, email address, phone number, and account login credentials. Where you are receiving services through the Support at Home program, we also collect your Aged Care Number for matching with your provider’s records.

Health information — when you complete the Eat Well Health nutrition screen, you provide answers to six clinical questions (appetite and food intake, recent unintentional weight loss, physical mobility, recent acute illness or stress, neuropsychological factors, and either body mass index or a calf-circumference measurement). The screen produces a score and a category (Normal, At Risk, or Malnourished). All of this is health information under Australian law and we treat it as sensitive personal information.

Service and product information — records of products you have purchased, dietitian appointments, communications with our team, and your screening history over time.

Technical and usage information — limited information collected when you use our website, including IP address, device type, browser type and pages visited, for security and analytics purposes.

If you are a provider, dietitian, pharmacist or other professional user

We collect your name, work email address, work phone, organisation, role and an account login. Where relevant, professional registration details. We also hold records of clients you have referred to or are working with through Eat Well Health, orders you have placed or approved, and your account configuration.

If you receive marketing communications

If you have subscribed to our newsletter or chosen to receive product updates, we hold your email address, the date and source of your subscription, and your engagement history with our communications. You can unsubscribe at any time using the link in any marketing email.

4. How we collect personal information

We collect information directly from you when you create an account, complete the nutrition screen, place an order, schedule a dietitian appointment, subscribe to a mailing list, or fill in a contact form.

We also collect information from third parties in limited circumstances:

•       From your Support at Home provider, pharmacist or dietitian where they enrol you into Eat Well Health services on your behalf and with your consent

•       From publicly available business directories and professional networks where we are identifying provider organisations and the relevant professional contacts for outreach

•       From service providers we engage to deliver our service (for example, our payments provider provides us with the status of a transaction)

We do not collect sensitive information about you without your consent, except where we are permitted or required to do so by Australian law.

5. Why we collect, use and disclose personal information

We collect, use and disclose your information to:

•       Run the Eat Well Health nutrition screen and produce your result

•       Recommend a nutrition product matched to your screening result

•       Suggest a dietitian referral where your screening result indicates that may be helpful

•       Process and deliver orders, manage subscriptions, and invoice for products and services

•       Share your screening result, recommended product and dietitian-referral status with your care team — typically your Support at Home provider’s care coordinator and your assigned Eat Well Health dietitian — so they can support your nutrition plan

•       Respond to your questions, requests for support, complaints or feedback

•       Administer customer accounts, prevent fraud and security incidents, and improve our service

•       Comply with our legal obligations including under the Aged Care Act 2024, the Privacy Act 1988, and the laws of relevant Australian states

•       Send transactional communications such as order confirmations, screening result emails, invoices, appointment confirmations and account notifications

•       Where you have subscribed, send marketing communications

We do not use your health information for marketing without your specific consent. We do not sell your personal information to anyone.

6. Who we share your personal information with

Your care team

If you are a client receiving services through a Support at Home provider, we share your screening result, score, category, recommended product and dietitian-referral status with your provider’s care coordinator and (if applicable) your assigned Eat Well Health dietitian. This is the central operational flow of Eat Well Health and is essential to the service you receive. We do not share this information with anyone else inside or outside your provider’s organisation without your specific consent or unless required by law.

Our service providers

We engage a number of third-party services to operate Eat Well Health. Each of these holds and processes some of your information on our behalf. We remain accountable for how they handle your information.

We take reasonable steps to ensure each of these providers handles your information in accordance with the Australian Privacy Principles or equivalent standards.

Other circumstances

We may also disclose your information:

•       Where you have given us consent for a specific further use or disclosure

•       Where required by Australian law (for example, in response to a court order or regulatory request)

•       Where necessary to investigate suspected illegal activity or to protect a person’s life, health or safety

•       In connection with a sale or restructure of our business, where the recipient agrees to handle your information consistently with this policy

7. When your personal information leaves Australia

Several of the service providers listed in section 6 are based outside Australia. This means some of your personal information — including, in some cases, your health information — is disclosed to overseas recipients within the meaning of Australian Privacy Principle 8.

The countries where your information may be processed are:

•       The United States — Bluehost (our primary clinical database and application platform), Twilio SendGrid (outbound transactional email), Apollo.io, and parts of Shopify’s infrastructure

•       Singapore — Shopify’s regional contracting entity for Australian merchants

•       Other regions where Zoho sub-processors operate — refer to Zoho’s published sub-processor list available at zoho.com/privacy

When we disclose personal information to an overseas recipient we take steps that we consider reasonable in the circumstances to ensure the recipient does not breach the Australian Privacy Principles. We remain accountable under Australian law for how these overseas recipients handle your information.

8. Automated decision-making and the Eat Well Health screening engine

Eat Well Health uses a computer program to:

•       Score your screening answers and assign you to a screening category (Normal, At Risk – Same Weight, At Risk – Weight Loss, Malnourished)

•       Recommend a nutrition product matched to your category, based on a deterministic rule set that takes into account your screening result and any dietitian-recommended override on your account

•       Determine whether a dietitian referral is suggested alongside your result

These are decisions made by a computer program that could reasonably be expected to affect your interests. The information used by these decisions is the personal and health information you provided during the screen, together with any clinical configuration already on your account.

The decisions are designed as a screen, not a diagnosis. The screening tool does not replace clinical judgement and the result is intended to inform a conversation with your care team, not to make a clinical decision on its own.

If you would like to understand how a specific decision affecting you was reached, or you would like the decision reviewed by a person, please contact us.

We may use automation in other parts of our service from time to time. Where we do, we will update this section to describe the additional uses.

9. How we protect your personal information

We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure. These steps include technical, organisational and contractual measures appropriate to the sensitivity of the information.

If you become aware of a possible security incident affecting your information, please contact us — see section 13.

10. How long we keep your information

We keep your personal information for as long as we need it for the purposes set out in this policy, and for any longer period required by law. Health information is subject to minimum retention periods under Australian state health records law (notably a seven-year minimum under the Health Records Act 2001 (Vic)). When information is no longer needed and we are not required by law to retain it, we securely delete or de-identify it.

11. Accessing and correcting your personal information

You have the right to ask us what personal information we hold about you, to receive a copy of it, and to correct any information that is inaccurate, out of date or incomplete.

To make a request, contact us using the details in section 13. We will respond within a reasonable period consistent with the Privacy Act 1988 and any applicable state health records law. We may need to verify your identity before providing access.

In limited circumstances we may need to refuse access or correction — for example where another person’s privacy would be affected, or where access is restricted by law. If we do, we will explain why and tell you how to complain.

12. Marketing communications

If you are subscribed to marketing communications from us, you can unsubscribe at any time using the link in any marketing email. We do not use information you have shared with us in a clinical or service-delivery context for marketing without your consent.

13. How to contact us, and how to make a complaint

You can contact us about anything in this Privacy Policy at:

Eat Well Health Pty Ltd — Privacy

Email: hello@eatwellhealth.com.au

Phone: 08 6119 3698 (9:00am – 5:00pm CST, Mon–Fri)

Postal: 111 Sturt Street, Adelaide SA 5000

If you would like to make a complaint about how we have handled your personal information, please contact us using the details above. We will acknowledge your complaint and respond within a reasonable period.

If you are not satisfied with our response, you have the right to complain to the Office of the Australian Information Commissioner (oaic.gov.au), or — for Victorian-resident or NSW-resident clients — to the Victorian Health Complaints Commissioner or the Information and Privacy Commission NSW respectively.

14. Changes to this policy

We may update this Privacy Policy from time to time. The current version is the one published at eatwellhealth.com.au/policies/privacy-policy. Where a change materially affects how we handle your information, we will take reasonable steps to notify you.

Notes for clients

The Eat Well Health nutrition screening tool is a screen, not a diagnosis. It is intended to support a conversation with your care team, not to replace clinical assessment.

When you complete the screen, the result is shared with your Support at Home provider’s care coordinator and (if applicable) your assigned Eat Well Health dietitian. If you do not want your information shared this way, please contact us — alternative arrangements may be possible but they materially change the service you receive.

Notes for provider, dietitian, pharmacist and staff users

Your professional account is governed by the Eat Well Health Provider Terms (available on request) and by this Privacy Policy. Information about clients held in the Eat Well Health platform is shared with you for the purpose of supporting their care and must not be used for other purposes.

You may also have obligations under the Aged Care Act 2024 and the Aged Care Quality Standards that apply to information about Eat Well Health clients. Where those laws require more of you than this Privacy Policy, you must follow them.

The Eat Well Health Provider Assurance Pack sets out our commitments to you as an upstream service provider. You can request a copy at any time.