Privacy Policy

This privacy policy explains how The Livewell Syndicate Ltd collects, uses and protects your personal data. It applies between you, the User of this Website, and The Livewell Syndicate Ltd, the owner and provider of this Website, and it covers any Data collected by us or provided by you in relation to your use of the Website and our services.

We handle health information, so this policy tells you plainly what we collect, who sees it and what we do not do with it.

This privacy policy should be read alongside, and in addition to, our Terms of Use, which are available on this website.

Please read this privacy policy carefully.

The short version

Definitions and Interpretation

In this privacy policy, the following definitions are used:

In this privacy policy, unless the context requires a different interpretation:

• The singular includes the plural and vice versa.

• References to sub-clauses, clauses, schedules, or appendices are to sub-clauses, clauses, schedules, or appendices of this privacy policy.

• A reference to a person includes firms, companies, government entities, trusts, and partnerships.

• "Including" is understood to mean "including without limitation."

• Reference to any statutory provision includes any modification or amendment of it.

• The headings and sub-headings do not form part of this privacy policy.

Scope of This Privacy Policy

This privacy policy applies only to the actions of The Livewell Syndicate Ltd and Users with respect to this Website and our services. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

For purposes of the applicable Data Protection Laws, The Livewell Syndicate Ltd is the "data controller." This means that we determine the purposes for which, and the manner in which, your Data is processed. We are registered with the Information Commissioner's Office, registration number ZB061995.

Data Collected

We may collect the following Data, which includes personal Data, from you:

• Your name, date of birth and sex, and your gender identity if you choose to tell us. We ask for your sex because many reference ranges depend on it.

• Contact information such as email addresses and telephone numbers.

• Your address, where we send you a kit or a practitioner visits you.

• Your account details, if you register with us.

• Information about your health, such as your current physical and mental health, and any medication or supplements you tell us about.

• Your blood sample, and the results of its analysis.

• Notes of any results consultation you have with us.

Information about your health, your sample and your results is health data. The UK GDPR treats health data as special category data and gives it extra protection. Our Use of Data, below, explains how we handle it.

How We Collect Data

We collect Data in the following ways:

• Data is given to us by you.

• Data is collected automatically.

• Data is generated when your sample is analysed and your results are produced.

• Where your employer arranges a workplace programme, your employing organisation may supply basic details, such as your name and work email address, to help us set it up. It never supplies medical information, and it never receives your personal data back (see Workplace Programmes and Your Employer).

Data that is given to us by you

The Livewell Syndicate Ltd will collect your Data in a number of ways, for example:

• When you contact us through the Website, by telephone, post, email, or through any other means.

• When you register with us and set up an account to receive our products/services.

• When you enter a competition or promotion through a social media channel.

• When you make payments to us, through this Website or otherwise.

• When you use our services.

In each case, in accordance with this privacy policy.

Data that is collected automatically

To the extent that you access the Website, we will collect your Data automatically, for example:

• We automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation and includes your IP address, the date, times, and frequency with which you access the Website and the way you use and interact with its content.

• We will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies."

Our Use of Data

We use your Data to provide your test and run our service. Specifically, we use it to:

• take your order, collect and test your sample, and return your results to you;

• produce and check the explanation that comes with your results;

• keep internal records, and improve our products and services;

• contact you about your order and, where you agree, send you marketing by email;

• produce anonymised group level reports for employers who arrange a workplace programme.

Our legal bases

• Contract: when you register with us or order from us, we process your Data because it is necessary to perform our contract with you, or to take steps at your request before entering into one.

• Legitimate interests: we may use your Data for internal record keeping and to improve our products and services where we deem it necessary for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your Rights" below). We do not rely on legitimate interests to process your health data.

• Vital interests: in an emergency, such as when we cannot reach you about a critical result, we may share the information needed to protect your life with the emergency services.

Health data

We process your health data, including your sample and results, to provide the service you have asked for. Because it is special category data, our legal basis is your explicit consent. You give it by ticking a separate box at checkout, or on the consent form at your appointment, before we collect your health data.

You can withdraw your consent at any time by emailing dataprotection@livewellsyndicate.com. If you do, we may no longer be able to provide or complete your service. Withdrawing consent does not affect processing that took place before you withdrew it, and we may still keep records we need to meet a legal obligation or to defend a legal claim.

Marketing

For the delivery of direct marketing to you via email, we'll need your consent, whether via an opt-in or soft opt-in:

• Soft opt-in consent: A specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under "soft opt-in" consent, we will take your consent as given unless you opt out.

• For other types of e-marketing, we are required to obtain your consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.

• If you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your Rights" below.

Who We Share Data With

We share your Data only with the people who need it to deliver your service, and only as far as they need it:

• Inuvi Diagnostics Limited: the laboratory, accredited by UKAS to ISO 15189, that analyses your sample. It receives your sample and the details needed to identify it and return your results. Inuvi may send some specialist tests to another accredited laboratory it works with, such as The Doctors Laboratory.

• BloodGPT (Real AI Ltd): provides our results platform. It processes your results and the information you give us to produce the explanations we return to you, including content produced with the help of artificial intelligence. Every result and explanation is checked by our Managing Director before it is released to you.

• Our service providers: the companies that host our website and email, take payments, manage bookings, send emails and run video calls. These are Krystal, Google (Workspace, Meet and Analytics), Stripe, SimplyBook, Resend and Mailchimp.

• Your GP: only if you ask us to.

• The emergency services or safeguarding teams: only where there is a serious risk to your life or safety, or to someone else's.

Inuvi Diagnostics Limited, BloodGPT and our service providers act as our processors. This means they handle your Data on our instructions and for no purpose of their own.

Some of our providers are based outside the UK, for example Real AI Ltd in Cyprus and Google in the United States. Where your Data leaves the UK, the transfer is protected by UK adequacy regulations, the UK Extension to the EU–US Data Privacy Framework, or the International Data Transfer Agreement.

BloodGPT uses artificial intelligence to draft the explanation of your results. No decision about you is made by automated means alone, and every explanation is checked by a person before you see it.

Workplace Programmes and Your Employer

We never share your personal data with your employer. This includes your results and any other health data, whether or not your employer arranged and paid for your test.

Employers who arrange a programme with us receive group level reports only. These reports are anonymised, and we only produce one where the group includes five or more individuals, so that no individual can be identified from it.

Where your employer arranges a programme, they may give us basic details, such as your name and work email address, to help us set it up. They never give us any medical information. We handle the details they do give us under this privacy policy.

Keeping Data Secure

We will use technical and organisational measures to safeguard your Data, for example:

• Access to your account is controlled by a password and a username that is unique to you.

• We store your Data on secure servers.

Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse, loss, or unauthorised access to your Data, please let us know immediately by contacting us at hello@livewellsyndicate.com.

Data Retention

We keep your health records, including your results, explanations, consent forms and consultation notes, for 8 years after your last test or consultation. We keep order and payment records for 6 years after the end of the financial year they relate to, and complaint files for 10 years after the complaint is closed. We keep your marketing preferences until you opt out, and then keep a minimal record so that we do not contact you again.

Even if we delete your Data, it may persist on backup or archival media for legal, tax, or regulatory purposes.

Your Rights

You have the following rights in relation to your Data:

• Right to access: The right to request copies of the information we hold about you. We will not charge you for this, unless your request is manifestly unfounded or excessive. Where we are legally permitted to refuse a request, we will tell you why.

• Right to correct: The right to have your Data rectified if it is inaccurate or incomplete.

• Right to erase: The right to request that we delete or remove your Data from our systems.

• Right to restrict our use of your Data: The right to "block" us from using your Data or limit the way in which we can use it.

• Right to data portability: The right to request that we move, copy, or transfer your Data.

• Right to object: The right to object to our use of your Data including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set out above, or withdraw your consent, please contact us at dataprotection@livewellsyndicate.com. We reply within one month.

If you are unhappy with how we have handled your Data, please tell us first at dataprotection@livewellsyndicate.com. We acknowledge data protection complaints within 3 working days. You can also complain to the Information Commissioner's Office (ICO) at ico.org.uk.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Links to Other Websites

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of Business Ownership and Control

The Livewell Syndicate Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of The Livewell Syndicate Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part, and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

We may also disclose Data to a prospective purchaser of our business or any part of it.

In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

This Website may place and access certain Cookies on your computer. The Livewell Syndicate Ltd uses Cookies to improve your experience of using the Website and to improve our range of services. The Livewell Syndicate Ltd has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

We use Google Analytics cookies to understand how visitors use the Website. These cookies are only set if you accept them in the cookie banner, and you can reject them as easily as you accept them. Google Analytics data may be processed by Google in the United States.

All Cookies used by this Website are used in accordance with current Cookie Law.

Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling The Livewell Syndicate Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

You can find a list of Cookies that we use in the Cookies Schedule (available on request or as published on this Website).

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

General

You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal, or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This privacy policy is governed by the law of England and Wales. Any disputes arising under it are subject to the exclusive jurisdiction of the courts of England and Wales.

Changes to This Privacy Policy

We may change this privacy policy from time to time, or where the law requires it. Any changes will be posted on the Website with the date of the change. Where a change significantly affects how we use your Data, we will tell you directly.

You may contact The Livewell Syndicate Ltd about this privacy policy by email at dataprotection@livewellsyndicate.com.