Privacy policy

Last updated: 12 October 2026

ABOUT THIS POLICY

This Privacy Policy explains how TenX2 Pty Ltd (ABN 65 702 247 809) trading as Hundred Holistic ("Hundred Holistic", "we", "us", "our") collects, holds, uses and discloses your personal information, including your health information, when you use the Hundred Holistic Patient Portal and related services (the "Services").

The Services are a closed patient portal, available only to Australian residents with an Australian delivery address who hold a current prescription issued by an Australian registered medical practitioner or nurse practitioner. We do not supply or deliver outside Australia. Because we handle health information, we are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) regardless of our size, and by the Health Records Act 2001 (Vic) and other applicable state and territory health records laws.

This Policy should be read together with our Terms of Service. If there is any inconsistency about how we handle your personal information, this Policy applies.

OUR ROLE AND WHO ELSE HANDLES YOUR INFORMATION

Hundred Holistic operates the portal. We are not your prescriber and we are not a pharmacy. Your care involves other independent organisations, each of which is responsible for its own handling of your information under its own privacy policy:

  • Your prescriber or telehealth clinic, who makes clinical decisions about your treatment and issues your prescription.
  • Our partner pharmacy, whose pharmacists check, dispense, label and supply your medication and keep the dispensing records required by law.

We share information with them only as described in this Policy.

THE INFORMATION WE COLLECT

We collect only the information that is reasonably necessary to provide the Services and meet our legal obligations. Depending on how you use the Services, this may include:

  • Identity and contact details: your name, date of birth, email address, phone number, and residential, billing and delivery addresses.
  • Identity verification information: details or copies of identification documents used to confirm your identity and age.
  • Health information: your prescription details (including medication, strength, dose, quantity, repeats and expiry), any approval or authorisation under which your medication is prescribed (for example, under the TGA Special Access Scheme or Authorised Prescriber Scheme), your prescriber's details, your order and dispensing history, and any information you give us about side effects, adverse events or your treatment.
  • Government identifiers: where needed for your prescription or dispensing, such as your Medicare number or Individual Healthcare Identifier. We do not use these as our own identifier for you.
  • Account information: your login details, account settings and the products you are authorised to access.
  • Transaction information: orders, payments, refunds, returns and delivery details. Card payments are processed by our payment providers. We do not store your full card number.
  • Communications: the content of emails, calls, messages and complaints you send us.
  • Technical information: your IP address, device and browser information, and how you use the portal, collected through cookies and similar technologies.

Health information is "sensitive information" under the Privacy Act. We collect it only with your consent, or where it is required or authorised by law.

HOW WE COLLECT YOUR INFORMATION

  • From you, when you accept an invitation, create an account, place an order or contact us.
  • From your prescriber or telehealth clinic, who provides your prescription and approval details so that we can verify your eligibility and set up your access.
  • From our partner pharmacy, about the status of your prescription, dispensing and delivery.
  • From our service providers, such as identity verification, payment and delivery providers.
  • Automatically, through cookies and similar technologies when you use the portal.

Because the Services involve supplying prescription medication, it is not practicable for you to use them anonymously or under a pseudonym. If you do not provide the information we ask for, we may not be able to verify your eligibility or process your orders.

HOW WE USE YOUR INFORMATION

We use your information to:

  • verify your identity, age, eligibility and prescription;
  • control which products you can see and order, based on your own current prescription and approval;
  • process orders and payments, and arrange dispensing by our partner pharmacy and secure delivery;
  • notify you about your account, orders, deliveries, and when your prescription is due to expire;
  • manage refunds, returns, complaints, product recalls and adverse event reports;
  • keep the records required by law and respond to lawful requests from regulators and authorities;
  • protect the security of the Services and detect and prevent fraud, misuse or diversion of medication; and
  • maintain and improve the portal, using de-identified or aggregated information where possible.

Automated access decisions. The portal automatically grants and removes your access to each product based on your prescription details, including its expiry date and remaining repeats. This is not a clinical decision. If you believe your access is wrong, contact us and a team member will review it.

NO MARKETING OR ADVERTISING OF MEDICATION

Under Australian law, prescription medication cannot be advertised to the public. We do not use your personal or health information to advertise or promote medication to you, and we do not use your health information to build advertising profiles.

We do not sell your personal information, and we do not share your health information with advertising networks, data brokers or social media platforms.

We may send you service messages about your account, orders and prescriptions. These are not marketing. If we send you any other communications that are permitted by law, we will only do so with your consent, and you can unsubscribe at any time.

WHO WE DISCLOSE YOUR INFORMATION TO

We disclose your information only as needed to provide the Services, with your consent, or as required or authorised by law. This may include disclosure to:

  • your prescriber or telehealth clinic, for example to confirm prescription details or tell them your prescription is due to expire;
  • our partner pharmacy, to dispense and supply your medication;
  • service providers who help us operate the Services, such as our e-commerce platform provider (Shopify), payment processors, identity verification providers, couriers, IT and cloud hosting providers, and our professional advisers. They may only use your information to provide services to us;
  • regulators, government agencies and law enforcement where required or authorised by law, including the Therapeutic Goods Administration and state and territory health departments; and
  • a purchaser or successor of our business, subject to equivalent privacy protections.

We will not disclose your health information to your employer, insurer or family members without your consent, unless required or authorised by law.

OVERSEAS DISCLOSURE

Our business, our partner pharmacy, prescribers and couriers are all located in Australia, and we only supply patients in Australia.

However, the portal is hosted on Shopify, and some of our technology providers (such as hosting, payment and email providers) store or process data on servers outside Australia, including in Canada and the United States. This means your personal information, including information about your orders, may be stored or processed overseas by these providers. Before using any provider that stores data overseas, we take reasonable steps to ensure it handles your information in a way that is consistent with the APPs, and it may only use your information to provide services to us.

COOKIES AND ANALYTICS

The portal uses cookies and similar technologies that are necessary for it to work, such as keeping you logged in, securing your session and processing checkout. We may also use analytics to understand how the portal is used. We configure these tools so that your prescription and product details are not sent to third-party advertising or social media platforms. You can control cookies through your browser settings, but disabling necessary cookies may stop the portal from working.

Shopify collects certain information about your use of the portal in order to host and secure it. For information about how Shopify handles personal information, see the Shopify Consumer Privacy Policy.

HOW WE PROTECT YOUR INFORMATION

We take reasonable steps to protect your information from misuse, interference, loss, and unauthorised access, modification or disclosure. These include encrypted connections, access controls limited to staff who need the information, invitation-only portal access, and contractual obligations on our service providers.

Please do not send prescriptions, identification documents or health information to us through unsecured channels such as social media. You are responsible for keeping your login details secure and must not share your account.

DATA BREACHES

If we become aware of a data breach that is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner (OAIC) as required under the Notifiable Data Breaches scheme.

HOW LONG WE KEEP YOUR INFORMATION

We keep health information for as long as required by law. Under the Health Records Act 2001 (Vic), this is generally at least seven years after your last use of the Services, or for a person who was under 18 at that time, until they turn 25. Our partner pharmacy keeps its own dispensing records for the periods required by pharmacy and poisons laws. When information is no longer needed, we securely destroy or de-identify it.

ACCESSING AND CORRECTING YOUR INFORMATION

You can ask to access, or to correct, the personal and health information we hold about you by contacting our Privacy Officer. We will need to verify your identity first. We will respond within 30 days. Access is generally free. If we refuse a request, we will tell you why in writing and how to complain.

Because we must keep certain records by law, we may not be able to delete some information on request. Requests to change prescription details must be made through your prescriber.

COMPLAINTS

If you have a concern about how we have handled your personal information, please contact our Privacy Officer in writing. We will acknowledge your complaint within 7 days and aim to resolve it within 30 days.

If you are not satisfied with our response, you can contact:

  • the Office of the Australian Information Commissioner: www.oaic.gov.au or 1300 363 992; or
  • for health information, the Health Complaints Commissioner (Victoria): hcc.vic.gov.au or 1300 582 113, or the equivalent body in your state or territory.

CHANGES TO THIS POLICY

We may update this Policy to reflect changes in law, regulatory requirements or our practices. We will post the updated Policy on this page with a new "Last updated" date and, where the changes are significant, notify you.

CONTACT US


TenX2 Pty Ltd trading as Hundred Holistic
Suite 381/11 Wilson St, South Yarra VIC 3141 Australia.
Email: holistic@hundredhealth.com.au
Phone: 1300 006 569
ABN: 65 702 247 809