Privacy Policy

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 controller of your personal data where we decide how and why your personal data is processed, including where we provide services directly to you or manage our own business operations.

In some cases, we may provide services on behalf of an employer, partner organisation, practitioner, or research body. In those cases, that organisation may be the controller and Vital Flow Health Ltd may process personal data on its behalf. Where this applies, you may also be given privacy information by that organisation.

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 explains how Vital Flow Health Ltd collects, uses, stores, and shares personal data when providing its services, including services provided directly to individuals and services arranged through employers or partner organisations. It also explains your rights in relation to your personal data. 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 applies to personal data processed by Vital Flow Health Ltd in relation to:

1. Individuals who enquire about or use our services
2. Individuals who participate in employer-arranged health services
3. Medical or clinical practitioners involved in delivering services
4. Business contacts, suppliers and partner organisations
5. Users of our website and online services.
   

Some of our services are arranged by employers or partner organisations. Where this applies, individuals may choose to participate and provide their personal data through registration forms, questionnaires, bookings, appointments, and related health service processes. 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 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’.

Our services are not generally directed at children. Where we process children’s personal data, we will do so in accordance with applicable data protection law and any relevant consent or parental responsibility requirements. 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 the following categories of personal data, depending on the service being provided:

• Identity and contact Data such as your name, date of birth, address, email address, and telephone number.  This could include first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
• 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.
• Service and Financial Data includes bank account and payment card details, booking details, appointment information, practitioner notes, and communications about the service.
• Technical & Usage 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. how you interact with and use our website and services.
• Profile Data includes your username, preferences, feedback and survey responses. 
• 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. 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 collect personal data:

1. Directly from you, including when you complete forms, book appointments, correspond with us, or participate in a health service
2. From employers or partner organisations, where they arrange access to our services
3. From practitioners, laboratories, or service delivery partners involved in providing the service to you
4. Automatically through our website and digital systems, including through cookies and technical logs where applicable.
   

How We Use Your Personal Data

We use your personal data for the purposes set out below. Where we process special category personal data, including health data, we identify the relevant lawful basis and special category condition that applies.

Legal basis

The law requires us to have a valid legal basis for collecting and using your personal data. As a healthcare provider, we rely on different lawful bases depending on the nature of the processing activity.

Article 6 – Lawful Bases for Processing Personal Data

We rely on one or more of the following:

• Performance of a contract (Article 6(1)(b))
   Where processing is necessary to provide our services to you, including managing appointments, delivering treatment, and communicating with you in relation to your care. 
• Legal obligation (Article 6(1)(c))
   Where we are required to process your data to comply with legal or regulatory requirements (for example, clinical governance, safeguarding, or record-keeping obligations). 
• Legitimate interests (Article 6(1)(f))
   Where processing is necessary for our legitimate interests as a healthcare provider, such as managing our services, improving service delivery, maintaining records, and ensuring appropriate standards of care, provided your rights do not override those interests. 
• Vital interests (Article 6(1)(d))
   Where processing is necessary to protect your life or the life of another individual in an emergency. 
• Consent (Article 6(1)(a))
   We rely on consent only where you have given clear, specific agreement for a particular purpose, such as receiving marketing communications or where we ask permission to use your data in a way that is not essential to delivering your care. 

Article 9 – Processing of Health (Special Category) Data

Health data is classified as special category data and requires an additional condition under Article 9 UK GDPR.

We process your health data under the following conditions:

• Provision of health or social care (Article 9(2)(h))
   Processing is necessary for medical diagnosis, the provision of healthcare treatment, and the management of healthcare systems and services. 
• Employment and social protection law (Article 9(2)(b))
   Where relevant, for example in occupational health or workplace-related services. 
• Substantial public interest (Article 9(2)(g))
   Where required for safeguarding or regulatory purposes. 
• Explicit consent (Article 9(2)(a))
   We rely on explicit consent only in limited situations where it is appropriate, such as where you have agreed to specific types of data sharing that are not essential to your care.

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. https://ico.org.uk/

Category of Personal Data	Purpose of Processing	Article 6 Lawful Basis	Article 9 Condition (where applicable)	Recipients / Sharing	Retention Period / Criteria
Identity Data(name, DOB, identifiers)	To register you as a service user, verify identity, and manage your care	Art. 6(1)(b) – Contract; Art. 6(1)(c) – Legal obligation	N/A	Internal staff, clinicians	Retained in line with patient record retention (e.g. 8 years or as required)
Contact Data(address, email, phone)	To communicate with you regarding appointments, results, and services	Art. 6(1)(b) – Contract	N/A	Internal staff, communication providers	Retained in line with patient record retention
Health Data(medical history, symptoms, test results, diagnoses, treatment records)	To assess suitability, provide healthcare services (including blood testing), monitor health, communicate results, and maintain clinical records	Art. 6(1)(b) – Contract; Art. 6(1)(c) – Legal obligation	Art. 9(2)(h) – Provision of healthcare; Art. 9(2)(a) – Explicit consent (only where required for specific additional uses)	Clinicians, laboratories, healthcare providers, relevant third parties involved in care	Retained in line with healthcare regulations (e.g. 8 years or longer where required)
Financial Data(payment details)	To process payments for services	Art. 6(1)(b) – Contract; Art. 6(1)(c) – Legal obligation	N/A	Payment processors, finance systems	6 years for financial records (legal requirement)
Transaction Data(services purchased, payment history)	To manage services provided and maintain financial records	Art. 6(1)(b) – Contract; Art. 6(1)(c) – Legal obligation		Finance systems, auditors, HMRC (if required)	6 years (legal requirement)
Technical Data (IP address, device info, login data)	To ensure system security, maintain service functionality, and improve services	Art. 6(1)(f) – Legitimate interests	N/A	IT providers, analytics services	Typically 6–12 months unless required for investigation
Profile Data(preferences, feedback, account details)	To manage your account, improve services, and personalise user experience	Art. 6(1)(b) – Contract; Art. 6(1)(f) – Legitimate interests	N/A	Internal systems, service providers	Retained for duration of relationship + standard retention period

We process technical and usage data to administer our website, maintain security, troubleshoot issues, and understand how our services are used.

Direct marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.  We may send you information about our services where you have asked to receive it, where you have consented to receive it, or where we are otherwise permitted to do so under applicable law. You can opt out of marketing communications at any time by using the unsubscribe link in our emails or by contacting us directly.

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

Our website uses cookies and similar technologies. For more information about the cookies we use and how to manage your preferences, please see our Cookie Policy. 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 our cookie policy page.

Sharing Your Personal Data with Third Parties

We may share personal data, where necessary, with:

1. Laboratories, clinicians, and other service delivery partners involved in providing health services
2. IT, hosting, software, and administrative service providers\
3. Professional advisers, insurers, auditors, and regulators
4. Employers or partner organisations where they arrange services, to the extent explained to you and permitted by law
5. Public authorities, regulators, courts, or law enforcement bodies where disclosure is legally required.

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.

Employer-Arranged Services

Some services are arranged by employers or partner organisations. In these cases, Vital Flow Health Ltd may receive your personal data in order to register you for the service, arrange appointments, deliver the service, and report outcomes as explained to you at the time. 
The extent of any information shared with the employer or partner organisation will depend on the nature of the service and the arrangements in place.

Sharing with Employers

Where a service is arranged by your employer, we may share limited administrative information, such as booking status, attendance, or service uptake, where necessary for managing the service. We may provide employers or partner organisations with anonymised or aggregated reporting about service uptake or outcomes where individuals are not identifiable.

International Transfers

We do not routinely transfer personal data outside the United Kingdom. Where a transfer outside the United Kingdom is necessary, we will ensure that appropriate safeguards are in place in accordance with applicable data protection law.

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 retain personal data only for as long as necessary for the purposes for which it was collected, including for the provision of services, legal and regulatory compliance, the establishment or defence of legal claims, and appropriate record-keeping. 

Different retention periods apply depending on the type of data and service involved. Further information about retention periods can be provided on request.

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: sara@vitalflow-health.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.

Date: April 2026

Version: 1.1

Author: Data Protection Consultant, Dev Parmer

Review April 2027