Privacy Policy

This policy covers:

1. Important information and who we are
2. Types of personal data we collect about you
3. How your personal data is collected
4. How we use your personal data
5. Direct Marketing
6. Information we obtain indirectly: Prospecting Letters
7. Disclosures of your personal data
8. International transfers
9. Data security
10. Data retention
11. Your legal rights
12. Contact details
13. Complaints
14. Changes to the privacy policy and your duty to inform us of changes
15. Third party links
16. Important information and who we are

Important information and who we are

This privacy policy gives you information about how Bluecrest Wellness collects and uses your personal data through your use of this website, including any data you may provide when you sign up to our newsletter, purchase a product or service, or take part in a competition or research project.

This website is not intended for children, and we do not knowingly collect data relating to children.

Controller

Bluecrest Health Screening Ltd (trading as Bluecrest Wellness) is the controller and responsible for your personal data (collectively referred to as "Bluecrest", "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 (paragraph 9), please contact the DPO using the information set out in the contact details section (paragraph 10).

The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

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

• Identity Data includes first name, last name, any previous names, username or similar identifier, title, date of birth, and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data 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.
• Health and medical information includes health information you willingly provide about yourself (such as through questionnaires or correspondence with our team), information physically collected through your health assessment, and information obtained from your health assessment results (from our pathology and cardiology providers).
• 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, device ID and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

How your personal data is collected

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

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;

• create an account on our website;

• use our services or publications;

• subscribe to our service or publications;

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us feedback or contact us.

• Providing our services. We collect health information about you as part of providing our health assessment services. This may be through physical measurements (such as height and weight) or through processing of samples by our partners (pathology and cardiology providers).

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, 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.

• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

• Technical Data is collected from the following parties:

• analytics providers, such as Google based inside the UK;

• advertising networks, such as Meta, based inside the UK; and

• search information providers, such as Google and Bing, based inside the UK.

• Identity and Contact Data is collected from data brokers or aggregators based in the UK. Our current contracted third-party suppliers of name and address data are listed below. Click on each one for more information.

• Epsilon Abacus (registered as Epsilon International UK Ltd)

• CACI Limited

• Experian

• DBS Datamarketing (DBS)

• Identity and Contact Data is also collected from publicly available sources such as Royal Mail partially addressed mailing lists. No personally identifiable information is provided as part of this. Where Bluecrest services are provided as part of your corporate benefit scheme, Identity and Contact Data may be collected directly from your employer. This data is collected on an opt-in basis only.

How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performing a contract: Where we need to perform the contract we are about to enter into, or have entered into, with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter or expressly consent to tailored communications based on your health information.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of 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.

Direct Marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting our Customer Service Team.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations for a purchase, appointment reminders, updates to our Terms and Conditions, checking that your contact details are correct.

Cookies For more information about the cookies we use and how to change your cookie preferences, please see https://www.bluecrestwellness.com/cookie-policy.

Information we obtain indirectly: Prospecting Letters
Bluecrest works with third-party data suppliers who provide us with name and address information for us to send marketing letters for promotional purposes. Bluecrest rely upon its legitimate interests as our lawful basis for processing your data. Specifically, for our legitimate interests to market our services effectively, develop new services, keep records updated and inform general marketing strategy. We only process information about you where it has been permissioned fairly and the level of processing does not override your rights. We have carried out a Legitimate Interest Impact Assessment to carefully consider this. We do not rely on consent for processing personal data to send prospecting letters.

The data mailing file is shared with our printer solely for the purposes of sending an invitation letter to you. Within 30 days of receipt of the mailing file, and the completion of the direct mail print job, the file is deleted. It is not used for any other purpose, sold to, or shared with any additional third party.

Our current contracted third-party suppliers of name and address data are:

• Epsilon Abacus (registered as Epsilon International UK Ltd)
• CACI Limited
• Experian
• DBS Datamarketing (DBS)

You can learn more about how our partners obtain and process your personal information at the details provided below where you can also ask to be removed from their data set.

Epsilon Abacus (registered as Epsilon International UK Ltd)

• Epsilon Abacus manage lists and prospect pools on behalf of UK retailers and charities. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, home interiors and travel categories. These retailers and charities share information about their customers and supporters and what they buy or donate. Our partners process this information as a processor on behalf of these companies to help them understand individuals’ behaviour and preferences. Information provided by participating retailers and charities is combined with third party data and from this combined information, these companies can tailor their communications, sending individuals suitable offers and appeals that should be of interest to them.
• Epsilon Visit: https://abacus.epsilon.com/services-privacy-policy Email: nomail@epsilon.com Phone: 020 8943 8049

CACI Limited

• CACI Limited provide marketing and analytical services to consumer brands to help them effectively market their products and services. CACI’s main data set is called Ocean, which uses names and addresses of consumers living in the UK based on the edited Electoral Register. CACI also obtain names and addresses from partners who collect data directly from consumers for marketing purposes. In these instances, CACI is named as a partner with whom the data is shared. CACI does not collect personal data directly from consumers for marketing or any other purpose.
• CACI Limited Visit: www.caci.co.uk/data-proivacy/consumer-information Email: compliance@caci.co.uk

Experian

• Experian manage lists and prospect pools on behalf of UK retailers and charities. The participating retailers are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, home interiors and travel categories. These retailers and charities share information about their customers and supporters and what they buy or donate. Our partners process this information as a processor on behalf of these companies to help them understand individuals’ behaviour and preferences. Information provided by participating retailers and charities is combined with third party data and from this combined information, these companies can tailor their communications, sending individuals suitable offers and appeals that should be of interest to them.

• We collaborate with Experian Marketing Services to identify potential customers who might be interested in our products. To achieve this, we may develop a profile using demographic information, which we then share with Experian Marketing Services. They utilise this data to select prospective customers based on the permissions they have and compile a mailing list for us. For more details on how Experian’s Marketing Services business acquires and processes your personal data, please visit their Consumer Information Portal

• Experian Visit: www.experian.co.uk/cip Email: customerservices@uk.experian.com Phone: 0115 828 6738

DBS Datamarketing (DBS)

• DBS Datamarketing Limited is a marketing services provider that supports businesses with their marketing and customer engagement strategies. Their services help us/clients gain deeper insights into existing customers and connect with new, relevant audiences in a responsible and ethical manner. They source, process, and manage consumer data in compliance with data protection laws, ICO codes, and the Data & Marketing Association’s Code of Practice. As thought leaders in data protection, they place data subjects’ rights and information privacy at the core of their operations. DBS Data collects data from a variety of sources from the public domain and from consented online and offline lead generation and surveys. Contributors of consented data collect permissioned data compliant with all applicable laws, regulations and guidelines surrounding the use of third party data. For more details on how they handle and process data, please refer to their Privacy Policy.

• DBS Datamarketing Visit: www.dbsdata.co.uk/trading-business-and-consumer-data Email: complianceteam@dbsdata.co.uk

Address-only data

Our current contracted third-party supplier of address-only data is Royal Mail MarketReach. MarketReach are part of the Royal Mail Group. They publish research and market insights, and give best-practice advice to brands. They supply Bluecrest with addresses of prospective customers who live in the areas we are holding our health check events.

If you have received a letter invitation from Bluecrest which did not have your name on the envelope, your address would have been supplied to us by MarketReach. MarketReach do not provide any information to Bluecrest other than an address, which is why the mailing is unpersonalised.

Accuracy of the data

To ensure the data is as accurate as possible, data is cleaned against Royal Mail Postal Address File and matched against registers of individuals who have moved house, died, registered with the Mailing Preference Service or been added to our internal suppression file. Data suppliers also provide regular (monthly) updates, refreshes and suppressions of their data to comply with UK GDPR. We only keep your personal details for as long as is necessary, or as long as you wish.

Opting out of prospecting letters

You can opt-out of receiving prospecting letters at any time at any time by contacting our Customer Service Team.

If you would like information about where obtained your data from, please contact our Data Enquiries Team at dataenquiries@bluecresthealth.com.

Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above.

• External Third Parties:

• Service Fulfilment Providers

• Health: These are UK based organisations which provide health results to allow us to deliver services. They fall into three further sub-categories: Pathology, Cardiology, and GP services. For our customers in Republic of Ireland (ROI), the pathology provider is based in ROI.

• Customer Service: These are UK based organisations who support our Customer Service Contact Centre.

• Printing: These are UK based providers who print results reports (where requested by the customer) and send our letters.

• 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 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.

International transfers

We do not transfer your personal data outside the UK.

For customers based in Republic of Ireland, your data is processed by our pathology provider in ROI and data is transferred to the UK for fulfilment. No further transfer outside the UK occurs.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 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.

Data retention

How long will you use my personal data for?

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, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see ‘your legal rights’ below for further information.

Your legal rights

You have several rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "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 to us.
• Request erasure of your personal data in certain circumstances. 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) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. 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 (see the table for details of when we rely on your consent as the legal basis for using your data). 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.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of 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; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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

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 if your request is clearly unfounded, repetitive or excessive. Alternatively, we could 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 could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Health Research We may use anonymised health and medical data for research purposes. Where applicable, we will fully anonymise your personal data (so that it can no longer be associated with you). This anonymised data may be used for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

We may partner with other organisations (such as universities or other health providers) to complete this research. Where research is published, it is fully anonymised.

Contact details

If you have any questions about this privacy policy, about the use of your personal data, or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: dataenquiries@bluecresthealth.com
• Postal address: Data Enquiries, Bluecrest Wellness, 1st Floor, Ridgeworth House, 5 – 9 Liverpool Gardens, Worthing, BN11 1RY

You can contact our DPO directly at dpo@bluecrestwellness.com

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (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.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. You are therefore advised to re-read this policy on a regular basis.

This version was last updated on 2 June 2025. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.