PRIVACY NOTICE
EverWell Health Ltd
Last updated: June 2025

1. INTRODUCTION
Welcome to EverWell Health's Privacy Notice.
We understand privacy policies can be overwhelming, so we've made this one as clear, concise, and practical as possible. Your privacy is extremely important to us, and we're committed to protecting your personal data while helping you improve your health and wellbeing.
This notice explains how we collect, use, store, and protect your data when you interact with EverWell Health, whether you're using our website or app, ordering testing kits or supplements, joining a coaching programme, accessing our EverWell Connect membership, or connecting wearable devices to your account.
This privacy notice supplements any other privacy communications we may provide and is not intended to override them.

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2. WHO WE ARE & WHAT THIS NOTICE COVERS
EverWell Health Ltd (Company No. 15324141), registered in England and Wales ("EverWell", "we", "us"), is the Data Controller responsible for your personal data.
This Privacy Notice applies to all individuals who:
•    Visit our website or use our app
•    Purchase health testing kits, supplements, or products
•    Book consultations or health screening appointments
•    Join our EverWell Connect membership (including Connect Basic and Connect Business)
•    Connect wearable devices or health platforms to their EverWell account
•    Participate in digital wellness programmes or coaching services
•    Interact with us directly or via third-party partners

If you were referred to us or access our services through a partner, please also refer to their own privacy notice for how they handle your data separately.

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3. THE PERSONAL DATA WE COLLECT
We may collect, use, store, and transfer the following types of personal data:

Account Data: Name, date of birth, gender, login credentials.
Contact Data: Email address, phone number, billing and delivery address.
Financial Data: Payment card details and transaction history.
Health Profile Data: Lifestyle habits, symptoms, health goals, and answers to questionnaires and intake forms.
Blood Test & Biomarker Data: Laboratory results from blood panels processed by our approved pathology partners, together with practitioner commentary and wellness insights derived from those results.
Wearable & Device Data: Data synced from connected health platforms and wearable devices, including but not limited to: heart rate, heart rate variability (HRV), sleep stages and duration, activity levels, steps, calories, readiness or recovery scores, blood oxygen (SpO2), stress scores, body composition metrics, and menstrual cycle data where applicable. This data is collected via integrations with Garmin Connect, Fitbit / Google Health, Oura Ring, and Apple Health, accessed through our client management platform Practice Better.
Order & Usage Data: Products and services purchased, usage logs, and return history.
Programme Engagement Data: Course progress, login activity, submitted feedback, and monthly review data.
Communications Data: Emails, support messages, and marketing preferences.
Technical Data: IP address, browser type, operating system, and device ID.
Cookie Data: Usage statistics collected via cookies and tracking tools. See our Cookie Policy for more detail.

We also process aggregated and anonymised data (for example, trends across our membership) which does not identify you personally.

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4. HOW WE COLLECT YOUR PERSONAL DATA
We collect data in the following ways:
•    Direct interactions: When you create an account, complete a health profile or intake form, make a purchase, book an appointment, or contact us directly.
•    Wearable and health platform integrations: When you connect a wearable device or health app (such as Garmin, Fitbit, Google Health, Oura Ring, or Apple Health) to your EverWell account via Practice Better, data from those platforms is synced to us automatically in accordance with the permissions you grant.
•    Blood testing: When you undergo blood testing as part of an EverWell Health screening or EverWell Connect membership, your samples are processed by our approved pathology partner (currently Sussex Pathology Services or equivalent). Results are returned to us electronically and stored securely on your client record.
•    Automated technologies: Via cookies and analytics tools when you use our website or app.
•    Third-party sources: When you engage with EverWell Health via a partner, affiliate, or referral.

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5. HOW WE USE YOUR PERSONAL DATA
We only process your personal data when we have a lawful basis to do so. This includes:
•    Performance of a contract: To deliver the products, screening services, or membership benefits you have purchased.
•    Legitimate interest: To improve our services, personalise your health coaching experience, and protect our business.
•    Consent: For marketing, optional services, and wearable data integrations (you may withdraw consent at any time).
•    Legal obligation: To comply with applicable regulations, including healthcare and data protection law.

Use of Wearable & Device Data
Where you have connected a wearable device or health platform, we use that data specifically to:
•    Generate your EverWell Connect Monthly Review report, including sleep, activity, recovery, and consistency scoring.
•    Provide personalised health coaching and recommendations.
•    Track progress over time and identify trends relevant to your health goals.
•    Contextualise your blood biomarker results alongside lifestyle and activity data.

We do not use wearable data for automated decision-making that produces legal or similarly significant effects, nor do we sell wearable data to any third party.

Use of Blood Test Data
Blood biomarker results are used to:
•    Produce your EverWell Health Screening Report or monthly Connect review.
•    Support health coaching recommendations within the EverWell framework.
•    Maintain a longitudinal health record for continuity of care.

Marketing & Communications
With your consent (where required), we may send you product updates, offers, and wellness tips by email or SMS. You can opt out at any time by clicking "unsubscribe" in any email or by contacting us at info@everwellhealth.co.uk.

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6. DISCLOSURE OF YOUR PERSONAL DATA
We may share your personal data with trusted third parties who help us provide our services, including:

Practice Better: Our client management and telehealth platform, used to store client records, deliver reports, manage messaging, and facilitate wearable device integrations. Practice Better acts as a data processor on our behalf.
Sussex Pathology Services (and approved alternates): Our primary pathology partner for blood analysis. Your sample and relevant identifying information are shared solely to process and return results.
Wearable platform providers: Garmin, Fitbit / Google LLC, Oura Health, and Apple Inc. Data is pulled from these platforms with your explicit consent via their respective integration permissions. Please note that each of these providers operates under their own privacy policy.
Technology and hosting providers: Providers who support our website, app, and infrastructure.
Fulfilment and delivery providers: For physical product orders and home testing kit dispatch.
Payment processors: For secure handling of card transactions.
Analytics and marketing platforms: To help us understand website usage and reach potential clients.
Professional advisors: Such as legal or tax professionals where necessary.

All service providers and data processors are required to handle your data securely and lawfully, under appropriate contractual safeguards.

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7. THIRD-PARTY PLATFORM INTEGRATIONS & WEARABLE DEVICES
EverWell Connect members may connect one or more of the following health platforms to their account via Practice Better:
•    Garmin Connect (Garmin Ltd / Garmin International Inc.)
•    Fitbit and Google Health (Google LLC)
•    Oura Ring (Oura Health Oy)
•    Apple Health (Apple Inc.)

By connecting a wearable platform, you authorise that platform to share specified data categories with Practice Better, which then makes that data available to EverWell Health for the purposes described in Section 5.
Important points regarding third-party integrations:
•    You must consent to the integration within each platform's own app or settings. EverWell Health does not have access to your wearable data unless and until you grant that permission.
•    You may disconnect any integration at any time, either within the relevant platform's app or by contacting us. Disconnecting will stop future data syncing, but data already synced and stored in your EverWell record will be retained in accordance with Section 10.
•    EverWell Health is not responsible for how third-party platforms collect, process, or store your data within their own systems. We strongly recommend reviewing the privacy policies of any platform you connect:
•    Garmin: https://www.garmin.com/en-GB/privacy/global-privacy-statement/
•    Google / Fitbit: https://policies.google.com/privacy
•    Oura: https://ouraring.com/privacy-policy
•    Apple: https://www.apple.com/uk/legal/privacy/

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8. INTERNATIONAL DATA TRANSFERS
Some of our partners and service providers operate outside the UK. Where we transfer your personal data internationally, we do so under approved legal mechanisms, such as Standard Contractual Clauses (SCCs), to ensure your data remains protected to UK GDPR standards.
In particular, the following integrations involve international data transfers:
•    Practice Better: Based in Canada, which benefits from a UK adequacy decision for commercial data transfers.
•    Garmin: Garmin International Inc. is a US entity. Transfers are governed by appropriate safeguards.
•    Google LLC (Fitbit / Google Health): US-based. Data transfers are subject to Google's standard contractual arrangements.
•    Oura Health Oy: Headquartered in Finland (EU), with data processing infrastructure potentially outside the UK. Transfers are covered by appropriate safeguards.
•    Apple Inc.: US-based. Transfers are subject to Apple's standard contractual arrangements.
•    Sussex Pathology Services: UK-based. No international transfer occurs for blood test processing.

For international customers, your data (such as shipping details) may also be shared with couriers or customs authorities as required for delivery of physical products.

9. DATA SECURITY
We implement robust technical and organisational safeguards to protect your personal data from loss, misuse, or unauthorised access. All data transmitted between your devices, our platforms, and third-party integrations is encrypted in transit. Health data, including blood results and wearable metrics, is stored in access-controlled environments.
If a breach occurs that may impact your rights, we will notify you and the relevant supervisory authority as required by law.

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10. DATA RETENTION
We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including to:
•    Deliver our services and maintain your health record.
•    Fulfil continuity of care obligations and support future health-related requests.
•    Comply with legal, regulatory, tax, or reporting obligations.
•    Meet requirements of professional, clinical, or healthcare frameworks.

Wearable and device data synced to your EverWell account is retained as part of your longitudinal health record for the duration of your membership and for a reasonable period thereafter. If you disconnect a wearable integration, data already synced will be retained for the same period unless you request deletion (see Section 11).
Blood test results are retained in line with healthcare recordkeeping standards, which may require longer retention periods.
When your data is no longer needed, we will either securely delete it or anonymise it so it can no longer be linked to you.

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11. YOUR LEGAL RIGHTS
Under UK data protection law, you have the right to:
•    Access the personal data we hold about you.
•    Correct or update inaccurate information.
•    Request deletion of your personal data (subject to legal retention obligations).
•    Object to or restrict how we use your data.
•    Request a portable copy of your data.
•    Withdraw consent to marketing or to wearable data integrations at any time.

We aim to respond to all requests within one calendar month. If your request is complex, we may extend this period and will inform you accordingly.
To exercise any of these rights, please email us at info@everwellhealth.co.uk. We may ask you to verify your identity before processing your request.

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12. COMPLAINTS
If you believe your data rights have been violated, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at https://ico.org.uk or by calling 0303 123 1113.

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13. CHILDREN'S PRIVACY
Our services are not designed for individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe we have done so, please contact us immediately at info@everwellhealth.co.uk and we will remove the data without delay.

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14. DATA MINIMISATION
We only collect the minimum amount of personal data necessary to deliver our services. We do not collect data without a clear and documented purpose, and we do not store unnecessary information. Where wearable platforms offer granular permission settings, we encourage members to grant only the data categories relevant to their EverWell services.

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15. DATA PROTECTION OFFICER (DPO)
We have appointed a Data Protection Officer to oversee our privacy practices. You may contact the DPO with any questions, concerns, or data rights requests at:

Email: info@everwellhealth.co.uk
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GLOSSARY
App: The EverWell Health mobile application.
Controller: The organisation that determines the purpose and method of data processing.
EverWell Connect: EverWell Health's remote health membership product, which includes monthly wearable data reviews, blood screening, and coaching.
Personal Data: Any information that identifies or could identify a living individual.
Practice Better: The third-party client management and telehealth platform used by EverWell Health to store records, deliver reports, and facilitate wearable integrations.
Processing: Any action performed on personal data, including storing, analysing, or sharing it.
Sussex Pathology Services: EverWell Health's primary approved laboratory partner for blood biomarker analysis.
Wearable Data: Health and activity metrics collected via connected devices or platforms such as Garmin, Fitbit, Oura Ring, or Apple Health.

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