Privacy Policy

Privacy Policy

This Privacy Notice gives you information about how Healthnix Ltd (“Healthnix”) collects and uses your personal data through your use of our app and when you communicate with us in any way, including any data you may provide when you sign up and use our services, including when you use Google sign in functionality to access our app.

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Neither this website or our app is intended for children and we do not knowingly collect data relating to anyone under 18 years old.

Who we are and how to contact us​

Healthnix Ltd is the controller and responsible for your personal data (collectively referred to as Healthnix, "we", "us" or "our" in this Privacy Notice).  Healthnix Ltd is a company registered in England and Wales with company number 15121283 with its registered office at 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE.  

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If you would like to contact us about anything in this Privacy Notice, or if you have any questions about how we use your information or if you would like to exercise any of your data subject rights please contact us here:

hello@healthnix.io

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The types of personal data we collect about all the users of our app

Personal data means any information about an individual from which that person can be identified. 

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

• Identity Data includes Google account email address, first name, last name, username or similar identifier, marital status, title, date of birth and gender.

• Contact Data includes billing address, delivery address, email address, and telephone numbers.

• Google User Data in relation to those users and Dietitians who create their account and access our mobile app via the Google login functionality includes: first name, last name, email address, user ID, profile picture (if uploaded by the user to their Google account), Google calendar information (which the user can decline to share with us).

• Transaction Data includes details about payments to and from you and other details of products and 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, purchases or orders made by you, your interests, preferences, feedback and survey responses.  

• Usage Data includes information about how you interact with and use our website, products and services. 

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

• Health Data includes any data about your health that you share with us or our registered dieticians or nutritionists when you express interest in, sign up for, and/or use our services.

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We currently do not collect any financial data directly from the users other than Transaction Data. All payments and refunds, if applicable to your plan, are handled by Stripe. 

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We also collect, use and share anonymised 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 use this anonymised data for the purposes of helping us build evidence to justify formal clinical trials and feasibility studies in a clinical setting, or for internal research and product development, including product development involving machine learning and big data analysis, or for future publications.

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How is your personal data collected?

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

• Your interactions with us. You may give us your personal data by signing up to use the mobile app, filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data, including special category health data, you provide when you:

• create an account to use the Healthnix mobile app;

• sign in to use the Healthnix mobile app;

• subscribe to our newsletters or publications; 

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us feedback or contact us. 

• Automated technologies or interactions. As you interact with our app, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We do not collect any cookies from users in our mobile app. 

• Third parties. We will receive personal data about you from the categories of third parties set out below: 

  • The dietician(s) that is allocated to you, who will share the personal data they collect from you with us, for example notes from the 1:1 calls or changes to your dietary and lifestyle plan.

  • Providers of laboratory services, for example blood testing.

  • Physiotherapists if you engage with them via our platform and consent to the information about your session being shared with us. 

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How we use your personal data

​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: Where we need to perform the contract we are about to enter into or have entered into with you.

• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose.

Purposes for which we will use your personal data 

We have set out below a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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1. PURPOSE: To register you as a new user 

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TYPES OF DATA

(a) Identity 

(b) Contact

(c) Google User Data (if user opts in to use Google login/ signup functionality)

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LEGAL BASIS: Performance of a contract with you

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2. 

PURPOSE: To register a new Dietitian on the mobile app

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TYPES OF DATA

(a) Google User Data (including Google calendar information)

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LEGAL BASIS: Performance of a contract with you

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3. 

PURPOSE: To identify the payments you have made to us, any refunds you may be due, and to identify the products or services you have purchased from us

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TYPES OF DATA

(a) Transaction Data

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LEGAL BASIS: Performance of a contract with you

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4.

PURPOSE: To process and deliver our services to you:

(a) Connect you with the Registered Dietitian and enrol into Healthnix programme 

(b) Provide you with most accurate educational and supportive materials

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TYPES OF DATA

(a) Identity 

(b) Health

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LEGAL BASIS: Performance of a contract with you

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5.

PURPOSE: To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or Privacy Notice

(b) Dealing with your requests, complaints and queries

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TYPES OF DATA

(a) Identity 

(b) Contact 

(c) Profile 

(d) Marketing and Communications

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LEGAL BASIS

(a) Performance of a contract with you 

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you)

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6.

PURPOSE: To enable you to complete a survey

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TYPES OF DATA

(a) Identity 

(b) Contact 

(c) Profile 

(d) Usage 

(e) Marketing and Communications

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LEGAL BASIS

(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

(b) Consent

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7. 

PURPOSE: To administer and protect our business and this mobile app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).  

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TYPES OF DATA

(a) Identity

(b) Contact

(c) Technical

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LEGAL BASIS

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

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8. 

PURPOSE: To deliver relevant mobile app content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

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TYPES OF DATA

(a) Identity 

(b) Contact 

(c) Profile 

(d) Usage 

(e) Marketing and Communications 

(f) Technical 

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LEGAL BASIS: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

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9. 

PURPOSE: To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing.

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TYPES OF DATA

(a) Technical 

(b) Usage 

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LEGAL BASIS: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

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10. 

PURPOSE: To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data.

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TYPES OF DATA

(a) Identity 

(b) Contact 

(c) Technical 

(d) Usage 

(e) Profile 

(f) Marketing and Communications

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LEGAL BASIS: Consent, having obtained your prior consent to receiving direct marketing communications.

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11.

PURPOSE: To allow the Registered Dietitian to assess your appropriateness for participation in/use of their services delivered through our platform. For the purpose of arranging and carrying out blood testing via Nationwide Pathology Ltd to enable my participation in our platform.

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TYPES OF DATA

(a) Identity 

(b) Contact 

(c) Profile

(d) Health

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LEGAL BASIS

(a) Performance of a contract with you

(b) Consent, having obtained your prior specific and explicit consent for the processing of your Health Data for this purpose.

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12.

PURPOSE: To provide you with a method of recording and reporting your symptoms whilst you are using our services
 

TYPES OF DATA

(a) Identity 

(b) Contact 

(c) Profile

(d) Health

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LEGAL BASIS

(a) Performance of a contract with you

(b) Consent, having obtained your prior specific and explicit consent for the processing of your Health Data for this purpose.

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13. 

PURPOSE: To provide you with the most relevant educational and informational content relating to nutrition, movement and mindset

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TYPES OF DATA

(a) Identity 

(b) Contact 

(c) Profile

(d) Health

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LEGAL BASIS

(a) Performance of a contract with you

(b) Consent, having obtained your prior specific and explicit consent for the processing of your Health Data for this purpose.

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Direct marketing 

During the registration process on our app when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via email.

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Third-party marketing 

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes. 

Opting out of marketing 

You can ask to stop sending you marketing communications at any time by by following the opt-out links within any marketing communication sent to you or by contacting us at hello@healthnix.io. 

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If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

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Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our Cookies Policy.

Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above.

• Nationwide Pathology Ltd for the purpose of arranging and carrying out blood testing to enable my participation in the Healthnix platform.

• Our registered Dieticians for the purpose of providing you with the dietary advice. 

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice. 

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We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.

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International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK or EEA to countries which have laws that do not provide the same level of data protection as the UK or EU law.

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Whenever we transfer your personal data out of the UK or EEA to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place: 

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• We will only transfer your personal data to countries that have been deemed by the UK or the EU to provide an adequate level of protection for personal data; or

• We may use specific standard contractual terms approved for use in the UK and/or EEA which give the transferred personal data the same protection as it has in the UK or EEA, or another transfer mechanism which has been approved by the relevant regulator in the UK and/or the EEA. To obtain a copy of these contractual safeguards, please contact us at hello@healthnix.io 

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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. 

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Data retention

How long will you use my personal data for?

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Healthnix retains all user data for a period of 12 months after the completion of the programme for each patient and all personal data for 6 years from the last active day of the user. This retention period is necessary for follow-up audits and to improve future service offerings. After this period, the data not necessary to be retained is securely deleted.

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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.

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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.

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Protecting your sensitive data

Healthnix follows the information security values of 

• confidentiality - making sure your information is always kept secret and private;

• integrity - we ensure the completeness, consistency, and accuracy of the data over its lifecycle; and

• availability - we ensure the right information is available to the right person at the right time

we use the following techniques and best practices to protect your sensitive data:

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People

• Training - All staff receive regular appropriate training on data protection and security and their related duties to ensuring your personal data is secure;

• Minimised access: your personal data, including Health Data, can only be accessed on a strictly needs to know basis by our admin staff, the Dietitian assigned to you specifically in our mobile app, or customer support as and when necessary specifically as relates to your particular request for support;

• Your Health Data, Identity data and Contact data can only be accessed by the Dietitian who was assigned to you for the purpose of the Healthnix programme and can only be accessed via the Healthnix Dietitian mobile app interface. 

• Security expertise: In order to design and operate our platform, we utilise qualified security professionals with recognised experience and certifications in technical security architecture as well as governance, risk, and compliance.

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Cyber resiliency, business continuity, and disaster recovery

• We utilise the most secure and resilient infrastructure from AWS which ensures servers are always patched and up to date.

• Web servers store no sensitive information – this is retrieved from an AWS AES-256 encrypted database accessible only within the virtual private cloud. Automated tests are performed internally across the codebase on every commit. 

• In addition, as part of our DSPT and DTAC certification processes, we commit to undertaking annual third-party security audits with certified security auditors including web, desktop and mobile application penetration tests to ensure comprehensive coverage. 

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Technology

We adopt principles of Secure by Design, including: 

• Architecture in line with industry standards.

• This includes role based access controls.

• Our REST APIs utilise authentication and authorization to ensure data minimization and prevent unauthorised access to data.

• Our password policy for users ensures only strong passwords are allowed and are stored hashed using Provos and Mazières's adaptive hashing algorithm.

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We use encryption in all of the following scenarios:

• In transit using modern protocols (TLS only) and secure ciphers (both internally within the VPC and externally with users & applications)

• At rest using AES-256 encryption

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Data centres

• We host data in multiple availability zones/regions in order to maximise availability. All production environments are located within the UK. 

• Where possible, through AWS we deploy a High Availability (HA) architecture to ensure resilience with automated failover to provide uninterrupted service.

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Development, security & operations

• We operate a mature secure software development life cycle (SDLC), which includes but is not limited to:

  • Separation of keys for each environment and robust key management processes

  • Regular dependency and package management audits and remediation 

  • Logical separation of production and development environments including isolated databases

  • Static code testing to ensure code is free from known vulnerabilities

  • Dynamic code testing to ensure applications do not expose vulnerabilities

  • Manual security testing (annual penetration test)

Your legal rights

You have a number of rights under data protection laws in relation to your personal data. 

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You have the right 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.

• You also have the 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 contact us hello@healthnix.io 

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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.

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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.

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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. 

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Contact details

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

Email address: hello@healthnix.io

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.

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Changes to the Privacy Notice and your duty to inform us of changes  

We keep our Privacy Notice under regular review. This version was last updated in September 2024.

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It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

Third-party links  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Notice of every website you visit.

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