The fine print
We are committed to protecting and respecting your privacy and therefore this Privacy (the “Policy”) sets out the basis on which any personal data we collect about you, or that you provide to us, will be processed by us.
Please read the Policy carefully to understand our views and practices regarding your personal data and how we will treat it. By using our online services including our site located at https://numan.com and purchasing products and accessing our services you agree to the use we make in accordance with this Policy of all personal data you provide to us or we collect about you. If you do not agree with any term in this Policy, please do not use our online services.
https://numan.com is a website and service operated by Vir Health Limited ("we"/"us"). We are a company registered in England and Wales under company number 11449267. Our registered office is located at 4-6 Canfield Place, London NW6 3BT but you can find our team working a stone’s throw away from busy Harley Street at 411-413 Oxford Street, London, W1C 2PF.
For the purpose of the Data Protection Act 2018 (the “Act”), we are the controller of your personal data. Our nominated representative for the purpose of the Act is Harold Eytan.
Data we may collect from you
In this Policy your "data" means information or pieces of information relating to you or that could allow you to be directly or indirectly identified. We may collect, use, store and transfer different kinds of data about you:
- Contact Data includes data such as your email address, telephone number and correspondence address
- Identity Data includes data such as first name, last name, username or similar identifier, date of birth and gender assigned at birth;
- Health Data includes your responses to our questionnaires and any other information you provide to us about your physical or mental health including current medication and your GP details if you choose to provide that to us;
- Technical Data includes data such as internet protocol (IP) address, your login data, browser type and version, cookies, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website and any communications we may send to you.
- Usage Data includes information about how you use our website such as information about your visit to our website, including the full Uniform Resource Locators (URL) clickstream to and through, pages you viewed or searches you made, page response times, download errors, length of visit, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
- Marketing Data includes your preferences in receiving marketing from us.
We do not knowingly collect data of children. Please do not provide data to us unless you are at least 18 years old.
Data you voluntarily provide
From time to time you may provide data to us. This may be because:
- You fill out our online questionnaires or register to receive communications.
- You contact us via email or phone, and if you do, we may keep a record of that correspondence and record the phone call.
- You complete surveys that we use for research purposes. These are however not mandatory
- You purchase services or products through our online service.
- You respond to our request for identification documents
- You provide services to us and/or our website users.
- You provide feedback to us.
- You otherwise contact us including with queries, comments or complaints.
We shall process all such data in accordance with this Policy. Certain data is mandatory to be provided to us in order that we can fulfil your request, for example to purchase services or products on our website, and we shall make this clear to you at the point of collection of the data.
All data that you provide to us must be true, complete and accurate. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this and we may also report this to the appropriate authorities.
Data we automatically collect about you
When you use our website, we may automatically collect and store information about your Technical Data and Usage Data for the purposes of research and analysis.
Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, please see our Cookies Policy..
Data we receive from others
If we reasonably believe that any of the data you have provided to us is inaccurate, we may receive further data from third parties, such as credit reference agencies, the electoral register, and our verification partners confirming or otherwise, your identity.
We may also receive data about you from our third party service providers, including our payment service provider and our analytic service providers In addition, our business relies on collaboration with third-parties such as our prescribers, pharmacies, our doctors and our blood testing companies and so we may therefore receive information about you from them.
Legal basis for processing your data
We will only use your data where we have a lawful basis to do so. The lawful purposes that we rely on under this Policy are:
- consent (where you choose to provide it);
- performance of our contract with you;
- compliance with legal requirements; and
- legitimate interests. When we refer to legitimate interests we mean our legitimate business interests in the normal running of our business which do not materially impact your rights, freedom or interests.
We may from time to time need to use Contact Data and/or Identity Data to comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party’s rights, property or safety.
We may also use any of your data, except your Health Data, for our legitimate interests including:
- to improve our website and our services;
- in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
- to deal with any questions or comments you raise;
- for audit purposes; and
- to contact you about changes to this Policy and/or our Terms.
Who do we share your data with?
For our legitimate interests, we may share your data with our service providers, sub-contractors, consultants and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including IT service providers, group companies, accountants, auditors and lawyers.
We shall provide our service providers, sub-contractors, consultants and agents only with such of your data as they need to provide the service for us and if we stop using their services, we shall request that they delete your data or make it anonymous within their systems
As noted above, our business relies on collaboration with third-parties such as our prescribers, pharmacies , blood testing companies and so we will share data about you with them, in particular your Contact Data and Health Data. Again, you agree that we cannot provide consulting services or products to you unless we share your Health Data with these third parties. As also noted above, if you use our consultation services, we will provide your personal data to our GP consultation organisation, Qured, and they will also act as a controller of your personal data.
If in accordance with our Terms of Sale we need to verify your identification, we shall share your some of your Contact Data and Identity Data with our verification partners.
To facilitate the delivery of your order to you, you also understand and agree, that we will use third party delivery companies, such as Royal Mail and other delivery service companies to deliver products to you and so we shall share your Contact Data with them.
To evaluate the performance of our business at a granular level we may occasionally send data to validated third parties for the purposes of evaluating ongoing performance.
We ensure that any data we disclose in accordance with our Policy is kept to the minimum required to allow the safe and effective delivery of services to you, and will never knowingly share with third parties who do not comply with the Act.
Only with your consent, we shall provide your data, including your Health Data to your own GP.
If we need to use your data to comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party’s rights, property, or safety then in doing so, we may share your data with third party authorities and regulatory organisations and agencies.
If we choose to merge, sell assets, consolidate or restructure, finance, or sell of all or a portion of our business by or into another company then the new owners may use your data in the same way that we do as set out in this Policy.
We may also occasionally use your data to receive feedback about our services.
Third Party Service providers
Currently, we work with the following third party service providers:
- You Can Clinic - to fulfil our services and enable you to receive any prescribed medication; (http://www.youcanclinic.com/privacy);
- Qured – to provide consultation services (https://qured.com/privacy-policy)
- Lexis/Nexis - to help Vir Health verify customer’s identity and comply with CQC regulations (https://www.lexisnexis.com/global/privacy/en/privacy-policy-uk.page);
- Drip - to send email communications to customers. (https://www.drip.com/privacy)
- Trustpilot - to solicit, collate & display reviews of products & services. (http://legal.trustpilot.co.uk/end-user-privacy-terms)
- Hotjar - to help us analyse how people use its websites and identify improvements. (https://www.hotjar.com/legal/policies/privacy/)
- Zendesk - to provide communication and customer service tools to better service customers and their requests. (https://www.zendesk.com/company/customers-partners/privacy-policy);
- Google Analytics - to help us analyse how people use its websites and identify improvements (https://www.google.com/policies/privacy/)
- Facebook - to help us understand how users find our site and identify improvements to the way we advertise our services. (https://en-gb.facebook.com/policies/ads);
- Twitter - to help us understand how users find our site and identify improvements to the way we advertise our services (https://twitter.com/privacy)
- Taboola - to help us understand how users find our site and identify improvements to the way we advertise our services (https://www.taboola.com/privacy-policy)
- Outbrain - to help us understand how users find our site and identify improvements to the way we advertise our services (https://www.outbrain.com/legal/)
- Snapchat - to help us understand how users find our site and identify improvements to the way we advertise our services (https://www.snap.com/en-GB/privacy/privacy-policy)
- Google Stack - to help us understand how users find our site and identify improvements to the way we advertise our services, and help us optimize our site to help users find the information they are looking for (https://policies.google.com/privacy?hl=en)
- Youtube - to help us understand how users find our site and identify improvements to the way we advertise our services (https://www.youtube.com/intl/en-GB/yt/about/policies/)
- Bing Ads - to help us analyse how people use of our websites and identify improvements; to measure the effectiveness of advertisements and communications; to provide relevant advertisements and communications to users (https://privacy.microsoft.com/en-gb/privacystatement)
- Mixpanel - to allow us to evaluate & improve subscriptions and onsite usage by customers and visitors
- MessageBird – To send personalised text messages for marketing or customer service updates (https://www.messagebird.com/legal/privacy/)
- PlusThis – Used to extend the functionality of our CRM platform (Drip) to allow us to connect to 3rd party services such as SMS, Appointment Booking and Video Conferencing (https://www.plusthis.com/privacy)
- Calendly – To allow users to book appointments to speak with clinicians (https://calendly.com/pages/privacy)
- Typeform – To allow users to answer custom surveys and give further information (https://admin.typeform.com/to/dwk6gt)
- Unbounce – To help create relevant landing pages for web traffic (https://unbounce.com/privacy/)
- Xplenty – To move data from one silo to another without human involvement (https://www.xplenty.com/privacy/)
- Adalyser – To analyse traffic that is driven by adverts on TV (https://www.adalyser.com/en/privacy#:~:text=Adalyser's%20Privacy%20Policy.&text=We%20are%20independent%20of%20any,without%20revealing%20any%20personal%20information.)
- Convertflow – To customise the onsite experience for users by adding additional elements to the page (https://help.convertflow.com/article/186-adding-your-privacy-policy-and-terms-of-service)
- Onesignal – To allow Numan to deliver push notifications when a user accepts a prompt (https://onesignal.com/privacy_policy)
- CJ Affiliate - Allows partners to receive a reward for referring customers from their own assets (https://www.conversantmedia.com/legal/privacy)
- MentionMe – Enables customers to refer a friend to join Numan in return for a financial incentive for the referrer and the referee (https://mention-me.com/help/privacy_policy_s)
- Loqate – Automatically validate addresses at the time of entry (https://www.loqate.com/en-gb/privacy/)
Where we store your data
The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom and/or European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of services.
Where your data is transferred outside the United Kingdom and/or the EEA, it will only be transferred to countries that have been identified as providing adequate protection for data or to a third party where we have approved transfer mechanisms in place to protect your data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).
We take appropriate security measures to protect against unauthorised access to or unauthorised alteration, disclosure or destruction of data.
These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorised access to systems where we store data.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our online properties, you are responsible for keeping this password confidential. You should not share this password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
You may request or consent to receive marketing email messages such as special offers from us about our website and our services and business generally. You may do by ticking the ‘Please keep me updated’ box when you sign up.
You can choose to no longer receive such marketing emails from us by contacting us via email at [email protected], within your Account page or clicking unsubscribe from a marketing email. Please note that it may take us a few days to update our records to reflect your request.
If you ask us to remove you from our marketing list, we shall keep a record of your name and email address to ensure that we do not send to you marketing information.
You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be found here and you can exercise any of these rights at any time by contacting us at [email protected].
- Right of access: You have the right to obtain from us a copy of the data that we hold for you.
- Right to rectification: You can require us to correct errors in the data that we process for you if it is inaccurate, incomplete or out of date.
- Right to portability: You can request that we transfer your data to another service provider if you initially provided consent for us to use the data or where we used the data to perform a contract with you.
- Right to restrict or object to processing: In certain circumstances, you have the right to require that we restrict the processing of your data if you believe our processing impacts on your fundamental rights and freedoms. However, we may demonstrate that we have legitimate grounds to process your data not withstanding your rights and freedoms.
- Right to be forgotten: You also have the right at any time to require that we delete the data that we hold for you, where it is no longer necessary for us to hold it. However, whilst we respect your right to be forgotten, we may still retain your data in accordance with applicable laws and when we respond to your request we shall notify you of any specific legal reasons that we have to retain your data.
- Right to stop receiving marketing information: You can ask us to stop sending you information about our services, but please note we shall continue to contact you in relation to any matters relating to your account, if you have one.
We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive, and we may ask for identification from you before we can fully respond to your request.
If you have any complaints in relation to this Policy or otherwise in relation to our processing of your data, please tell us. We shall review and investigate your complaint and try to get back to you within a reasonable time. You do also have the right to contact the Information Commissioner, see www.ico.org.uk or if you are based outside of the United Kingdom, please contact your local regulatory authority.
Retention of data
Subject to the provisions of this Policy, we will retain data in accordance with applicable laws. This means that we shall retain your data for as long as you have an account with us or otherwise access or use our site. However, we may also be required to retain data for a particular period of time to comply with legal, auditory or statutory requirements, including requirements of HMRC in respect of financial documents and in order to deal with any dispute you might raise. You acknowledge and agree that we are required by law to archive electronic patient records including your personal information, communication and treatments for a minimum of 10 years.
Where we have no legal basis for continuing to process your data, we shall either delete or anonymise it or, if this is not possible (for example, because your data has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
If any provision of this Policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.
This Policy shall be governed by and construed in accordance with English law and you agree to submit to the exclusive jurisdiction of the English Courts.
Any changes we may make to our Policy in the future will be posted on this page and, if the changes substantially affect your rights or obligations, we shall notify you if we have your email address.
Questions, comments and requests regarding this Policy are welcomed and should be addressed to Vir Health Ltd, #2.03 411-413 Oxford St. W1C 2PE, London, United Kingdom or via email at [email protected].
This Policy was last updated on 2 July 2020. You may contact us if you wish to review any previous version.