1. Introduction
This Privacy Policy explains how Anchr Digital Health Pty Ltd (ACN 696 944 537) ("Anchr", "we", "us", "our") collects, uses, shares and protects your personal information when you use the Anchr app, our websites and related services (together, "the App").
We are an Australian company. We handle personal information under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, and health information under state health records laws where they apply, including the Health Records and Information Privacy Act 2002 (NSW). Where you live outside Australia, we also respect the privacy laws that apply to you (see section 16).
2. Who to Contact
For privacy questions, requests or complaints, contact our privacy team at privacy@anchr.health. We may ask you to confirm your identity before acting on a request, usually by confirming the email address on your account.
If you are in the European Economic Area or the United Kingdom, use the same address with the subject line "GDPR Request".
3. Information We Collect
3.1 Account Information
- Email address, display name and avatar image
- Date of birth, if you choose to give it (used to confirm you are old enough to use the App)
- Sign-in details from Apple or Google if you use them: a unique identifier, your verified or relay email address, and your name if you share it
- Your acceptance of the Terms and this policy, your consent choices, and your App preferences
3.2 Check-Ins and Wellbeing Data
- Mood ratings, emotions, sleep, energy, stress, physical symptoms, activities and context tags
- Journal, gratitude and thought-snapshot text you write
- Wellbeing scores and streaks the App calculates from your check-ins
3.3 Screening Information
- Answers to standard wellbeing questionnaires (such as the PHQ-9 and GAD-7) if you are asked to complete them
- Estimates of these measures that the AI infers from your conversations
Screening information is used to tailor your support, to recognise when professional help may be useful, and to support safety. It is not shown to you in the App, and it is never a diagnosis. If you are linked to a clinician, they can see it only if you allow "Wellbeing screening" in your sharing settings.
3.4 Anchr Guide and Self-Care Data
- Your conversations with Anchr Guide (Explore & Discover and Talk It Through), including summaries, themes and takeaways created from them
- Numerical "embeddings" of your insights, used to give relevant context in later conversations
- Pathways, module and lesson progress, lesson notes and module feedback
- Toolkit practice records, your safety plan, tiny actions, distraction lists, deferred notes and letters you write
- Real Life focuses, plans and reflections
- Everyday Activities you choose for yourself: what each one is, the days and reminder times you pick, the days you mark, any notes, and how it felt
- Living Compass values and intentions, Thought Defusion entries, Digital Sunset reflections, Human Challenge and Anchr Moments completions, and AI Relationship Audit results
- Vulnerability Vault letters, voice memos and photos (stored privately and visible only to you)
3.5 Peer Support (Anchor Someone)
- Encouragement messages you write or receive, anonymous match records, and reports and blocks you make
- Automated moderation results for those messages
3.6 Information Connected With a Clinician
- Your link with a clinician, your sharing settings and changes to them, and a log of when your clinician accessed your information
- Connection requests you send through Find a Clinician
- What your clinician records about you in Anchr, such as an assigned pathway, a weekly focus, a safety plan, and their session notes (held on their behalf)
- Appointments, telehealth consent choices, and the state you tell us you are in at the start of each telehealth session
- Session audio and transcripts, only for telehealth sessions where you chose "Allow AI for this session"
- Session charges if your clinician bills you through Anchr: card brand, last four digits, expiry and charge status (your full card details are held by Stripe, not us)
3.7 Subscription Information
- Subscription status, plan, renewal and trial dates
- Purchase identifiers from Apple or Google, and an identifier from RevenueCat used to keep your subscription in sync. We never receive card details for subscriptions.
3.8 Device, Diagnostics and Usage Information
- Device platform, operating system version, locale and push notification token
- Crash and error diagnostics: the error type, a shortened technical message and code location, the App version and the screen you were on. We remove quoted text, emails and long numbers, and we do not include what you type.
- Product usage events: a fixed list of milestones (for example, finishing onboarding, starting a Guide session, completing a lesson, viewing subscription options), each with a timestamp, the App version and a few non-content details such as a module ID. These stay in our own database and are never sent to an analytics company.
- Security audit logs recording when health information is viewed, changed, exported or deleted, with a timestamp, IP address and device details
4. How We Collect It
- From you, when you use the App
- Generated by the App, including AI summaries, themes, screening estimates and wellbeing scores
- From your clinician, if you are linked to one, when they record information about your care in Anchr
- From Apple, Google, RevenueCat and Stripe, about sign-in, subscriptions and session payments
5. How We Use Your Information
- To provide the App: your check-ins, pathways, lessons, Toolkit, Real Life and other features
- To provide Anchr Guide and personalise it using the context described in section 7
- To recognise signs of crisis and show support resources, and to suggest professional help when it may be useful
- To share information with your clinician, as you choose (section 6)
- To run telehealth sessions, and AI note drafting where you allow it
- To run Anchor Someone, including moderation for safety
- To send notifications you have switched on
- To manage your subscription and any session payments
- To keep the App secure, prevent abuse, and keep audit records
- To fix problems and improve the App, using diagnostics, usage events and de-identified statistics
- To meet our legal obligations
We only use health information for these purposes, or for a directly related purpose you would reasonably expect, or where the law requires or permits it.
6. Sharing With Your Clinician
If you link your account to a clinician who uses Anchr, you choose what they can see before anything is shared. The categories are:
- Mood check-ins: mood, sleep, energy, stress and emotion tags, and short AI observations from any notes you add
- Anchr Guide conversations: full transcripts of Explore & Discover and Talk It Through, and short AI observations from them
- Lesson notes: reflections you write inside lessons
- Thought defusions: original thoughts, reframes, technique and intensity, and short AI observations from them
- Living Compass: domains, values and intentions
- Wellbeing screening: screening results and trends (visible to your clinician, not shown to you)
- Safety flags: severity tags recorded when a conversation crosses a safety threshold, and your safety plan
- My Journey snapshot: your reflective Journey letter
- Pathway progress: modules assigned, completed and pacing
- Moments practice: breathing, grounding and anxiety exercises, and short AI observations from them
- Real Life: only focus versions you separately preview and share
"AI observations" are brief notes the AI prepares for your clinician before your next session, such as a change in mood or a theme worth raising. They are only made from categories you share. Sharing a category includes what you recorded in it before you linked, as well as from then on. All categories except Real Life start switched on, and you can switch any of them off before linking or at any time afterwards. Your Vulnerability Vault, Toolkit practice records, the Everyday Activities you choose for yourself, Digital Sunset reflections, Human Challenge and AI Relationship Audit results are never shared with your clinician.
- You can ask us for a record of when your clinician accessed your information by emailing privacy@anchr.health.
- Your clinician is an independent health service provider. Information they receive or record becomes part of their clinical records, which they handle under their own privacy and record-keeping obligations. Switching a category off, or unlinking, stops new sharing but does not remove what your clinician has already received.
- You can also create a summary in Share with My Clinician and send it to any practitioner yourself. It contains only the sections and dates you choose.
7. AI and Automated Processing
AI processing needs your separate, explicit consent, which you give after accepting the Terms. You can withdraw it in Settings. Withdrawing stops new AI requests; it cannot undo processing that has already happened, and it does not cancel a subscription.
7.1 What Is Sent to the AI Provider
To generate responses, Anchr sends Anthropic, PBC (the provider of the Claude AI model): your messages and conversation history; relevant pathway, lesson, clinician-plan and wellbeing context, which can include summaries of your mood, sleep, activity, Thought Defusion and Living Compass data; optional journal and gratitude text for background analysis; and peer messages for moderation. Anything you type, including personal details, is part of what is sent, so avoid including details you do not want processed.
Your display name may be included so the Guide can greet you. We do not send your email address, date of birth, payment details or Vulnerability Vault content to Anthropic.
7.2 Automated Processing We Use
- Pathway and module suggestions based on your conversations and progress (you are free to ignore them; a linked clinician can set your pathway instead)
- If you are linked to a clinician, brief observations for your clinician, made only from the categories you share (section 6)
- Screening estimates inferred from conversations, used to tailor support and recognise when professional help may be useful
- Suggestions to seek professional support when a need appears to be beyond self-help, and safety responses when crisis language is detected
- Wellbeing scores calculated from your check-ins
- Moderation of peer messages
None of these decisions limit your access to the App or produce legal or similarly significant effects for you. You can ask for a person to review any automated decision by emailing privacy@anchr.health.
8. Who We Share Information With
We share information only with your clinician when you choose to (section 6), with the service providers below who help us run the App, and where the law requires or permits it. Each provider may use your information only to provide its service to us, under a written agreement.
8.1 Supabase (Database, Sign-In and File Storage)
- Stores all App data described in section 3, on Amazon Web Services infrastructure
- Location: Japan (Tokyo region)
- Privacy policy: https://supabase.com/privacy
8.2 Anthropic (AI Model)
- Generates Anchr Guide responses, summaries, embeddings, safety checks and moderation, as described in section 7.1. Under our commercial agreement, Anthropic does not use your information to train its models.
- Location: United States (Anthropic may also process requests in other countries where it operates)
- Privacy policy: https://www.anthropic.com/legal/privacy
8.3 Daily.co (Telehealth Video)
- Carries live video and audio for telehealth sessions, and records session audio only when you choose "Allow AI for this session"
- Location: United States
- Privacy policy: https://www.daily.co/legal/privacy
8.4 Deepgram (Session Transcription)
- Transcribes session audio for AI note drafting, only for sessions where you allowed it. We instruct Deepgram not to use the audio to train its models.
- Location: United States
- Privacy policy: https://deepgram.com/privacy
8.5 Stripe (Session Payments)
- Stores your card and processes session charges when your clinician bills you through Anchr
- Location: United States and Australia
- Privacy policy: https://stripe.com/privacy
8.6 RevenueCat, Apple and Google (Subscriptions and Sign-In)
- RevenueCat keeps your subscription status in sync; Apple and Google process purchases and optional sign-in, and deliver push notifications
- Location: United States
- Privacy policies: https://www.revenuecat.com/privacy, https://www.apple.com/legal/privacy, https://policies.google.com/privacy
8.7 Expo (Push Notifications)
- Delivers notifications you have switched on. Notifications do not contain health details.
- Location: United States
- Privacy policy: https://expo.dev/privacy
8.8 Postmark (Service Email)
- Sends service emails such as appointment confirmations, payment setup links, and session summaries your clinician chooses to send
- Location: United States
- Privacy policy: https://postmarkapp.com/privacy-policy
8.9 Google Places and Healthdirect (Find a Clinician)
- Search for local practitioners who are not on Anchr. Only the state or postcode you search for is sent, from our servers, never your identity or health information.
- Location: United States (Google) and Australia (Healthdirect Australia's National Health Services Directory)
8.10 When the Law Requires or Permits It
We may disclose information where required by law (for example, a court order or a valid request from a regulator), or where permitted by law to lessen or prevent a serious threat to someone's life, health or safety. Where it is lawful and practical, we will tell you first. If Anchr is sold or restructured, information may transfer to the new owner, who must continue to protect it as this policy describes, and we will tell you before that happens.
8.11 Changes to Providers
We will update this list when we add or change a provider. For a new provider that will handle health information, we will give at least 14 days' notice in the App.
8.12 Videos in Your Clinician's Lessons
A lesson from your clinician can link to a video on YouTube or Vimeo. The video opens on that site or app only when you tap it, and their privacy policy applies there. We do not send them anything about you.
9. What We Never Do
- Sell or rent your personal information, or share it for advertising
- Use third-party analytics, advertising or tracking tools, or track you across other apps and websites
- Use your information to train AI models, or allow our providers to do so
- Share your health information with employers, insurers or data brokers
- Share anything with your clinician that you have not allowed
10. Overseas Storage and Transfers
Your information is stored in Japan and processed in the United States and Australia by the providers listed in section 8. Before disclosing information overseas, we take reasonable steps (including written agreements) to make sure those providers protect it in line with the Australian Privacy Principles, and we remain accountable for how they handle it.
Overseas laws may not protect personal information in the same way as Australian law, and authorities in those countries may in some circumstances be able to access it. For transfers from the EEA, the UK or Switzerland, we rely on Standard Contractual Clauses or equivalent safeguards. You can ask us for more detail at privacy@anchr.health.
11. How We Protect Your Information
- Encryption in transit (TLS 1.2 or higher) and at rest (AES-256)
- Database rules that limit access to your own account, and to a linked clinician only for the categories you allow
- Private, access-controlled storage for Vault media, avatars and documents
- Sign-in tokens kept in your device's secure storage (Keychain or Keystore), and optional Face ID or fingerprint unlock
- Append-only audit logs of access to health information, least-privilege access for our systems, and rate limiting to prevent abuse
- Screen-capture protection on sensitive screens
11.1 Device Permissions
- Camera: for Vault photos, your profile picture and telehealth video, only when you use those features
- Microphone: for Vault voice memos and telehealth sessions, only when you use those features. We never listen in the background.
- Photo library: to choose a photo for your Vault or profile
- Notifications: for reminders and alerts you switch on
Photos you upload can contain hidden details such as the date and, if your device added it, location. We do not use these details, but they stay in the file until you delete it. Your device can remove location before sharing.
No system is completely secure. If you find a security issue, please tell us at privacy@anchr.health with the subject "Security Report". We will not take legal action against good-faith research that follows responsible disclosure.
12. How Long We Keep Information
- Most information is kept while your account is open. You can delete individual entries at any time.
- Telehealth session audio is deleted once your clinician signs the note, within 7 days at most.
- Unmatched Anchor Someone requests expire after 24 hours.
- Security audit logs are kept for at least 6 years. When you delete your account, they are anonymised rather than deleted.
- When you delete your account, your information is deleted from our database and storage. Encrypted backups clear within 30 days.
- If you are linked to a clinician when you delete your account, the records held in Anchr for that link, including your clinician's session notes, are also deleted from Anchr. Your clinician may be required by law to keep clinical records and may keep copies outside Anchr.
- Information already processed by a provider is handled under that provider's retention terms. Anthropic does not use it for training.
13. Your Choices and Rights
13.1 Access and Export
You can see your information in the App and download an export from Settings. The export does not include screening estimates or records written by your clinician. You can ask us for screening information by email, and ask your clinician for their records. We will respond within 30 days and explain if the law allows us to refuse any part of a request.
13.2 Correction
You can edit most information in the App. If something we hold is wrong, email us and we will correct it or explain why we cannot.
13.3 Deletion
You can delete entries at any time, and delete your account in Settings. Deletion is permanent. See section 12 for what happens to audit logs and clinician records.
13.4 Withdrawing Consent
- AI processing: withdraw in Settings
- Sharing with your clinician: change your sharing settings or unlink at any time
- AI note drafting: choose for each telehealth session
- Notifications: turn them off in the App or your device settings
13.5 Anonymity
You can use a display name that does not identify you. Some features (such as linking with a clinician, telehealth and payments) need you to identify yourself.
13.6 Complaints
Please contact us first at privacy@anchr.health. If you are not satisfied with our response within 30 days, you can complain to the Office of the Australian Information Commissioner (oaic.gov.au, 1300 363 992). For health information handled in New South Wales, you can also contact the NSW Information and Privacy Commission (ipc.nsw.gov.au, 1800 472 679).
14. Young People
Anchr is for people aged 16 and over. If you are 16 or 17, a parent or guardian should agree to your use of the App. We do not knowingly collect information from anyone under 16. If we learn that we have, we will delete it. If you think your child under 16 is using Anchr, please contact us at privacy@anchr.health.
15. Data Breaches
If we suspect a data breach, we will act quickly to contain it and assess it. Under the Notifiable Data Breaches scheme, if a breach is likely to cause serious harm, we will notify the Office of the Australian Information Commissioner and the people affected as soon as practicable. Where other laws apply (such as the GDPR or US state laws), we will also notify regulators and people within the timeframes those laws require. Notifications will explain what happened, the information involved and what you can do.
16. If You Live Outside Australia
16.1 European Economic Area and United Kingdom
You have rights under the GDPR or UK GDPR to access, correct, delete, restrict, object to and port your information, and to complain to your data protection authority. We rely on your explicit consent for health information (Article 9(2)(a)), on our contract with you to provide the App, on legitimate interests for security and improvement, and on legal obligations for record keeping. Email privacy@anchr.health with the subject "GDPR Request".
16.2 United States
Residents of California and other states with privacy laws may have rights to know, access, correct, delete and port their information, to limit the use of sensitive information and to appeal a refused request. We do not sell or share personal information for cross-context behavioural advertising, and we use sensitive information only to provide the App. Email privacy@anchr.health with the subject "Privacy Rights Request". You may use an authorised agent. If we refuse a request, you can appeal within 60 days with the subject "Privacy Appeal". Anchr is not a HIPAA covered entity, but we apply safeguards aligned with HIPAA's security principles.
16.3 Canada
You have rights under PIPEDA and provincial laws to access and correct your information, withdraw consent and complain to the Office of the Privacy Commissioner of Canada.
17. Cookies and Our Website
The App does not use cookies or any advertising or tracking technology, so it does not show Apple's tracking prompt. Our website (anchr.health) does not use cookies or analytics. It loads fonts and scripts from public content delivery networks (such as Google Fonts, jsDelivr and unpkg), which receive your IP address and browser details when serving those files, and it may remember a display preference in your browser.
We only send marketing emails if you opt in, and you can unsubscribe at any time. Service emails (such as account and security messages) are part of using the App.
18. Changes to This Policy
We will update this policy when our practices or the law change, and update the Effective Date above. For material changes (such as new kinds of information or new providers handling health information), we will tell you in the App at least 14 days before they take effect.
19. Contact Us
Anchr Digital Health Pty Ltd (ACN 696 944 537)
- Privacy enquiries, requests and complaints: privacy@anchr.health
- GDPR requests: subject line "GDPR Request"
- US state privacy requests: subject line "Privacy Rights Request"
We acknowledge enquiries within 5 business days and respond in full within 30 days, or sooner where the law requires.