1. Who is responsible for your information
Valixe is the name used for this website and patient platform. The legal operator below is responsible for the personal information it controls. In this policy, “we”, “us” and “our” refer to that operator.
- Legal operator
- Valixe Healthcare
- Business address
- [Business address]
- Privacy contact
- [Privacy contact email]
- Data protection lead
- [Data protection contact; DPO details if required]
- ICO registration
- [ICO registration reference, or confirmed exemption]
A doctor or clinical provider and a dispensing pharmacy may have their own responsibilities as separate controllers of clinical or dispensing records. Their roles and privacy information must be provided when they are involved in your care.
To complete before launch: confirm the legal operator, contact details, whether a data protection officer is required, and the controller or processor roles of each clinical and pharmacy provider.
2. What this policy covers
This policy covers the Valixe website, registration and patient account, health assessments, doctor review, treatment orders, payment records, progress tracking, photos, private messages and aftercare requests.
It also covers information you send through our contact routes. Please read any separate privacy notice provided by a doctor, pharmacy or payment provider for information they process under their own responsibility.
This draft describes the proposed service. The final policy must match the information actually collected and the providers used when live patient services begin.
3. The information we collect
- Account and contact details: your name, email address, account credentials, verification status and contact or delivery details you provide.
- Assessment and health information: your age or date of birth, height, weight, medical history, current conditions, medication, previous treatment, goals and answers to health questions.
- Clinical and treatment records: review outcomes, requests for further information, prescription details and relevant aftercare updates.
- Progress records: weight entries and photos you upload to your patient account.
- Messages and enquiries: information you share with the care team, including support requests, complaints and correspondence.
- Orders and payments: selected or approved products, order references, amounts, payment status, transaction references and dispatch or delivery updates.
- Technical records: relevant website and account activity, session information, IP addresses, browser information and security or error logs, where collected by the configured service.
Health information and photographs used to assess or monitor health may be sensitive health data. Do not send more information than is needed for your care or enquiry.
To complete before launch: check the live forms, uploaded-file metadata, logs, payment integration and website trackers against this list. Explain any additional collection before it happens.
4. Where information comes from
Most information comes directly from you when you register, complete an assessment, place an order, upload a photo, track your weight or contact us.
We may receive review and prescription information from the doctor, dispensing and dispatch updates from the pharmacy, payment confirmations from the payment provider and delivery updates from the carrier. Only relevant information should be shared for these purposes.
If information is obtained from another source, we will explain that source and its use as required by law. Any information obtained from another healthcare provider must have an appropriate lawful basis and any necessary authority.
5. How we use your information
- Set up, verify and manage your patient account.
- Coordinate your assessment and provide relevant information for doctor review.
- Manage approved treatment orders, payments, dispensing and delivery.
- Provide progress tools, private messages, aftercare and repeat-treatment requests.
- Respond to enquiries, investigate complaints and resolve order problems.
- Protect accounts, investigate misuse and maintain the platform.
- Meet applicable record-keeping, accounting and legal obligations.
We will not use health records or progress photos for an unrelated purpose merely because you have provided them for care. Any new use needs an appropriate lawful basis and clear information about that use.
6. Our lawful bases for processing
Each use of personal information needs a lawful basis under Article 6 of the UK GDPR. Where information reveals your health, we also need a separate applicable condition under Article 9. Creating an account or accepting terms is not, by itself, explicit consent to every use of health information.
| Purpose | Article 6 basis to confirm | Additional detail |
|---|---|---|
| Account access and requested services | Contract, where necessary to perform the service you request | Identify which controller provides the service and which data is necessary. |
| Assessment, doctor review and aftercare | [Confirm the applicable basis for each provider] | [Confirm Article 9 condition and any applicable UK-law requirements.] |
| Orders, payment and delivery | Contract; legal obligation for specific required records | Limit pharmacy and carrier sharing to what is necessary; apply an Article 9 condition where health is revealed. |
| Security, support and complaint handling | Legitimate interests where appropriate; legal obligation where required | Document the specific interest, necessity and balancing assessment. Health information also requires an Article 9 condition. |
| Optional marketing or optional tracking | Consent where required | Explain the separate choice and how to withdraw it. Confirm any other lawful basis or exemption before relying on it. |
Where properly applicable, the health or social care condition in Article 9(2)(h) may support healthcare processing subject to the required confidentiality and UK-law conditions. It must not be assumed to apply to all platform staff or every use. If explicit consent under Article 9(2)(a) is used instead, we must obtain and record it separately and explain withdrawal.
To complete before launch: replace this draft map with the chosen and documented bases, the relevant Article 9 conditions, any required safeguards and the specific legitimate interests relied upon.
8. Payment information
The current payment integration uses Stripe. At checkout, payment information is processed through the configured payment service. Valixe uses order and transaction information to confirm payment, update orders and handle refunds or payment queries.
The payment provider's own privacy information also applies to processing it performs as a separate controller. Read Stripe's Privacy Policy for its details.
Do not send card numbers or security codes in patient messages. The final policy must accurately describe any payment details or identifiers retained by Valixe after checkout.
9. Progress photos and private messages
Photos uploaded through your patient account are for your care and progress records. They are not a public profile or website gallery. Relevant records may be accessed by authorised people involved in your care, in accordance with their role.
Uploading a photo for care does not authorise its use in advertisements, testimonials or social media. Any proposed marketing use would require separate, specific permission.
Private messages and aftercare requests can contain sensitive information and form part of your service records. Keep them relevant to your query. They are not an emergency service.
10. How information is protected
Health records require appropriate technical and organisational safeguards. Access should be limited to authorised users and relevant purposes, and providers handling data on our behalf must have appropriate contractual safeguards.
Keep your password private, sign out on shared devices and tell us if you suspect unauthorised access. We will investigate reported security concerns and meet applicable incident-reporting duties.
No website can promise that all security risks are eliminated. This policy does not make an unverified claim about certification or compliance.
To complete before launch: verify the actual access controls, storage protections, backups, logging and incident procedures before describing specific security measures in the final notice.
11. Where information is processed
Our hosting and other suppliers may process information in locations determined by their service arrangements. We must identify these locations, including overseas support access, before collecting live patient information.
If personal information is transferred outside the UK, we must explain the destination and applicable protection. Where required, this includes a recognised adequacy arrangement or appropriate contractual safeguards and the necessary transfer assessment.
You can ask the privacy contact for information about applicable transfer safeguards.
To complete before launch: [Supplier locations, overseas access, transfer mechanisms and how safeguards can be obtained.]
12. How long we keep information
Different records serve different purposes. We must keep information only for as long as necessary for the relevant service, clinical, accounting or legal purpose, then delete or anonymise it appropriately.
| Record type | Retention period or criterion |
|---|---|
| Account details and unsuccessful or abandoned registrations | [Confirm duration, trigger and deletion process.] |
| Assessments, clinical decisions, prescriptions and aftercare records | [Confirm clinical retention rules, provider responsibilities and when the period starts.] |
| Weight entries and progress photos | [Confirm whether these form part of the clinical record and the applicable duration.] |
| Patient messages, support enquiries and complaints | [Confirm duration for each record category.] |
| Orders, transaction and accounting records | [Confirm statutory and operational retention periods.] |
| Technical logs and backups | [Confirm log duration, backup rotation and handling after deletion.] |
Closing an account does not necessarily require immediate deletion of records that must lawfully be retained. Where a record is needed for a legal claim or other lawful retention reason, we will apply the relevant requirements and restrict unnecessary use.
13. Your choices and rights
Depending on the processing and the applicable law, you may have rights to:
- Access your personal information and receive a copy.
- Correct inaccurate information and complete relevant incomplete records.
- Request deletion or restriction where the legal conditions apply.
- Object to processing based on legitimate interests, and object to direct marketing.
- Receive certain information in a portable format where the right applies.
- Withdraw consent where consent is the basis for processing.
These rights are not all unconditional. For example, lawful clinical record-retention requirements may affect a deletion request. We will explain any applicable limitation and respond within the legal timeframe.
Contact the privacy contact or use our contact page to make a request. We may need proportionate information to confirm identity before releasing sensitive records; do not send identity documents unless requested through an appropriate route.
Withdrawing consent does not affect processing carried out lawfully before withdrawal. If a service cannot continue without information processed on that consent, we will explain the practical effect. Refusing optional marketing does not prevent access to care.
14. Messages, marketing and cookies
Account verification, password resets and assessment or order updates are service communications. They are distinct from promotional messages.
If optional marketing is offered, we will explain the choice and the applicable basis. You can stop marketing through the unsubscribe option or by contacting us. We must not treat consent to receive marketing as consent to use health information for advertising.
The website may use cookies or similar technologies for sessions, security or other configured features. The final cookie information must identify the actual technologies, purposes, providers and durations, and provide any legally required choices.
To complete before launch: audit cookies, analytics, advertising tags and email marketing. Confirm any consent requirements or applicable exemptions and implement the required controls; this page alone does not provide them.
15. Clinical decisions and automation
The proposed prescribing pathway includes review by a doctor. A product selection, payment, account status or automated notification is not itself a clinical approval.
Any future use of profiling, AI or automated decision-making must be assessed and explained before implementation, including any relevant effect on you and the safeguards or rights that apply. This notice does not authorise an undisclosed automated use of patient records.
16. Children and young people
The proposed weight-management service is intended for adults aged 18 or over. It is not designed for children to create accounts or submit treatment requests.
If you believe a child has submitted personal information, contact us so that we can investigate and determine the appropriate action and any lawful record-handling requirements.
17. Questions and privacy complaints
Contact the privacy contact shown above or use our contact page if you have a question or concern about information handled by Valixe.
You can also complain to the UK Information Commissioner's Office. Visit ico.org.uk/make-a-complaint for its current complaint process. Contacting us first may help resolve a concern, but does not remove your right to contact the regulator.
For records controlled separately by a clinical provider or pharmacy, their privacy contact and notice may also be relevant. We will help identify the appropriate organisation where possible.
18. Changes to this policy
We will update this policy when our processing or legal requirements change. The version and date at the top identify the notice you are reading.
Material changes will be communicated as appropriate. A policy update alone does not provide consent for a new purpose or remove your rights.