Privacy Policy

1. Who we are

CHM Solutions Pty Ltd ("we", "us", "our") develops and publishes the Contrast Sensitivity iPadOS application, shown in-app as part of the Neuro Tools suite by Clear Health Media. For privacy enquiries, visit our Contact Us page.

2. Who this policy applies to

This policy applies to persons ("users") who use the Contrast Sensitivity application to administer a standardised contrast sensitivity test to a participant. The user operates the iPad; the participant is the individual being tested and the subject of the data described below. The application is not intended for unsupervised use by participants. Users are responsible for ensuring their own use of the application complies with all applicable laws and professional obligations in their jurisdiction, including participant consent requirements.

3. What data the application processes

3.1 Patient identifiers

The application does not request a name, date of birth, medical record number, or any other patient identifier. It also does not request or record the participant's age. This is a deliberate design decision, as the application does not perform any age-based interpretation of the result.

3.2 Test trial data

For each stimulus shown during practice and the scored test, the application records the contrast level, the edge orientation shown, the orientation selected, whether the response was correct, the response time, and a timestamp. Practice responses are recorded separately and are flagged as practice; they do not contribute to the reported result. This data exists only in the application's working memory, for the duration required to compute and display the result.

• Trial data is not written to a file, a database, or any other persistent storage on the device, and it does not leave the device.
• A result and its trial-level detail can be viewed only while the corresponding Result screen is displayed.
• Repeating the test, selecting "Done," or otherwise navigating away from the Result screen discards the result and all associated trial data immediately and irreversibly. There is no stored data to delete, as none is retained.

3.3 Device and session metadata

While a result is displayed, the application also holds technical metadata alongside it, comprising the device model identifier, iPadOS version, screen resolution and scale, the display-calibration profile used, the screen brightness used during the test, and a protocol version identifier. This metadata is intended to keep a result interpretable and comparable over time as the application or its calibration is refined. It is not shown to the participant or user on the Result screen and, like the trial data described above, is held only in memory and is not written to disk.

3.4 Display brightness

Immediately before practice and testing, the application reads the iPad's current screen brightness, temporarily sets a standardised test brightness, and disables screen auto-dimming for the duration of the test. The original brightness is restored automatically when the test ends, is cancelled, or is interrupted (for example, if the application is backgrounded). This value is a display characteristic of the iPad itself, not a personal setting tied to an individual, and reading or adjusting it does not require an iOS permission prompt.

3.5 Data not collected

The application does not collect, transmit, or store:

• Patient names, identifiers, or age
• Any video, audio, or location data
• Any usage analytics, advertising, or third-party tracking data. The application has no analytics SDK and makes no network connections.

4. Permissions requested

The application requests no permissions. It does not request the camera, microphone, location, contacts, photo library, notifications, or any other iOS permission. Camera-based or other automated measurement of viewing distance is not used; the 40 cm distance is a written instruction to the user, not something the application measures.

5. What the application does not do

• Does not create user accounts or require sign-in.
• Does not transmit any data to a server. There is currently no cloud synchronisation, upload, or export feature of any kind.
• Does not store test results. A result exists only on screen, in the application's working memory, while the Result screen is displayed. When the user selects "Repeat Test" or "Done," or otherwise leaves the Result screen, the result and all associated trial data are discarded. No data is written to a file or database at any point.
• Does not use analytics, advertising, or third-party tracking software.
• Does not share, sell, or otherwise disclose any data to third parties, as no data leaves the device.
• Does not generate a diagnosis, a normal or abnormal label, a percentile, or a falls-risk classification from the result. The application presents an objective dB score and, separately, a published reference chart for context; a qualified user makes any comparison or interpretation.

6. Clinical and regulatory context

6.1 HIPAA (United States)

The Contrast Sensitivity application does not receive, create, maintain, or transmit electronic protected health information (ePHI) on behalf of any covered entity or business associate. All test administration and scoring take place locally on the user's iPad, entirely in memory, and no data is sent to CHM Solutions Pty Ltd. Because the application does not transmit data off-device, and does not write data to disk, no Business Associate Agreement with CHM Solutions Pty Ltd is required for use of the application. Users remain responsible for how they record results outside the application, under their own HIPAA obligations.

6.2 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). Trial data and device metadata are captured and processed entirely in memory on the user's iPad, are discarded when the Result screen is left, and are never collected or received by CHM Solutions Pty Ltd. Accordingly, most APPs are not engaged in ordinary use of the application by us. The user remains responsible, as the party viewing the data while it is displayed, for handling it in line with their own APP obligations. Any personal information provided to us directly, for example via support requests, is handled in accordance with the APPs and used only to respond to the relevant enquiry.

6.3 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 sent to us directly (for example, support messages). We do not act as controller or processor for any trial data or result created within the application, as this data is never transmitted to us.
• Processors: The application uses no third-party analytics or data processors.
• Legal basis: Legitimate interests or contract performance, for support communications only.
• Data subject 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: Trial data may briefly constitute special category (health-related) data while it is displayed, held in the application's working memory. Because this data is not written to disk, is not transmitted, and is not held by CHM Solutions Pty Ltd, we do not process it as controller or processor under the GDPR. The user, as the party administering and viewing the test, is responsible for its handling under the GDPR during that period.
• International transfers: No trial data leaves the user's device, so no international transfer occurs in respect of that data. Where we receive personal data from EEA contacts directly, for example support enquiries, we rely on standard contractual clauses or consent as our transfer mechanism.

6.4 Not a certified medical device

Contrast Sensitivity is positioned as a physiological, falls-risk-relevant assessment tool for use by a qualified user. It is not a certified medical device and is not an optometry or ophthalmology diagnostic product. The published reference chart shown alongside the result reflects a research study's own testing conditions, which differ from this application's conditions in some respects, for example the stopping rule and calibration approach. The application does not claim its test conditions are identical to that study.

7. Data retention

The application does not retain test results in any form after the user leaves the Result screen. No local file storage, database, or cache of past results exists to delete, back up, or export, as none is created. A result and its trial-level detail can be viewed only while the corresponding Result screen is displayed; repeating the test, selecting "Done," or otherwise navigating away discards the result immediately and irreversibly. Because no data is written to disk, there is no data for the uninstallation of the application to remove, and no data that could appear in a device backup. Any personal data submitted to us through customer support is retained only for as long as necessary to resolve the enquiry, and for no longer than three years.

8. Security

All test administration takes place entirely on the user's iPad, in memory only, and no trial or result data is transmitted over any network at any point or written to disk. Primary responsibility for securing the device, including passcode or biometric lock, timely iPadOS updates, and physical security, lies with the user. We recommend users follow their organisation's device management policies.

9. Future changes to this application

A future version of the application may allow results to be uploaded to a companion NeuroTools web portal, for users who elect to use it. This capability is not implemented as at the effective date of this policy; the application currently has no mechanism for retaining results, and accordingly no data exists to export or upload. Introducing this capability would require adding a data retention mechanism that does not currently exist. We will update this policy in advance of any such change and will describe what data would be retained, what would be transmitted, to whom, and how users may opt in or out.

10. Children

The Contrast Sensitivity app is a clinical tool intended for use by trained users. It is not directed at children. We do not knowingly collect personal information from individuals under 18.

11. 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 users to review this policy periodically.

12. Contact

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