Date 23 March 2024
Modern Body Ltd ("us, we") is a tech enabled virtual lifestyle clinic. We aim to empower you with the knowledge and tools needed to make informed decisions about your health and wellness journey. Our goal is not to replace medical advice from your healthcare providers but to complement it by providing personalised nutrition and lifestyle plans and holistic health support based on online health assessments and tracking ("Services").
Your privacy is at the forefront of how we offer our Services to you. We are passionate about privacy. We take seriously our responsibilities under General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA) (collectively, "Data Protection Legislation").
This policy outlines our approach to managing your personal information. Our goal is to clarify our data processing practices, providing you with the power to make well-informed decisions regarding your personal details. We encourage you to take time to familiarise yourself with this policy. You should review this Policy before using our Platform or Services. If you find you do not concur with our practices, please refrain from using our Platform or Services. We periodically review and may amend this policy. Should there be any significant alterations, we will inform you accordingly and offer you a chance to review the revisions. Your continued engagement with our Services following such amendments and our communication to you will be deemed acceptance of the new terms outlined in any revised policy.
Moreover, this policy details the ways in which your personal information may be utilised in connection with our Services, and it is applicable to all data collected via our Platform, including through the Healthie practice management application we utilise and from your consultations with Practitioners (as defined in our Terms of Service and Use available on our website at www.modern-body.co.uk/terms).
This policy covers:
- Who we are;
- What personal data we hold and how we get it;
- What we use your personal data for;
- Sharing your personal data;
- Handling, storage and destruction of your information;
- Retention;
- How we store and move your data;
- Your rights; and
- Cookies
If you have any further questions about how we process your information, please don't hesitate to get in touch by contacting our Data Protection Officer: Address: Data Protection Officer, Modern Body Ltd, 20 Wenlock Road, London, England, N1 7GU Email: info@modern-body.co.uk
Who we are
We are Modern Body Ltd, a company registered in England and Wales (number 15482319). Our registered office is situated at is 20 Wenlock Road, London, England, N1 7GU.
Your relationship is with Modern Body Ltd. When this policy talks about ‘Modern Body’, ‘the Company’ or ‘us’ or ‘we’, it means Modern Body Ltd.
What personal data we hold and how we get it:
We use the following categories of personal data:
Personal details
Upon signing up for our Services, you will be prompted to fill in certain forms, supplying personal details including but not limited to your full name, date of birth, residential address, and e-mail address. Should you provide an e-mail address, it may be used to provide you with informational content, except where you have explicitly opted out of such communications.
Health, wellness and medical information
During the process of your registration, completing our online questionnaire, and engaging with our Services, particularly consultations with Practitioners, you might share personal health, wellbeing, lifestyle, symptomatology, therapeutic interventions, sessions, prescriptions, and medical procedures-related information. This data is sourced directly from your input.
Over the course of using our Services, we amass health and lifestyle related details, which include:
- Overall health and lifestyle habits;
- Symptoms you experience, treatment plans, and medications used;
- Data derived from laboratory tests; Notes, audiovisual records, and written summaries from
- Practitioners with whom you have consultations;
- Any additional health details you choose to share or enter during communications with our team; and
- Data input into our third-party data processor service provider, Healthie Inc. (to which their terms and privacy policy shall apply and can be viewed here: https://www.gethealthie.com/privacy).
Financial Information
If you make any payments for our Services, your credit/debit card details are processed directly by a third-party processor that will store all payment information and transaction details. We will only retain details of transactions on secure servers.
Technical information and analytics
In the course of your interaction with our Platform, subject to your device's configuration allowing it, we may automatically gather certain data, which includes:
- Technical details, such as the internet protocol used to connect your smartphone or another device online, your sign-in credentials, type and version of browser or application, time zone configuration, information about your system and the operating system environment, along with your geographical position deduced from your IP address;
- Details of your website usage, encompassing the viewing or utilisation of products and our Services, site response durations, and interaction data like button clicks.
We collaborate with third parties who support us in analysing and advertising our services (exclusively for our offerings, not for external advertising purposes). These activities assist us in comprehending user interactions with our services, delivering our advertisements on the web, and evaluating the performance of both our services and advertisements. For these purposes, we may utilise cookies and analogous tracking technologies to collect data regarding your engagements with our services.
What we use your personal data for:
The purposes for which we use your personal data and the legal grounds on which we do so are as follows:
Providing you with our Services
We need your personal information to: (i) enter into a contract with you and deliver our Services. (ii) communicate with you about the Services (iii) process any purchase you make for using the Services or purchasing products from our Platform (iv) sending you email newsletters.
We use your information to provide you with a holistic and wellness lifestyle plan as part of our Services. This includes giving you wellness and lifestyle advice and coaching, as well as a suggested plan and recommendations for other tests that may be relevant to your actual needs.
This information is based on:
- Providing you or planning for health and wellness coaching Services in our 'legitimate interest' (outlined below).
- Performing tasks in the public's interest (for example, our research initiatives).
- Your consent (for example, when you use our Service and agree to share information with the Practitioner).
The health and wellness information we use includes:
- Information supplied in our assessments.
- Information obtained from you from your consultations, test results shared by the client or ordered through us as well as your comments on the app.
- Consultations, like notes, recordings, and transcripts from teleconsultations and messaging chat interactions. Your willing disclosure or input of detail in any correspondence with our team.
We may use fully anonymised health information to improve our Services, and utilise technology such as artificial intelligence, so that we can deliver better Services to you and other Modern Body users. This does not involve making any decisions about you – it is only about improving our Services and software so that we can deliver a better experience to you and other Modern Body users and help achieve our aim of making holistic health and wellness lifestyle support more affordable and accessible to everyone. Strict confidentiality and data security provisions always apply. With your consent, we share this information with Practitioners for consultations and to help with the design of any lifestyle plan. This is so we can give you the right tailored support for your needs . These services may include:
- Our Practitioners if you use our consultation Services.
- Our referral product service partners.
- Referrals for at-home lab tests.
By using our Service and sharing laboratory result with us or ordering at-home lab tests through us, you are giving us your informed consent to share the necessary information to Practitioners so that we can deliver our Services to you. Depending on how you access our Services, we get your location from your phone, internet browser, IP address or postal address.
Tracking Data
We may collect personal data from personal devices you use to track your health and wellness with such data collected to track your progress against your personalised lifestyle plan.
Improving our Services and research
We may use fully anonymised health and medical information to improve our services and for health research, including an artificial intelligence system. This helps us deliver better healthcare to you and other Modern Body users.
Long term datasets on lifestyle impacts on health outcomes remains insufficient. We want to be able to contribute to the research exploring the role of lifestyle on health outcomes and believe the information you share whilst engaging with our Services is vitally important data that we may want to use anonymously and in aggregate to help explore this field of research further.
We remove details that could identify you from this information, such as your name, address and contact details. These are called 'personal identifiers'.
The information we collect (with your personal identifiers removed) includes information from:
- Information provided on our assessments and tracked through the Platform.
- Information obtained from your test results shared by you.
- Consultations, like notes, recordings, and transcripts from consultations and chat messaging with our Practitioners.
- Your willing disclosure or input of detail in any correspondence with our team.
We only use this information to deliver a better experience to you and for other Modern Body users. This explicit consent relates to when we use your personal data.
How we use your data to help you
We need to keep a record of the Services you receive to ensure that:
- Practitioners involved in supporting you have accurate and up-to-date information;
- We have all the information necessary for assessing your needs and providing support and our Services to you;
Information obtained from third party services
Our third party payment provider will need to collect your payment details in order to process your payment for us.
Sharing your personal data with others
Other than expressly set out herein, we do not share your personal data with any third party, without your consent.
Service Providers
We may disclose your personal data to our service providers who perform functions on our behalf, insofar as it is reasonably necessary to provide specific services (including providers of servers and maintenance thereof, data storage and management, payment processing email service providers, labs specifically authorised and abiding to medical confidentiality and health data sharing regulations; third party providers of Products purchased through our Platform, and web analytics providers); We only provide our Service Providers with the information necessary for them to perform these services on our behalf.
Insurance and Compliance with Laws and Regulation
We use your health and medical information for legal, safety, training, regulatory, and compliance purposes. This means that we may also store your health information, such as your interactions with our digital services, for safety, regulatory, and compliance purposes. We may disclose your personal data to our insurers and/or professional advisers, regulatory bodies insofar as reasonably necessary for the purposes of maintaining compliance with reasonable requests by regulatory bodies, obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Security and Fraud
Where necessary, we may need to share personal and financial details for the purposes of fraud prevention and detection.
International transfers
Where personal data is shared and disclosed as set out above, these parties may be established outside the United Kingdom. For example, some of the service providers we use to support the Services are based in the US and EU, and this would involve a transfer of your personal data to the US and the EU. Whenever we transfer your personal data outside the United Kingdom, we ensure that a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented, where necessary. This may include, where appropriate, signing up to Standard Contractual Clauses.
Your rights
We rely on your consent to process your personal data, you have the right to withdraw your consent at any time by contacting us. You also have specific rights under the GDPR and DPA to:
- Wherever we process data based on your consent, withdraw that consent at any time.
- Understand and request a copy of information we hold about you. For other information, you can make a request by email;
- Ask us to rectify or erase information we hold about you, subject to limitations relating to our obligation to store medical records for prescribed periods of time;
- Ask us to restrict our processing of your personal data or object to our processing; and
- Ask for your data to be provided on a portable basis.
If you consented to us collecting and/or processing your personal information but change your mind, you can get in touch with us to request that we erase the personal information that we hold about you.
Your data is stored on secure servers on encrypted databases. This includes our third-party practice management service provider, Healthie. Inc, whose servers are hosted in the US.
You may also contact the Information Commissioner's Office (the data protection regulator in the UK): Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, telephone: 0303 123 1113 (local rate).
Third Party Links and Services
The Services may include links to third-party websites or services. This Privacy Policy does not apply to the information (including personal information) collected on any third-party website or service over which we have no influence or control. Modern Body is not responsible for the privacy practices of these third-party websites or services. Accordingly, we recommend that you review the privacy notice and related policies on any such website or services.
Cookie Policy
Our Platform uses cookies to distinguish you from other users of our Platform. This helps us to provide you with a good experience when you browse our Platform and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. You can find more information about the specific first- and third-party cookies served through the Modern Body Platform and the purposes for which we use them in the table below:
How to manage cookies
You can choose to accept or reject cookies. To deactivate the use of third-party advertising cookies, you may visit the relevant consumer page to manage the use of these types of cookies.
Most computers and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.aboutcookies.org, which includes additional useful information on cookies and how to block cookies using different types of browser. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of the Platform.
Contact us
For any questions or concerns, you can contact us by sending an email to info@modernbody.co.uk
