Privacy policy
Last updated: [DATE]
Who we are
Prime40 Health is a trading name of [COMPANY NAME], a company registered in England and Wales (company number [COMPANY NUMBER]), registered with the Information Commissioner's Office (registration number [ICO REGISTRATION NUMBER]). We are the data controller for the personal information described in this policy. You can contact us at [CONTACT EMAIL].
What Prime40 Health does
Prime40 Health is a referral service. We send you a plain-English checklist and, if you would like it, we can introduce you to a doctor-led clinic. We do not give medical advice or provide treatment. We may be paid by the clinics we introduce.
We only share your details with a named partner clinic after you have agreed. Before any details are shared, we will tell you which clinic it is. If you don't agree, we don't share them.
What we collect
- Details you give us: your first name, phone number and email address.
- Your quiz answers: your age range, the region you are based in, when you would like a blood test, and what would help you most.
- Your consent: the consent wording you agreed to and when you agreed.
- How you found us: the page address and advert details (for example the campaign name) from the link you clicked.
- Technical information: basic information your browser sends, such as your IP address, device type and browser.
We do not ask any health questions.
How we use it and our lawful basis
- To send your checklist and contact you by phone, text and email about your results and options. Lawful basis: your consent.
- To introduce you to a partner clinic, only after you have agreed and been told which clinic. Lawful basis: your consent.
- To keep records of your consent and our contact with you. Lawful basis: legal obligation and our legitimate interests in showing we act lawfully.
- To measure which adverts work, only if you accept advertising cookies. Lawful basis: your consent.
- To prevent fraud and misuse of our forms. Lawful basis: our legitimate interests.
Who we share it with
- A named partner clinic, only after you have agreed and been told who it is.
- Service providers who work for us under contract, such as website hosting (Cloudflare), our customer-management system and phone, text and email providers. They may only use your information to provide their service to us.
- Meta (Facebook), only if you accept advertising cookies: we tell Meta that a page was viewed and that a form was sent, so we can measure our adverts. Your contact details are scrambled (hashed) before they are matched. We never send your quiz answers to Meta.
- Regulators, courts or the police where the law requires it.
We never sell your information.
Cookies
We only use advertising cookies (the Meta pixel) if you click "Accept" on our cookie notice. If you click "No thanks", none are set. We remember your choice in your browser. To change your mind, clear this site's data in your browser and you will be asked again.
International transfers
Some of our service providers may process information outside the UK. Where they do, we make sure appropriate safeguards are in place, such as the UK International Data Transfer Agreement or an adequacy decision.
How long we keep it
We keep your details for up to [RETENTION PERIOD, e.g. 24 months] after our last contact with you, unless you ask us to delete them sooner or the law requires us to keep them longer. Consent records are kept for as long as we need to show we had your consent.
Your rights
Under UK data protection law you have the right to:
- withdraw your consent at any time (this doesn't affect anything we did before you withdrew it);
- ask for a copy of your information;
- ask us to correct or delete it;
- ask us to restrict or stop using it, or object to how we use it;
- ask us to transfer it to you or someone else.
To use any of these rights, or to stop us contacting you, email [CONTACT EMAIL]. You can also reply STOP to any text from us. We will respond within one month.
Complaints
If you are unhappy with how we use your information, please contact us first at [CONTACT EMAIL]. You also have the right to complain to the Information Commissioner's Office (ICO): ico.org.uk/make-a-complaint or 0303 123 1113.
Changes to this policy
We may update this policy. The latest version will always be on this page, with the date it was last updated.