Introduction 

Vital Flow Health Limited (“VFH”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you access any of our services, and tell you about your privacy rights and how the law protects you. The policy also applies when you visit our website, correspond with us in person, by letter, by phone, email or any other means. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. 

Vital Flow Health Limited a company limited by shares registered in England and Wales under company number 15727765 whose registered office address is Suite 6, Floor 2 Congress House, 14 Lyon Road, Harrow HA1 2EN (collectively referred to as VFH, we, us or our in this privacy policy) is the data controller and responsible for your personal data, if you register with us to access any of our services following an invitation from us or your employer then we may also act as a data processor in connection with the delivery of our services to you and or on behalf of your employer 

We are registered with the Information Commissioners Office (ICO) under registration number ZB773676 and you can view more information about our registration online by following the link here. 

About this Policy 

This Privacy Policy sets out how Vital Flow Health Limited ("we", "our", "us") handle the Personal Data of our customers, suppliers, employees, workers and other third parties. 

This policy applies to all Personal Data we Process regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject. 

This policy applies to all Vital Flow Health Limited team members ("you", "your"). You must read, understand and comply with this policy when Processing Personal Data on our behalf and attend training on its requirements. It sets out what we expect from you for Vital Flow Health Limited to comply with applicable law. 

Your compliance with this policy is mandatory. Related Policies and Privacy Guidelines are available to help you interpret and act in accordance with this policy. Any breach of this policy may result in disciplinary action. 

Where you have a specific responsibility in connection with Processing such as capturing Consent, reporting a Personal Data Breach, conducting a Data Protection Impact Assessment (DPIA) as referenced in this policy or otherwise then you must comply with the Related Policies and Privacy Guidelines. 

Scope of The Policy  

This privacy policy gives you information about how VFH collects and uses your personal data belonging to you or your personnel in the context of providing healthcare services to you or your business through any of the other ways we interact, as set out in more detail in paragraph 3 below.  

This policy is updated from time to time. The latest version updated on December 2024 is published and is available from our website. This policy has been updated to reflect the changes introduced by the Data Protection Act 2018 (“DPA”) and the General Data Protection Regulation (“GDPR”). 

In this Privacy Policy we seek to abide by the letter and spirit of the guidelines laid out by the ICO on their webpage on the ‘Right to be Informed’. 

If you wish to report any knowledge of a child contacting us and providing personal data without parental consent, please notify us at info@vitalflow-health.com and we will then delete the applicable personal data. If we become aware of a child contacting us, we will also delete the applicable personal data. 

Controller 

The Controller of your personal data is Vital Flow Health Limited. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (Paragraph 10), contact the DPO using the information set out in the contact details section.  

The Personal Data We Collect About You 

Except as described below in this privacy policy, we will be the controller and responsible for your personal data. Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). When you visit our website, correspond with us in person or by phone, e-mail or otherwise, you may give us information that would be classed as personal data about you and others you are acting on behalf of. The information we collect from you will be dependent on your relationship with VFH and whether you are an organisation, medical practitioner, carer or end user of our services. 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: 

• Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender. 
• Contact Data includes billing address, delivery address, email address and telephone numbers. 
• Health Data which includes any information about your health including your medical history and/or current health status including but not limited to data regarding exercises, patient reported outcomes, diary results, flares or episodes or other symptoms, test results, diagnoses and medications. 
• Financial Data includes bank account and payment card details. 
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us. 
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.  
• Profile Data includes your username and password, preferences, feedback and survey responses.   
• Usage Data includes information about how you interact with and use our website and services.  
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 

As a data controller, we may collect Special Categories of Personal Data (as defined in the GDPR) about you. This may include details about your health, race or ethnicity, religious or philosophical beliefs, sex life or sexual orientation. As controller, we may collect personal data about your health including your medical history and/or current health status including but not limited to data regarding exercises, patient reported outcomes, diary results, flares or episodes or other symptoms, test results, diagnoses and medications. In addition, we may collect and process such of your personal data submitted by you (“Patient Data”) as a processor.  

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering. 

Where we need to collect personal data by law, or under the terms of a contract we have with you or your employer and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have asked us to provide but we will notify you if this is the case. 

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us. We will only retain Personal Data to the extent necessary to enable us to provide our services to you.   

How Is Your Personal Data Collected? 

We use different methods to collect data from and about you including: 

Direct interactions: You may give us any of the categories of data identified above by filling in forms on our website, by corresponding with us, meeting with us in person or by phone, e-mail or otherwise. This includes personal data you provide when you: 

• Register to use our services; 
• Access our services; 
• Request marketing or other communications to be sent to you; 
• Give us feedback. 

Medical Practitioners: During the delivery of services it may be appropriate for you and/or us to communicate with Medical Practitioners and we may receive personal data and Special Categories of Personal Data from them or you whilst we deliver our services to you. You explicitly consent to the processing of this personal data and Special Categories of Personal Data as part of your use of our services and in accordance with this Privacy Policy. We may also process this Personal Data as a processor for your employer, as described in our contract with them, although it would never be shared with them. 

Employers: During the delivery of services it may be appropriate for you and/or us to communicate with your employer and we may receive personal data and Special Categories of Personal Data from them or you whilst we deliver our services to you. You explicitly consent to the processing of this personal data and Special Categories of Personal Data as part of your use of our services and in accordance with this Privacy Policy. We may also process this Personal Data as a processor for your employer, as described in our contract with them, although it would never be shared with them. 

Academic and Research Organisations: If your use of our services requires the involvement of academic or research organisations then we may receive personal data and Special Categories of Personal Data from them whilst they help you to monitor your health condition. You explicitly consent to the processing of this personal data and Special Categories of Personal Data as part of your use of the Platform and in accordance with this Privacy Policy. We may also process this Personal Data as a processor for your employer, as described in our contract with them, although it would never be shared with them. 

Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources such as analytics providers, advertising networks and/or search information providers based inside the EEA.  

Contact, Financial and Transaction Data (if applicable): We may receive this information from providers of technical, payment and delivery services inside the EEA required for the provision of our Services. 

How We Use Your Personal Data 

We process personal data in accordance with our Data Processing Impact Assessment (“DPIA”), which is a set of tools and assessments used to identify and reduce risks of a data processing activity. The DPIA is a description of the processing, its purpose and our legitimate interests if appropriate, which assesses the necessity and proportionality of processing in relation to its purposes and the risk to individuals, along with the risk mitigation measures in place and demonstration of compliance. Our DPIA (redacted to remove any commercially sensitive information) is available on request. 

Legal basis 

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases: 

• Performance of a contract with you: The processing is necessary for a contract we are about to enter into or have entered into with you (for example, to process and deliver our services to you and to manage our relationship with you), or because you have asked us to take specific steps before entering into a contract. 
• Legitimate interests: Where it is necessary for our legitimate interests as a health care services provider (or those of a third party) and your interests and fundamental rights do not override those interests. These legitimate interests include our interests in managing our relationship with our clients and service users, prospective clients and service users, attending to clients and service users at their offices and/or place of work, hosting virtual and in-person events and ensuring appropriate standards and compliance with policies, practices or procedures. 
• Legal obligation: Where we need to comply with a legal obligation to which we are subject. 
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example via our patient consent forms or if you subscribe to an [email newsletter]. 
• Vital interests:  the processing is necessary to protect someone’s life. 
• Healthcare provision: the processing of data is necessary for the purposes of preventative or occupational medicine, medical diagnosis, provision of health or social care treatment. This includes where it is necessary for us to deliver our services to you and to allow access to the features of our services and to keep you in contact with you, your medical practitioner, carer or other authorised third-parties (where applicable). 

To find out more about the types of lawful basis that we will rely on to process your personal data on the ICO website please follow the link here.  

Direct marketing  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising  

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing. 

Third-party marketing  

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.  

Opting out of marketing 

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time on info@vitalflow-health.com  

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes (for example relating to order confirmations for a service, appointment reminders, checking that your contact details are correct). 

Cookies 

We do use Cookies on our website. However, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see are cookie policy page. 

Sharing Your Personal Data with Third Parties 

We may have to share your personal data with the parties below in order to provide our services to you. We require all third parties to respect the security of your personal data and to treat it in accordance with the law, and when they are processing personal data on our behalf we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and in accordance with the law. Examples of our third parties include:  

• Medical device regulators (e.g. the Medicines and Healthcare products Regulatory Agency in the UK) in the performance of their powers and obligations under applicable medical devices legislation the Medical Devices Directive 93/42/EC (whilst still in force) and the Medical Devices Regulation (EU) 2017/745 (when in force); 
• Sub-contractors for the performance of any contract we enter into with them or you, including but not limited to pathology laboratories appointed to analyse your health data; 
• Service providers acting as processors who provide IT and system administration services. 
• Medical Practitioners to allow them to deliver their medical services to you; 
• (where applicable) academic and research organisations to allow them to help you manage and/or monitor your health condition; 
• (where applicable) to other third-parties that you authorise to help manage and/or monitor your health condition; and 
• Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services. 
• If you are using our services within the United Kingdom or the European Economic Area (EEA) then we do not transfer your personal data outside the EEA. Visitors from outside this jurisdiction will involve transfers outside the EEA. 

International Transfers 

We do not transfer your personal data outside the UK. 

Data Security 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.  

Data Retention 

How long will you use my personal data for? 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. 

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. 

Patient data will be retained by VFH for a period of 7 years. This data is used to provide information on the level of compliance with our services.  

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.  

Following the expiration of the retention period, your personal data will be destroyed. In relation to hard copy data, this shall be conducted by shredding. All electronic data (including any and all backups thereof) will be deleted. 

Your Legal Rights 

You have rights under data protection laws in relation to your personal data to:  

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. 
• Absolute right to object any time to the processing of your personal data for direct marketing purposes.  
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios: 

• If you want us to establish the data's accuracy; 
• Where our use of the data is unlawful but you do not want us to erase it; 
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or 
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

If you wish to exercise any of the rights set out above, please see our Contact details. 

No Fee Usually Required 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. 

What We May Need from You 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

Time Limit to Respond 

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.  

Contact Details 

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways: 

Full name of legal entity: Vital Flow Health Limited 

Email address: info@vitalflowhealth.com 

Postal address: Suite 6, Floor 2 Congress House, 14 Lyon Road, Harrow, United Kingdom, HA1 2EN 

Complaints     

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.