Privacy Policy
1. Who we are
PRIMEX ("the Service") is operated by PRIMEX Study Pty Ltd (ABN 44 699 908 506), based in New South Wales, Australia. This policy explains what data we collect, why, and how we handle it. We comply with the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Where you access the Service from outside Australia, additional regional rights may apply (see section 13).
Privacy Officer. Questions, access requests, complaints, and notifications under this policy can be directed to the PRIMEX Privacy Officer at support@primexstudy.com.au.
2. What we collect
Account information: your email address and name when you register. We need this to create your account and send you access codes or subscription confirmations. If you sign in with Apple or Google, we receive your name and email address from that provider.
Study data: answers you write for SAQs, MCQ responses, viva transcripts, flashcard progress, and study plan settings. This data is stored to provide the Service and track your progress.
Payment information: purchases on the website are processed by Stripe, and in-app purchases in the PRIMEX iOS app are processed by Apple through the App Store. We do not store your card number, CVC, or bank details. Stripe's and Apple's privacy policies govern their handling of your payment data. For subscriptions bought in the iOS app, RevenueCat manages your subscription status on our behalf (see section 8).
Usage data: basic analytics such as page views and feature usage to help us improve the Service. We use Plausible (privacy-friendly analytics that runs without third-party cookies) and Google Analytics 4 (uses cookies to measure aggregate site usage and conversions; Google may transfer this data to the United States). We do not use third-party advertising or marketing pixels. Google Analytics 4 purchase events, including renewals that we send from our servers using a pseudonymous identifier derived from your payment-customer record (not your email), may be imported into Google Ads to measure advertising conversions. We also use Vercel Web Analytics and Speed Insights for page-view and performance measurement without advertising cookies.
3. How we use your data
We use your data to provide and improve the Service, send transactional emails (access codes, subscription updates), and generate anonymised, aggregated statistics about exam performance and usage patterns. We do not sell your personal data to anyone.
Advertising audiences (hashed email only). To show PRIMEX ads to existing users and to people with similar interests on Meta platforms (Facebook and Instagram), we may share a one-way hashed (SHA-256) version of your account email address with Meta Platforms, Inc. as a customer-list audience. Meta receives only the hash, matches it against its own users, and cannot recover your email from it. No study data, exam responses, account content or payment information is ever included. We do not do this for accounts on UK exam tracks, and we exclude anyone who has unsubscribed from PRIMEX marketing email. To be excluded at any time, unsubscribe from marketing email using the link in any PRIMEX email, or write to support@primexstudy.com.au. We do not use tracking pixels for this (see section 11).
4. AI processing
Your written answers (including photographs of handwritten answers that you upload), voice transcripts, and Ask-PRIMEX questions are sent to AI language models for grading, feedback and answer generation. We currently use Anthropic's Claude and may use other providers under commercial terms that do not allow training on your data. Under Anthropic's commercial terms it does not use this data to train its models, and it keeps inputs and outputs for a limited period for operation, safety and legal purposes (currently up to 30 days, and longer if content is flagged for a usage-policy violation). PRIMEX itself keeps your answers, transcripts and the feedback you receive as part of your study data (see sections 2, 6 and 9). Grades and ratings are generated automatically for practice only. They are not used to decide your access to any examination, training position or employment.
Live voice sessions. In the Mock Viva and, where enabled, AI patient sessions (see section 5), the spoken conversation is run by ElevenLabs' conversational voice platform: it transcribes your speech and generates the AI examiner's or patient's replies with a language model under ElevenLabs' terms. Where enabled, the session transcript is also analysed after the session for its topics and tone by Google's Gemini model (currently Gemini 2.5 Flash), through ElevenLabs.
Interview practice and your CV. If you save a curriculum vitae or biographical text in Interview practice, it is sent to Anthropic when you ask for a model answer or a CAMP audit of your CV. It is also included, with your typed or transcribed answers, in the context sent to Anthropic when your Interview answers are graded or followed up, so that feedback can refer to your actual experience. To ground feedback in clinical guidance, the question and up to 1,200 characters of your latest answer are also sent to our retrieval service (see section 8). The CV is used as context so the model answer is grounded in your actual experience instead of an invented persona; without it the model answer is framed hypothetically. Anthropic does not train on this input under our commercial API agreement. Your CV is stored with your PRIMEX account so that it syncs across your devices. The generated model answers and CAMP audits are content-addressed cached on Cloudflare R2 so re-listening doesn't trigger a fresh API call; we index these cache entries against your account so that account deletion erases them. Your spoken-answer attempts in Interview practice are not sent to Anthropic for scoring - the engine receives only the typed-or-transcribed text form - and your saved-answer library entries do not include your spoken attempt unless you explicitly opt in by tapping "Save my attempt with this answer".
5. Microphone, voice and audio data
If you choose to use voice dictation in Ask PRIMEX or spoken-response mode in the viva simulator, the Service records short audio clips while you are actively holding the microphone. Audio is sent to Deepgram for transcription (we use Deepgram's Australian endpoint, hosted in Sydney, and ask Deepgram not to use your audio to improve its models). On some browsers and devices, your voice may instead be transcribed by the speech-recognition service built into your browser or device (for example Google in Chrome, or Apple in Safari and on iOS). If so, that provider receives your audio under its own privacy terms and may process it outside Australia. Audio clips are not stored by PRIMEX after transcription is complete. In these modes the microphone permission is only active while you tap the mic button; it is not continuously on. The viva simulator may also synthesise spoken examiner replies using a text-to-speech provider (currently ElevenLabs); the text sent for synthesis is the AI-generated response, not your personal data.
Live AI examiner, AI patient and voice sessions. Some practice modes are live spoken conversations: the Mock Viva (an AI examiner) and, where enabled, AI patient sessions (a simulated patient you take a history from). For the whole session, until you end it, your microphone is open and your microphone audio is streamed to ElevenLabs, which provides the speech recognition, the AI's replies and the AI's voice for the session.
Where an AI patient session shows a video of the patient, the video avatar is produced by Anam. Anam receives only the AI patient's synthesised voice audio, together with your IP address and the device and connection information needed to stream the video to you. Anam never receives your microphone audio.
Since 2 October 2026, Mock Viva sessions have been configured so that ElevenLabs does not keep a recording or transcript of them once the session ends. While a session is running, ElevenLabs and the AI model providers it uses process your audio and text, and ElevenLabs may keep limited technical and billing records (such as session length and usage). Mock Viva sessions before 2 October 2026 were recorded and kept by ElevenLabs; we are deleting those recordings and transcripts. When you complete a spoken practice session (for example a Mock Viva, hot case or OSCE), PRIMEX stores a transcript of that session with your account so it can show you feedback and history. These transcripts are kept until you delete your account (see sections 2 and 9). AI patient sessions are not yet generally available; when they are, ElevenLabs will keep their transcripts for 7 days and then delete them (see section 9).
PRIMEX does not perform voiceprint or facial analysis, and does not use your voice or image to identify you.
6. Community features
Study groups. You can create or join a private study group using an invite code. Other members of that group can see your display handle, your study statistics (such as your SAQ, MCQ and viva counts, your highest tier, and your last-active date), and any messages you post in the group chat. Your name and email address are never shown to other members. You can leave a study group at any time.
Question discussions. On practice questions you can post comments that are visible to other users preparing for the same exam. You post under a display handle of your choosing, or anonymously. Comments are checked by an automated moderation step and may be reviewed or removed by our moderators. Your name and email address are never shown.
Live peer practice. Viva Exchange and OSCE Hot Case Exchange let you book and run live practice sessions with another trainee. During a session your audio, and video if you turn on your camera, are streamed in real time to the other participant through our realtime infrastructure provider (LiveKit). After a session, you and your practice partner can each submit a rubric mark and written feedback on the other's performance, which is visible to the person it is about. In an OSCE Hot Case session, the host can choose to record the session audio so the participants can review it afterwards. When recording is enabled, an audio-only recording is stored in cloud storage and is available to the people who took part in that session. You can ask us to delete a recording at any time.
Cohort activity. Your study activity contributes to anonymised, aggregated statistics shown to other users preparing for the same exam, such as recent activity counts and the most-discussed questions. Individual users are not identified in these aggregates.
Saved answers and Interview session history. When you save a model answer in Interview practice, or complete an Interview practice session, those records are synced to your PRIMEX account so they appear across the devices you sign in on. They sit in your account's private partition and are not shown to other users, not surfaced in community features, and not used to train AI models. They are deleted when you delete your account. Your curriculum-vitae text is part of your account data and syncs in the same way (see section 4). By default, Interview practice also keeps a full copy of each session transcript in your account until your account is deleted.
Content you post in study groups or question discussions is stored on our servers so it can be shown to other members. You can ask us to remove community content you have posted at any time.
7. Push notifications (mobile app)
The PRIMEX iOS and Android apps may send you push notifications for flashcard review reminders, new features, or subscription updates if you opt in during first-run setup. Notification preferences can be changed at any time from the device Settings app or from PRIMEX account settings. Push tokens are stored only to deliver notifications to your device. Notifications are routed through Apple Push Notification service (iOS) and Google Firebase Cloud Messaging (Android); these providers receive the device token and the notification payload to deliver the message.
8. Data storage and overseas disclosure (APP 8)
Our serverless functions run in Sydney, Australia (Vercel), and our main relational database is hosted in Sydney, Australia (Neon). Static pages and files are delivered through Vercel's global network. Some of your data is held overseas: our key-value database (Upstash), which holds account records, study-progress sync data and some practice history, has its primary write location in the United States, and the other providers listed below hold or process data in the countries shown against each. Overseas providers may also be able to access data from outside Australia for support and security purposes.
Before disclosing personal information overseas, we take reasonable steps to ensure each recipient handles your data consistently with the Australian Privacy Principles, including by relying on the recipient's published data-protection commitments, contractual terms accepted as part of using each service, and (where offered) standard contractual clauses or equivalent transfer mechanisms.
We use the following third-party processors to deliver the Service. Each is bound by its own privacy and data-processing terms.
- Anthropic (United States) - AI language model provider (grading, viva, Ask PRIMEX). No-training commercial API agreement. Inputs are processed in real time and are not used to train Anthropic's models.
- Vercel (United States company; our functions run in Sydney, Australia) - application hosting and serverless functions, plus Vercel Web Analytics and Speed Insights (page-view and performance measurement without advertising cookies).
- Upstash (United States) - managed Redis key-value database (previously described as "Vercel KV"). Holds account records, study-progress sync data and some practice history. Primary write location: United States.
- Neon (United States company; our database is hosted in Sydney, Australia) - PostgreSQL database for community features, practice attempts and some account data.
- LiveKit (United States, with regional edge nodes in the European Union, United Kingdom, and Asia-Pacific) - realtime audio and video infrastructure for live peer practice sessions (Viva Exchange and OSCE Hot Case Exchange).
- Cloudflare R2 (Cloudflare's global network, which may include Australia, the United States and other countries) - storage for opt-in audio recordings of OSCE Hot Case practice sessions.
- Stripe (United States, Australia) - payment processing for purchases on the website. Card details go directly to Stripe; we never receive or store them.
- Apple App Store (Apple Inc., United States) - processes in-app subscription purchases made in the PRIMEX iOS app. Apple handles your payment details; we never receive them.
- RevenueCat (United States) - manages App Store subscriptions and access for the PRIMEX iOS app. It receives an anonymous account identifier (purchases made before October 2026 may still be recorded under the email address you used then), your purchase and subscription status, and device and transaction metadata from the App Store.
- ChartMogul (Germany; data hosted in the European Union - Ireland) - subscription analytics. It receives the name, email address and billing history of customers who pay through Stripe. It receives no study data, and no personal information about App Store subscribers.
- Resend (United States) - transactional email delivery (access codes, subscription confirmations, account emails).
- Deepgram (United States company; we use its Australian endpoint, hosted in Sydney, Australia) - speech-to-text transcription of viva and Ask-PRIMEX voice clips.
- ElevenLabs (United States) - realtime voice agent for the Mock Viva and, where enabled, AI patient sessions: it receives your microphone audio during a session for speech recognition, the AI's replies and the AI's voice. Also text-to-speech for spoken examiner replies in the viva simulator. Mock Viva sessions since 2 October 2026 are configured not to be retained by ElevenLabs; where enabled, AI patient session transcripts are kept for 7 days.
- Anam (United Kingdom; hosting in the European Union and the United States) - video avatar for AI patient sessions, where enabled. It receives the AI patient's synthesised voice audio plus your IP address and device and connection information. It never receives your microphone audio.
- Google (Gemini, accessed through ElevenLabs; United States) - where enabled, analyses session transcripts after the session (topics and tone).
- Plausible (European Union - Germany) - privacy-friendly analytics (page views and feature usage; runs without third-party cookies).
- Google Analytics 4 (Google LLC) (United States, with global processing) - measurement of aggregate site usage, conversions, and feature engagement. Uses cookies.
- Meta Platforms, Inc. (United States, with global processing) - customer-list advertising audiences built from one-way hashed email addresses only (see section 3). No pixel, no study data, and no plain-text identifiers are shared.
- Sentry (United States and other countries) - application error monitoring. Receives stack traces, device and browser details, an opaque account identifier and, when an error occurs, a recording of screen activity with all text and form inputs masked.
- PRIMEX retrieval service (hosted with Railway, United States and other countries; Cloudflare Workers and R2 fallback) - keeps AI answers aligned with current clinical guidelines. Receives the text of the question you are working on and, in Interview practice, up to 1,200 characters of your latest answer, but not your account identity.
- Google (Gmail and Google Workspace; United States and other countries) - receives emails you send to PRIMEX support and any feedback report you choose to send us.
- Apple and Google sign-in (United States) - if you sign in with Apple or Google, we receive your name and email address (or Apple's private relay address).
- Apple Push Notification service (Apple Inc., United States) and Google Firebase Cloud Messaging (Google LLC, United States) - delivery of mobile push notifications.
9. Data retention
We retain your account and study data for as long as your account is active. If you cancel your subscription, your data is kept for 12 months in case you return, then deleted. You can request earlier deletion at any time.
Retention by our providers. This is separate from the account retention above. Since 2 October 2026 ElevenLabs keeps no recording or transcript of Mock Viva sessions (earlier recordings are being deleted). Where AI patient sessions are enabled, ElevenLabs keeps their transcripts for 7 days and then deletes them. Our other providers hold data under their own data-processing terms (see section 8).
10. Your rights and account deletion
Under the Australian Privacy Act 1988, you have the right to access the personal information we hold about you (APP 12), request correction of inaccurate information (APP 13), make an anonymous or pseudonymous enquiry where practicable (APP 2), and ask us how we handle your information. You can also export your study data and request deletion of your account and all associated data.
In the PRIMEX mobile apps, account deletion is available from Settings → Account → Delete Account. On the web, account deletion is available from the Account page and takes effect immediately. If you cannot sign in, email support@primexstudy.com.au and we will action the request within 7 business days.
How to complain. If you believe we have mishandled your personal information, please email support@primexstudy.com.au so we can investigate. We will respond within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or by calling 1300 363 992.
Notifiable data breaches. We comply with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act. If we become aware of an eligible data breach that is likely to result in serious harm to individuals whose personal information is involved, we will notify those individuals and the OAIC as soon as practicable.
11. Cookies
We use a small number of cookies and similar identifiers on the website:
- Strictly necessary: a session cookie to keep you signed in.
- Analytics (Plausible): aggregated, privacy-friendly site usage. No third-party cookies.
- Analytics (Google Analytics 4): measurement of aggregate site usage, conversions, and feature engagement.
We do not use advertising or marketing pixels. Google Analytics 4 purchase events, including renewals that we send from our servers using a pseudonymous identifier derived from your payment-customer record (not your email), may be imported into Google Ads to measure advertising conversions. We also use Vercel Web Analytics and Speed Insights for page-view and performance measurement without advertising cookies. To opt out of Google Analytics across all sites, you can install Google's official browser opt-out add-on or enable "Do Not Track" / "Global Privacy Control" in your browser. The PRIMEX iOS and Android apps do not use advertising SDKs or third-party tracking identifiers.
12. Children
The Service is intended for users aged 18 and over (medical trainees and medical students), and you must confirm you are 18 or older to create an account. We do not knowingly collect personal information from anyone under 18. If you become aware that someone under 18 has provided personal information to us, please contact us at support@primexstudy.com.au so we can delete it.
13. International users
PRIMEX is designed for Australia and New Zealand. International Medical Graduates and other users may access the Service from outside Australasia. Depending on where you are located, additional data-protection law may apply. We address this on a good-faith basis as follows:
- European Economic Area and United Kingdom (GDPR / UK GDPR). Our lawful bases for processing are: performance of a contract with you (delivering the Service); your consent (community features and push notifications); and our legitimate interests in operating, securing, and improving the Service. You have rights to access, rectification, erasure, restriction, portability, and objection, and the right to lodge a complaint with your national supervisory authority. To exercise these rights, email support@primexstudy.com.au. PRIMEX has not appointed an EU representative at this time; if you are in the EU or UK and need to escalate, please contact us first.
- India (Digital Personal Data Protection Act 2023). If you are accessing the Service from India, you may exercise the rights of access, correction, erasure, grievance redressal, and consent withdrawal by emailing support@primexstudy.com.au.
- Other jurisdictions. Where local law gives you rights additional to those in this policy, we will give effect to those rights to the extent we are legally required to. Contact us with the details of your request.
Note that parts of the Service are hosted in Australia and parts overseas, mainly in the United States. Wherever you use the Service from, your personal information is processed in those places. See section 8 for the list of overseas recipients and the countries in which they are located.
14. Changes
If we make material changes to this policy, we will notify you by email at least 14 days before the changes take effect. The "last updated" date at the top of the page reflects the most recent revision.
15. Contact
Questions about privacy, or to make a request under Australia's Privacy Act 1988, the GDPR, or any other applicable data-protection law? Email the PRIMEX Privacy Officer at support@primexstudy.com.au.