Privacy Policy

Welcome to The Health Nav Limited (referred to as "we", "us", "our", or "The Health Nav"). We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you use our website www.thehealthnav.co.uk our mobile application (The Health Nav), and the services we offer through them (collectively, our "Services") to help you find and connect with health and wellness practitioners ("Practitioners").

This policy is designed to help you understand:

• What personal data we collect
• How we use your personal data
• Our lawful bases for processing your personal data
• How we handle sensitive information, such as search queries that might infer health conditions
• Who we might share your personal data with
• Your data protection rights
• How we keep your data secure

Please read this policy carefully.

Last updated: November 10, 2025

This Privacy Policy applies to all individuals who use our Services. By using our Services, you acknowledge that you have read and understood this Privacy Policy. This policy is prepared in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

For the purpose of the UK GDPR, the data controller is:

The Health Nav Limited
Albany House, Claremont Lane, Esher, KT10 9FQ
Company Registration Number: 16453655
Email for privacy inquiries: info@thehealthnav.co.uk
Website: www.thehealthnav.co.uk

We are registered with the Information Commissioners Office with registration number ZC038027.

We have appointed a Data Protection Manager (DPM) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Notice, including any requests to exercise your legal rights concerning your data as a Practitioner, please contact our DPM.

DPM Contact Email: info@thehealthnav.co.uk
DPM Contact Address: The Health Nav Limited, Albany House, Claremont Lane, Esher, KT10 9FQ

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

Identity Data: first name, last name, username or similar identifier, title, date of birth, and gender.

Contact Data: email address, telephone numbers.

Account Data: your username, password (encrypted), preferences, and feedback.

Search Information: When you use our Services to find Practitioners, we collect:

• The types of Practitioners or services you search for (e.g., Physiotherapist, Osteopaths, Exercise Physiologist).
• Specific keywords, specialties, or conditions you may include in your search terms (e.g., Back Pain Specialist, Women's Health, Post-operative care).
• The location parameters you use for your search (e.g., postcode, city, or an area based on your device's location if you grant permission).

Important Note on Search Information: Your search queries, particularly those for specific medical specialties or terms, may allow inferences to be made about your personal health interests, needs, or potential conditions. This is treated as sensitive information, as detailed in Section 8 (Special Category Data).

Location Data:

• General location information you provide (e.g., city or postcode for searches).
• With your explicit consent, precise geolocation data from your mobile device if you enable location services for our app.

Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location (derived from IP), browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Services.

Usage Data: information about how you use our website, app, and Services, such as the pages you visit, the features you use, the time spent on the platform, and your interaction patterns.

Communications Data: records of your communications with us (e.g., emails to our support team, feedback submissions).

Communications via the Platform: If our platform facilitates communication between you and Practitioners (e.g., a messaging or booking request feature), we may process data related to these communications to enable the service and ensure its proper use.

We do not directly collect or store your official medical records or detailed clinical health history from healthcare providers. Our service focuses on helping you find Practitioners based on the information you provide during your search.

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

Direct interactions: You may give us your Identity, Contact, Account, and Search Information by filling in forms on our platform, creating an account, conducting searches, or by corresponding with us by post, phone, email, or otherwise.

Automated technologies or interactions: As you interact with our Services, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. Please see our Cookie Policy for further details.

Third parties or publicly available sources: We may receive Technical Data from analytics providers such as Google and we may also receive information from Google Sign-In and Apple Sign-In.

We will only use your personal data when the law allows us to. The table below describes the ways we plan to use 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, and the specific condition under Article 9 UK GDPR where we process inferred health data.

Purpose of Processing: To register you as a new user and manage your account
Type(s) of Data Used: Identity, Contact, Account Data
Lawful Basis under UK GDPR Article 6: Performance of a contract with you, necessary for our legitimate interests (to operate our business and provide services)
Specific Condition under UK GDPR Article 9: Not Applicable

Purpose of Processing: To provide our core Service: enabling you to search for and find Practitioners
Type(s) of Data Used: Identity, Contact, Account Data, Search Information, Location Data
Lawful Basis under UK GDPR Article 6: Performance of a contract with you, necessary for our legitimate interests (to operate our business and provide services)
Specific Condition under UK GDPR Article 9: Explicit Consent (Article 9(2)(a)) for processing Search Information that infers health data

Purpose of Processing: To manage our relationship with you (e.g., notifying you about changes to our terms or privacy policy, responding to your queries, asking for feedback)
Type(s) of Data Used: Identity, Contact, Account Data, Communications Data
Lawful Basis under UK GDPR Article 6: Performance of a contract; Necessary to comply with a legal obligation; Legitimate Interests (to keep our records updated and to study how customers use our services and to operate our business and provide services)
Specific Condition under UK GDPR Article 9: Explicit consent, legal claims or judicial acts, reasons of substantial public interest (with a basis in law) including regulatory requirements, preventing fraud

Purpose of Processing: To facilitate your interaction or booking requests with Practitioners via the platform, as initiated by you
Type(s) of Data Used: Identity, Contact, Account Data, relevant Search Information, Communications via the Platform
Lawful Basis under UK GDPR Article 6: Performance of a contract (to fulfil your request); Your Explicit Consent (for sharing any inferred health data with the practitioner), necessary for our legitimate interests (to operate our business and provide services)
Specific Condition under UK GDPR Article 9: Explicit Consent (Article 9(2)(a)) if inferred health data is passed to the practitioner at your request

Purpose of Processing: To administer and protect our business and our Services (including troubleshooting, data analysis, testing, system maintenance, support, security, fraud prevention)
Type(s) of Data Used: Identity, Contact, Account Data, Technical Data, Usage Data
Lawful Basis under UK GDPR Article 6: Legitimate Interests (for running our business, to provide services, provision of administration and IT services, network security, to prevent fraud); Necessary to comply with a legal obligation
Specific Condition under UK GDPR Article 9: Explicit consent, legal claims or judicial acts, reasons of substantial public interest (with a basis in law) including regulatory requirements, preventing fraud

Purpose of Processing: To use data analytics to improve our Services, marketing, customer relationships, and experiences (typically using aggregated or pseudonymised data)
Type(s) of Data Used: Technical Data, Usage Data, Anonymised/Aggregated Search Information
Lawful Basis under UK GDPR Article 6: Legitimate Interests (to define types of customers for our services, to keep our Services updated and relevant, to develop our business and to inform our strategy)
Specific Condition under UK GDPR Article 9: Not Applicable (if data is truly anonymised/aggregated), otherwise explicit consent

Purpose of Processing: To send you marketing communications about our Services, where you have given us permission to do so
Type(s) of Data Used: Identity, Contact Data, your marketing preferences
Lawful Basis under UK GDPR Article 6: Consent
Specific Condition under UK GDPR Article 9: Not Applicable

Purpose of Processing: To share with regulators, law enforcement and applicable government departments/agencies.
Type(s) of Data Used: Professional Identity, Clinic/Business Info, Contact Data, Account Data
Lawful Basis under UK GDPR Article 6: Necessary for legitimate interests (to protect our business and ensure compliance with applicable laws), necessary to comply with a legal obligation
Specific Condition under UK GDPR Article 9: Explicit consent, legal claims or judicial acts, reasons of substantial public interest (with a basis in law) including regulatory requirements, preventing fraud

Legitimate Interests: Where we rely on legitimate interests, it means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you by contacting us.

Consent: Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct and our own direct marketing communications to you via email or text message, or for the processing of Search Information that infers health data (see Section 8), and for use of non-essential cookies. You have the right to withdraw consent at any time by contacting us by using the contact details in section 19. Please note, if you withdraw your consent for us to process your special category data, you may not be able to use our Services.

As highlighted in Section 5 and 7, your search queries on our platform (e.g., searching for "back pain" or "pelvic floor") can allow inferences to be made about your personal health status, interests, or potential conditions. Under the UK GDPR, data that reveals or infers health status is "special category data" and requires a specific condition for lawful processing, in addition to an Article 6 lawful basis.

Our Commitment: We treat this inferred information with the utmost care and sensitivity.

Lawful Basis (Article 9 Condition): For the processing of Search Information that allows inferences about your health status, we primarily rely on your Explicit Consent (Article 9(2)(a) of the UK GDPR), but we may also rely on other basis in certain situations – for details please see section 7. Where we obtain your explicit consent, we do this through our website and mobile application sign up processes.

We may have to share your personal data with the parties set out below for the purposes set out in the table in Section 7:

External Third Parties (For example Service Providers):

Providers of IT and system administration services, including (e.g., cloud hosting services (Google Cloud), data analytics providers (Google Analytics), customer service software, email delivery platforms, payment processing providers). These providers are contractually bound to act only on our instructions and to implement appropriate security measures.

Practitioners:

We do not share your personal search history or identifiable account information directly with Practitioners you find through our Service. Any interaction you have with a Practitioner, including sharing your information with them, is initiated by you outside of this specific data sharing by us. Practitioners act as independent data controllers of your data – please review and ensure you are comfortable with their privacy policies before you share any data with them because The Health Nav is not responsible for the processing of personal data by Practitioners.

Professional Advisers: including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services, where necessary for our legitimate interests or legal obligations. Such professional advisors typically act as independent controllers of your personal data and accordingly they are responsible for their processing of your personal data.

HM Revenue & Customs, regulators, and other authorities: who require reporting of processing activities in certain circumstances or to comply with legal obligations. Such bodies typically act as independent controllers of your personal data and accordingly they are responsible for their processing of your personal data.

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 Policy. We do not otherwise sell your personal data.

Where external third parties act as our data processors, we require them 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.

Where external third parties act as independent controllers of personal data, we are unable to determine the purpose that they use your data for. Please contact the relevant organisation for details.

Data Processing Services

The following services process personal data on our behalf. You can manage your consent preferences for each service through our consent management platform.

Who provides this service. We use Zoho CRM, provided by Zoho Corporation (Zoho Corporation B.V., Netherlands; Zoho Corporation Pvt. Ltd., India; and Zoho Corporation, USA), to manage our customer, practitioner, and clinic relationships and to help us meet our legal obligations around consent and privacy requests.

Our role and Zoho's role. We are the data controller for personal data we store in Zoho. Zoho acts as our data processor and processes personal data on our instructions under a data processing agreement (including the EU/UK Standard Contractual Clauses for international transfers).

What we send to Zoho. Depending on your relationship with us (e.g., user/patient, practitioner, clinic manager), we may store the following data in Zoho:

• Contact & account data: name, email address, phone number, professional title, website URL, and descriptive tags related to services or specialties; limited clinic details (e.g., clinic name, address, phone, website, listing status).
• Practitioner verification & registrations: verification status (e.g., pending, verified, denied, needs revision), registration body and number, expiry dates, and related operational notes (we store supporting documents in our secure storage, not in Zoho).
• Consent records: consent type (functional, analytics, marketing, health-data), the action taken (given/revoked), capture method (e.g., web app), timestamp, and where available the source IP and user agent string.
• Data subject rights (DSR) logs: request type, status, date received, identity verification status, and operational notes necessary to track and fulfil privacy requests.
• Internal identifiers: our system IDs (e.g., user ID, practitioner ID, clinic ID) for reconciliation and audit.

What we receive from Zoho. We also receive status updates from Zoho (via secure webhooks) such as practitioner verification outcomes, clinic issue reports (e.g., takedown/unpublish requests), and submitted consent/DSR forms that you or your clinic may complete through our Zoho-powered workflows.

Why we process this data (legal bases).

• Contractual necessity: to provide and manage your account, practitioner listing, or clinic services.
• Legitimate interests: to operate a CRM, keep accurate records, provide support, prevent abuse/fraud, and improve our services while protecting your rights and freedoms.
• Consent: to record and honour your marketing and cookie/analytics preferences, and—where applicable—your explicit consent for processing special-category health data.
• Legal obligation: to demonstrate compliance with privacy and marketing laws and to respond to data subject requests.

International data transfers. Zoho may process data outside the UK/EEA. Where this occurs, we rely on appropriate safeguards, including the EU/UK Standard Contractual Clauses and Zoho's published security and privacy commitments. You can contact us for details of the applicable safeguards.

Retention.

• CRM/contact & account data: retained while you have an active relationship with us and for up to 6 years thereafter for record-keeping and legal purposes.
• Consent logs: retained for the duration necessary to demonstrate compliance (typically at least 2 years, and up to 6 years for audit/legal purposes).
• DSR logs: retained for up to 6 years to evidence compliance with privacy requests.

We may retain data longer where required by law, to resolve disputes, or to enforce agreements.

Security. We configure Zoho with access controls and audit logs. Zoho implements technical and organizational measures appropriate to the risk, and we ensure any sub-processors engaged by Zoho are subject to equivalent protections.

Your choices and rights. You can update your consent preferences at any time in the app (e.g., marketing emails, analytics/cookies). You also have the right to access, rectify, erase, or restrict processing of your personal data, to object to processing based on legitimate interests, and to data portability. Where processing is based on consent, you may withdraw your consent at any time; this does not affect the lawfulness of processing before withdrawal.

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 to countries which have laws that do not provide the same level of data protection as the UK law.

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

• We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, for example countries in the EU.
• We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or The International Data Transfer Addendum to the European Commission's standard contractual clauses for international data transfers. To obtain details of these contractual safeguards, please contact us using the details in paragraph 19.

We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. Examples of such measures include encryption of data at rest and in transit, access controls based on roles and responsibilities, regular security testing, staff training on data security and privacy, incident response plans.

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.

We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator (such as the ICO) of a breach where we are legally required to do so.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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.
• The applicable legal, regulatory, tax, accounting, or other requirements.

If you would like to discuss our retention periods, please contact us using the details in paragraph 19.

Upon expiry of the applicable retention period, your data will be securely deleted or anonymised.

Once personal data is no longer required for its original purpose, or the retention period has expired, it will be securely deleted or anonymised (so that it can no longer be associated with you).

Under UK data protection law, you have a number of rights in relation to your personal data. These include the right to:

• Request access to your personal data (commonly known as a "data 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.
• Request erasure of your personal data. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in 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.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party (data portability). 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 (as explained in Section 7 and 8). 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.

To exercise any of these rights, please contact us or our DPO using the contact details provided in this policy (Section 3 or 4).

You will not usually 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 may refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

Our website and app use cookies and similar technologies to distinguish you from other users, to provide certain functionalities, to improve our Services, and to understand how our Services are used. For detailed information on the cookies and similar technologies we use, the purposes for which we use them, and how you can manage your preferences, please see our separate Cookie Policy.

reCAPTCHA: We use Google reCAPTCHA Enterprise (reCAPTCHA v3) to protect our website from spam and abuse. reCAPTCHA analyzes your behavior on our site to determine whether you are a human user or a bot. This service is provided by Google LLC and is subject to Google's Privacy Policy and Terms of Service. By using our Services, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Cookie Categories

We use the following categories of cookies and similar technologies:

Tracker Declaration

The following trackers are used on our website. You can manage your preferences for each tracker category through our consent management platform.

Our Services are not intended for use by persons under the age of 18. UK GDPR (via the Data Protection Act 2018) sets the age for consent for information society services at 13. We do not knowingly collect personal data from children under this specified age without appropriate parental consent where required. If you are a parent or guardian and believe we may have collected information about a child under this age without your consent, please contact us immediately so we can take appropriate action.

Our Services may contain links to other websites, plug-ins, and applications run by other organisations. This Privacy Policy applies only to our Services. If you click on a link to another website, you should read their own privacy policy. We are not responsible for the privacy policies and practices of other sites, even if you access them using links from our Services.

We keep our Privacy Policy under regular review and may update it from time to time. Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate and significant, notified to you by email, an in-app notification, or a prominent notice on our website. The "Effective Date" at the top of this policy will indicate when it was last revised. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

We aim to resolve any queries or concerns you raise about our use of your information directly. Please contact us or our DPO in the first instance (see Section 3 or 4).

You also have the right to lodge a complaint at any time with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection issues.

The ICO's contact details are:
Information Commissioner's Office
Wycliffe House, Water Lane
Wilmslow, Cheshire, SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://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.

If you have any questions about this Privacy Policy or our data protection practices, or if you wish to exercise any of your rights, please contact our Data Protection Manager at:

Email: info@thehealthnav.co.uk
Postal Address: Albany House, Claremont Lane, Esher, KT10 9FQ

Don't have an account? You can still exercise your privacy rights. Clear all cookie consent preferences and anonymize analytics data collected during your visits.