Privacy Policy

Who we are and what we do

SH:24 respects your privacy and is committed to protecting your personal data.

This privacy policy will inform you as to how we look after your personal data and sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Your visit to SH:24 or fettle.health is collectively referred to as the “Site” and is subject to the terms set out in this privacy policy.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

SH:24 Community Interest Company is the data controller and responsible for your personal data (collectively referred to as “SH:24”, “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our DPO Matt Spall on ms@dpocentre.com or telephone 44 (0) 203 797 1289.

Information we may collect from you

Personal data, or personal information, means any information about an individual from which that person can be identified, whether directly or indirectly.

It does not include data where the identity has been removed (anonymous data).

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

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Health Data includes any information about your physical health including your medical history and/or current health status including but not limited to sexual history, data regarding test results, diagnoses and medications.
  • Financial Data (if applicable) includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and Services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, 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 this Site.
  • Usage Data includes information about how you use our Site, products and services.
  • Feedback Data includes information relating to your use of the Site or services.We also collect, use and share aggregated data such as statistical or demographic data for any purpose, but only where such data is anonymous. Data is considered to be anonymous where you cannot be identified (whether directly or indirectly).

For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect, use and / or share any of your personal data for marketing purposes.

Keeping your data secure

We know that data security is important to you and it is therefore important to us.

We have put in place appropriate security measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage of your personal data.

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 in accordance with this policy and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We use SMS (text messaging) a lot. We think it’s the best and most private way to keep you up to date with the progress of your order with us, whether it’s for STI testing, contraception or support and advice.

Most phone handsets provide a preview of incoming SMS on receipt - be aware that this may make your interaction with SH:24 visible to people around you.

However, it is possible to adjust your phone’s settings to prevent SMS previewing – very easy to change on most handsets. Learn more by visiting:

  • iPhone
  • Android
  • You may also wish to periodically delete your SMS history with us, just in case you lose your handset.

How we will collect your data

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

Direct interactions

You may give us any of the categories of data identified above by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise. This includes personal data you provide when you:

  • register to use our Site;
  • make a request for our products or services;

Automated technologies or interactions

As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns.

We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Please see our cookie policy for further details.

Contact, Financial and Transaction Data (if applicable) from providers of technical, payment and delivery services such as Stripe (or similar third party payment processors) based inside the EU.

Identity and Contact Data from data brokers or aggregators such as Google Analytics and Kissmetrics (or similar organisations) based inside the EU.

Why we will use your data

The lawful basis for processing are set out in Article 6 and 9 of the General Data Protection Regulation (GDPR), as amended in the UK following the UK’s withdrawal from the European Union.

We may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data.

Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

At least one of these must apply whenever we process personal data:

Consent: you have given clear consent for us to process your personal data for a specific purpose.

Contract: the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.

Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).

Vital interests: the processing is necessary to protect someone’s life.

Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.

Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests.

Healthcare provision: the processing of data concerning your health is necessary for us to provide you with a medical diagnosis and/or healthcare treatment.

Public Interest The use is necessary for reasons of public interest in the area of public health, such as ensuring high standards of quality and safety of health care.

Research The use is necessary for public interest or scientific research purposes so long as it is subject to appropriate safeguards.

For more information on how we process your personal data and what lawful basis we rely on please see the table below.

ReasonLawful BasisAdditional legal basis for special categories of personal data

Handling an initial request for a test kit and/or other services provided by SH:24.

The use is necessary in order to take steps so that you can enter into a contract with us for the delivery of healthcare.

The use is necessary for fulfilling our legitimate interests (e.g. an appropriate business need) and those interests are not overridden by your privacy rights.

This is necessary to provide you with a medical diagnosis and/or healthcare treatment.

Processing information about your sexual or medical history

The use is necessary in order to take steps so that you can enter into a contract with us for the delivery of healthcare.

The use is necessary for fulfilling our legitimate interests (e.g. an appropriate business need) and those interests are not overridden by your privacy rights.

This is necessary to provide you with a medical diagnosis and/or healthcare treatment.

Providing healthcare (or health assessment) and related services.

This is necessary to provide you with a medical diagnosis and/or healthcare treatment.

This is necessary to provide you with a medical diagnosis and/or healthcare treatment.

Seeking and receiving payment of fees

The use is necessary to fulfil our contract with you for the provision of health assessment services, care and/or treatment.

The use is necessary for fulfilling our legitimate interests (e.g. an appropriate business need) and those interests are not overridden by your privacy rights.

Administration and management of healthcare services (such as maintaining records including patient medical records, receiving professional advice, and sharing your information with your GP where relevant).

The use is necessary for fulfilling our contract with you for the delivery of healthcare.

The use is necessary for fulfilling our legitimate interests (e.g. an appropriate business need) and those interests are not overridden by your privacy rights.

This is necessary to provide you with a medical diagnosis and/or healthcare treatment.

Communicating with you and resolving any queries or complaints that you might have, including responding to any data subject rights.

The use is necessary for fulfilling our contract with you for the delivery of healthcare.

The use is necessary for fulfilling our legitimate interests (e.g. an appropriate business need) and those interests are not overridden by your privacy rights.

The use is necessary for the purposes of preventive or occupational medicine, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services.

The use is necessary in order for us or a third party to establish, exercise or defend our legal rights.

Clinical research and development

The use is necessary for fulfilling our legitimate interests (e.g. an appropriate business need) and those interests are not overridden by your privacy rights.

You have given us your consent.

We need to use the information for reasons of substantial public interest, public interest in the area of public health, such as ensuring high standards of quality and safety of health care.

The use is necessary for public interest or scientific research purposes so long as it is subject to appropriate safeguards.

You have given explicit consent.

Complying with our legal and regulatory requirements including investigating complaints or claims and defending or exercising our legal rights.

The use is necessary for compliance with a legal obligation.

The use is necessary for fulfilling our legitimate interests (e.g. an appropriate business need) and those interests are not overridden by your privacy rights.

This is necessary to provide you with a medical diagnosis and/or healthcare treatment.

The use is necessary in order for us to establish, exercise or defend our legal rights.

Provision of feedback to help us improve our services.

The use is necessary for fulfilling our legitimate interests (e.g. to help us improve our service) and those interests are not overridden by your privacy rights.

Click here to find out more about the types of lawful basis that are available to process your personal data.

Disclosing your personal data

We may have to share your personal data with the parties below in order to provide our services to you.

We require all third parties 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.

Examples of our third parties include:

a. Sub-contractors for the performance of any contract we enter into with them or you (for example, distributors who may deliver test kits);

b. Local authorities/public services;

c. NHS bodies;

d. Accredited pharmacies (the dispensing of the medicines is performed directly by our accredited pharmacies to you);

e. Academic institutions for research purposes;

f. Service providers acting as processors who provide IT and system administration services.

We transfer personal data from the UK to the EEA, which the UK government has recognised as adequate for the purposes of the UK implementation of the GDPR. We may also transfer personal data from the UK to the US on the basis of the EU approved standard contractual clauses.

Cookies

Consider whether you want a digital log of your visit to sh24.org.uk to be recorded in your browser.

If you don’t want a record to be kept, you can choose to delete your browser history afterwards or view our pages in incognito mode / private browsing, which won’t store your browser history, cookies, or search history after you’ve closed your browsers. However, you are not invisible.

Using incognito mode / private browsing does not hide your browser history from your internet service provider, SH:24 or your employer (if you are using a company device).

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.

If you disable or refuse cookies, please note that some parts of this Site may become inaccessible or not function properly.

For more information about the cookies we use, please see cookies.

Change of purpose

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How long we will keep your data

We will only retain records in accordance with the minimum periods required by law, NHS directions, orders and guidance, and guidance published by the British Association for Sexual Health and HIV. This means that we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our records management policy which you can request from us by contacting us.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please Contact us.

No fee usually required

You will not 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 of £10 if your request is clearly unfounded, repetitive or excessive.

Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

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.

The right to lodge a complaint with a supervisory authority

If you have concerns about our information rights practices you can contact the Information Commissioner’s Office (ICO) at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.

Email: casework@ico.org.uk.

Website: https://ico.org.uk/make-a-complaint/