Privacy Policy

1. Who we are

CHM Solutions Pty Ltd ("we", "us", "our") develops and publishes the Luria Sequencing iOS application. For privacy enquiries, visit our Contact Us page.

2. Who this policy applies to

This policy applies to healthcare professionals and clinical researchers ("clinicians") who use the Luria Sequencing app to record and score the Luria three-step motor sequence. The app is not intended for direct use by patients. Before recording, the app requires the clinician to confirm a consent step; clinicians are responsible for obtaining the patient's consent to be filmed and for ensuring their use of the app complies with all applicable laws and professional obligations in their jurisdiction, including consent and health-record requirements for video of a patient.

3. What data the app processes

3.1 Video recording

The app uses the device camera to record the patient performing the assessment, so the clinician can replay it in slow motion and score it calmly and consistently afterwards. The recording is held only on the device that captured it. It is never transmitted, uploaded, or made accessible to CHM Solutions Pty Ltd or any third party.

3.2 Automatic deletion

Once the clinician finalises scoring for a clip, the app automatically deletes that recording. This happens without any further action from the clinician — there is no separate confirmation step and no setting to retain clips beyond this point.

• Recordings are never uploaded, at any point.
• Recordings are automatically deleted once scoring is finalised.
• The app does not maintain a video library, backup, or history of past recordings.

3.3 Scoring tallies

Tallies of successes, errors, freezes and hesitations are shown on screen during and after scoring. The app itself does not export, transmit, or persist these tallies once the session ends — it has no export feature and keeps no results history. If a clinician wants to retain a record of the results, they note them down separately, in their own patient records or systems, outside the app.

3.4 Data we do not collect

The app does not collect, transmit, or store:

• Patient names, identifiers, or demographic information
• Scoring tallies or results, beyond the active session
• Precise location data
• Any usage analytics — the app has no analytics SDK and makes no network connections for patient data of any kind

4. Clinical and regulatory context

4.1 HIPAA (United States)

The Luria Sequencing app does not receive, transmit, or maintain any patient data or recording on behalf of any covered entity or business associate — recording, scoring and deletion all occur entirely on the clinician's own device, and nothing is sent to CHM Solutions Pty Ltd. While a recording exists briefly on-device, it is created, held, and deleted automatically within the app's local sandbox; the primary responsibility for safeguarding the device during that window (passcode, encryption, physical security) sits with the clinician under their own HIPAA obligations. Because the app itself never receives or stores patient data, no Business Associate Agreement with CHM Solutions Pty Ltd is required for use of the app.

4.2 Australian Privacy Act 1988

CHM Solutions Pty Ltd is an Australian company and operates in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth). Video recorded during an assessment is personal (and likely sensitive, health-related) information, but it is captured, processed, and deleted entirely on the clinician's device and is never collected or received by CHM Solutions Pty Ltd — so most APPs are not engaged in ordinary use of the app by us. The clinician remains responsible, as the entity actually holding the recording during the local scoring window, for handling it in line with their own APP obligations. Any personal information you provide to us directly (e.g. via support requests) will be handled in accordance with the APPs and used only to respond to your enquiry.

4.3 GDPR (European Economic Area and United Kingdom)

If you are located in the EEA or UK, the following applies:

• Controller: CHM Solutions Pty Ltd acts as data controller only in respect of any personal data you send to us directly (e.g. support messages). We do not act as controller or processor for the video recordings or scoring tallies created within the app — these are never transmitted to us.
• Processors: The app uses no third-party analytics or data processors of any kind.
• Legal basis: Legitimate interests or contract performance for support communications only.
• Your rights: You have the right to access, rectify, erase, restrict, or port any personal data we hold about you, and to object to processing. Visit our Contact Us page to make a request.
• Health data: Assessment recordings may constitute special category (health-related) data while they exist on the clinician's device. Because this data is never transmitted to or held by CHM Solutions Pty Ltd, we do not process it as controller or processor under GDPR. The clinician, as the party capturing and locally holding the recording, is the controller for that data during the recording-to-deletion window and remains responsible for its handling under GDPR.
• International transfers: No video or clinical data leaves the clinician's device, so no international transfer occurs in respect of that data. Where we receive personal data from EEA contacts directly (e.g. support enquiries), we rely on standard contractual clauses or consent as our transfer mechanism.

5. Data retention

Video recordings are deleted automatically as soon as scoring is finalised; the app retains no recording, tally, or results history beyond that point. Any personal data sent to us via support is retained only as long as necessary to resolve the enquiry, and no longer than 3 years.

6. Security

Recording, scoring and deletion all take place entirely on the clinician's device, protected by the device's own storage encryption. No patient data or video is transmitted over any network at any point. The primary responsibility for securing the device during the recording-to-deletion window — passcode or biometric lock, timely OS updates, physical security — lies with the clinician. We recommend clinicians follow their organisation's device management policies.

7. Children

The Luria Sequencing app is a clinical tool intended for use by trained healthcare professionals. It is not directed at children. We do not knowingly collect personal information from individuals under 18.

8. Changes to this policy

We may update this policy to reflect changes in the app or applicable law. Material changes will be noted on this page with a revised effective date. We encourage clinicians to review this policy periodically.

9. Contact

For privacy-related questions or to exercise your rights under applicable law, please visit our Contact Us page.