Privacy Policy

We are the controller of your personal data. For more information on controllers and their responsibilities please see our guidance on data protection principles, definitions, and key terms. This privacy notice tells you what to expect us to do with your personal information.

What information we collect, use, and why

We collect or use the following personal information to provide our services to you:

• Names and contact details
• Payment details
• Account information
• Information used for security purposes
• Marketing preferences

We also collect the following special category information. This information is subject to additional protection due to its sensitive nature:

• Health information

Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access. You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
• Your right to rectification. You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
• Your right to erasure. You have the right to ask us to delete your personal information. Read more about the right to erasure.
• Your right to restriction of processing. You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
• Your right to object to processing. You have the right to object to the processing of your personal data. Read more about the right to object to processing.
• Your right to data portability. You have the right to ask that we transfer the personal information you gave us to another organization, or to you. Read more about the right to data portability.
• Your right to withdraw consent. When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, contact us.

California Consumer Privacy Act

This Privacy Notice supplements the Privacy Policy and applies solely to California consumers. Any terms defined in the California Consumer Privacy Act of 2018 (“CCPA”) have the same meaning when used in this Privacy Notice.

Sharing personal information

We have not disclosed consumer personal information in the past twelve months.

Sale of personal information

We have not sold consumer personal information in the past twelve months.

Your rights and choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how you can exercise those rights.

You have the right to request that we disclose to you certain information about our collection and use of your personal information in the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources from which we collected personal information about you.
• Our business or commercial purpose for collecting or selling personal information.
• The categories of third parties with whom we share personal information.
• The specific pieces of personal information we have collected about you (also called a data portability request).

Deletion request rights

You have the right to request that we delete any of your personal information that we collected and retained, subject to certain exceptions. Once we have received and confirmed your verifiable consumer request, we will delete, and direct any of our service providers to delete, your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when deletion of the information is likely to render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

NHS Care Identity Service 2

Please note that if you access our service using your NHS Care Identity credentials, the identity access and management services are managed by NHS England. NHS England is the controller for any personal information you provided to NHS England to get a national digital identity and authenticate your claim to that identity, and uses that personal information solely for that single purpose. For any personal information, our role is a “processor” only and we must act under the instructions provided by NHS England (as the “controller”) when verifying your identity. To see NHS England’s Privacy Notice and Terms and Conditions, view the NHS Care Identity Service 2 page. This restriction does not apply to the personal information you provide to us separately which is managed in accordance with our Privacy Policy.