Privacy Policy

Personal Data

To provide you with the Unbound Services, we will collect, store, and use the following categories of personal information:

• Basic details (name, date of birth, address, etc.)
• Contact details (phone number, email address etc.)
• Payment information (Debit card, credit card, billing address etc.)
• Cookie information (please refer to Cookie Policy)
• Device information when using our services or technology

We collect this personal information about you through the registration process and throughout your membership with us directly from you and from third-party providers involved in delivering the Services.

We may also use technologies, such as tracking pixels to collect information from emails we send you. This helps us to focus our marketing to your requirements and provide more relevant emails to you. It also helps us to identify if you are not engaged with our marketing emails.

Health and Other Special Category Data

You may provide us with health and medical information directly. We will also receive such information from our third party providers in the course of providing the Services to you, as described below.

We may collect, store and use the following Special Category Data:

• Personal health and medical information for example reports, notes, blood test results, clinical measurements, previous and current prescriptions, disability information, family history of disease, historic appointment & activity records.

Information from Third Party Providers

In the course of providing the Services, we will receive Personal Data from third parties with whom we have agreements in place. These include:

• Third party service providers such as pathology laboratories and reporting providers.
• Wearable device services, where you choose to share such device data with us.

Aggregated Anonymised Data

We may use anonymised aggregated data to improve our Services or otherwise in connection with our business. Such data is not considered to be Personal Data.

Aggregated Pseudonymised Data

We may use pseudonymised aggregated data to improve our Services or otherwise in connection with our business. We will treat such data as Personal Data to be used in accordance with this Privacy Policy.

We will only use your personal information when the law allows us to. The legal bases we rely upon to use your Personal Data include the contract we have with you, where we need to comply with a legal or regulatory obligation or when you have given your consent.

We will collect and use your Personal Data in order to provide the Services you have requested and comply with legal obligations:

• To provide you with your ‘whole-person’ Health Assessment, Health Report, and your Unbound App 90-day plan, Unbound collects and processes your personal and ‘special category’ data. This includes your demographics, health information, and assessment results (blood biomarkers, physical performance data, mental wellbeing scores, and health habits). We process this data strictly to provide actionable insights into your everyday health.
• To enable us to provide healthcare services through our Partner Tuli, and other third party testing partners
• To enable us to collect payment
• To provide safe services
• To bill for services
• To meet our regulatory obligations
• To conduct audits
• To improve our systems and services
• To support marketing activities
• To enable building security
• To enable us to comply with our legal obligations (for example, fraud prevention)

Special Category Data

Where we use your more sensitive Special Category Data (including health data), we are required to have further justification for collecting, storing and using this type of personal information. We will collect and use your health and other Special Category Data in order to provide the Services you have requested, which includes:

• Diagnostic and Screening Procedures: To enable us to provide blood testing services through our Partner Tuli, and functional performance testing through our Partner VALD.
• Treatment of disease, disorder or injury; the provision of preventative medicine, lifestyle medicine, and general wellbeing advice.
• CCTV images may be used to identify an individual, in which case processing will be necessary for the establishment, exercise or defence of legal claims, or carried out on the basis of substantial public interest for the purposes of detecting and preventing crime.

Intended Use & Unrelated Use

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Legitimate Interests

In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. In line with our legitimate interests, we may use your Personal Data for the following:

• To administer, protect and improve our Services, mobile app, and website (including troubleshooting, data analysis, testing, support, fraud, reporting and hosting of data).
• To inform you of products or services that we provide.
• In the case of CCTV cameras on our premises, to prevent crime, to protect against damage or theft, and to protect the safety of staff and clients.

Protecting Interests (Including Public Interest)

We may also use your personal information where we need to protect your interests (or someone else's interests), or where it is needed in the public interest. These situations are likely to be rare.

Additional Consent

In limited circumstances, we may approach you for your written consent to allow us to process certain data for a specific purpose (for example, we may ask if you are willing to accept email marketing from us). If we seek your consent, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. If you choose not to provide consent we may not be able to provide services to you.

Anonymise

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you on the basis that it does not identify you at all.

Automated Decision Making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We do not currently conduct automated decision making. If this position changes, we will notify you and inform you of your specific rights in connection with it.

Monitoring Performance & Quality

We are committed to delivering a ‘high quality’ health membership: safe, effective, timely, people-centred, accessible, equitable, acceptable, transparent, efficient, sustainable, integrated, and resilient. To monitor our performance against these quality domains for quality control, service improvement, training, and troubleshooting, we use aggregated pseudonymised datasets. Your individual identity is never visible in these quality monitoring datasets. When you use Unbound products and services, your data is collected, identifiable details (e.g. name, DOB, contact details) are removed and your anonymised or pseudonymised data (e.g. survey responses, blood biomarkers, performance measures, app activity) are combined with other users' data to create datasets where no individual can be identified.

Improving Unbound Products and Services For You

We may use aggregated pseudonymised or anonymised datasets for internal research and development to develop new services and products for Unbound members. Your individual identity is never visible in these research datasets. You can opt out of contributing your data for research to improve your Unbound membership anytime from your account data settings. Your choice will not affect your membership or services.

Digital Health Research (Public)

Anonymised data is no longer Personal Data. Research may be conducted using Anonymised Unbound Data. These data may be used to generate findings that could be included in publications (such as peer-review science journals or Unbound blog articles and social media) to contribute to general knowledge about health, behaviour change, and lifestyle medicine.

We will not use data from which you can be identified for external research without first seeking your explicit, opt-in, informed consent. You may opt-in to specific research studies via the Unbound app after reviewing and accepting the study's Research Information Sheet and Informed Consent.

Your participation is completely voluntary and will not affect your main membership or services. You can change your mind at any time in your account settings. You can use your account settings and tools to withdraw your consent at any time or delete your account.

Parties With Whom We May Share Your Data

In order to provide Services to you, we use third parties as set out below. We may have to share your data with third parties where we have a lawful justification for doing so. Such a lawful justification may include: that the sharing is necessary for the provision of healthcare services, that we have your consent to do so or that we have a legal or regulatory obligation to fulfil.

Third parties with whom we may share your data include any of the following:

• Clinical Partners: We share your data with regulated providers (e.g., Tuli) to analyse and report your blood test results and provide you with health and wellness advice. This is a requirement of the service.
• Stripe – To take payments from you.
• Tally – To create intelligent forms and documents.
• VALD – To conduct and analyse functional performance (force plate) testing.
• Sports physiologists (e.g. Athlete Lab) to conduct and analyse VO2max testing.
• IT service providers and system administrators.
• Data hosts and providers of programming or technical support.
• Professional advisers including lawyers, accountants, bankers, auditors, regulators.

We may share Special Category Data in order to provide the Services, with:

• Third party service providers such as pathology and reporting providers (e.g. Tuli).
• Other health care practitioners with whom you may consent for data to be shared, as detailed below.

Information Sharing for Individual Care

Ensuring your care is safe and coordinated. If we detect results needing further medical investigation or treatment, Unbound will inform you and your GP. Unbound will share relevant information (such as your blood test results or questionnaire answers) on a need-to-know basis with those who are directly involved in providing care to you to ensure safe, joined-up support. Sharing these data helps your primary care doctor maintain an accurate record of your health, ensuring you receive safe, joined-up healthcare.

Sharing this information is standard clinical practice supported by the NHS and GMC. Health and care professionals have a legal duty to share information to support individual care. The duty to share information for individual care is as important as the duty to protect confidentiality.

When your information is shared with people providing your care (such as your NHS GP), Unbound will ensure that information is relevant and appropriate, and apply principles of data minimisation.

We do not need your specific consent to share your personal (including special category data) with your primary care practice for the purposes of providing your care. You will always be informed when your data is shared with your GP.

If you object to your information being shared with your primary care doctor for the purposes of your ongoing health care, you can change your GP data sharing preferences in your account settings. Please note that even if you opt out of referrals, there are special circumstances where Unbound has a duty to share information, for example to comply with a court order, CQC inspection, or overriding public interest.

There are some very specific exceptions where we would not share information. This includes information relating to the gender history of a person who is transgender (or undergoing transgender care) and who holds a Gender Recognition Certificate.

When Required by Law

We may also share Personal Data if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or to protect the rights, property, or safety of our business, our customers or others.

To Enforce Legal Rights

We may also share Personal Data: (i) if disclosure is required in legal proceedings; (ii) as necessary to protect legal rights; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.