Privacy Notice

The privacy of your personal data is important to us and we are committed to protecting your privacy.  This notice provides you with information about how we collect and use your personal data when you interact with us, including any data you may provide when you:

• visit our website (https://marleyhealth.com) (Website);
• use our applications;
• apply for a job with us;
• participate in one of our research projects (Research Project);
• subscribe to receive updates, newsletters of other information from us;
• request information from us or provide information to us; or
• supply goods or services to us (or you work for an organisation that does).

This notice also applies to Shareholder Data that we might process (as described below). 

The Website and our applications are not for children and we do not knowingly collect the personal data of children.

1. Important information about us

Marley Health Ltd (company number 16206956) (Marley Health, we, our or us) is the controller of, and therefore responsible for, your personal data.

If you have any questions about this notice, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 11).

2. 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, age, images / video snippets, username, title, job title, information about your pet (such as type, name and breed), as well as organisation details.
• Contact Data includes address, email address and telephone number.
• Research Data includes data collected as part of the Research Project such as breed, habits / routines, experience / areas of expertise, preferences, feedback and research responses.
• 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 our Website and our applications.
• Profile Data includes your username and password.
• Usage Data includes information about how you interact with and use the Website and our applications.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
• Shareholder and Investor Data includes information relating to our actual, potential or former individual shareholders and investor, as well as representatives of institutional or corporate shareholders and investors of us, which may include details of your participation in our affairs as an individual shareholder or representative of an institutional or corporate shareholder (as applicable) or investor, such as attendance at and contribution to meetings, voting records etc, details of your respective shareholdings and or investments and any other information which is required to be recorded about you as a shareholder and or investor by law or which we hold in relation to your current or former shareholding or investment or which we may acquire in connection with any discussions relating to potential shareholding or investment.
• Candidate Data includes, if you are applying for a role with us, the information you have provided to us in your curriculum vitae and covering letter, the information you have provided on our application form, including education history, qualifications and employment history; any information you provide to us during the course of your application and any interview process, as well as information obtained from sources other than yourself.

We do not collect Special Categories of Personal Data  (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) and Criminal Offence Data (this includes confirming that you do not have a criminal record) about you except in limited circumstances.  For example, when you apply for a job (if you have any particular access requirements or we need to confirm that you do not have a criminal record before offering you a job with us). Your provision of such data would indicate your consent to us using the data for the relevant purpose.  Where we are required to do so by law, we have in place an appropriate policy document and safeguards.

We (and service providers that we use) may 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 the Website or our applications to help improve the Website or applications. We, or our service providers, may collect and aggregate individuals’ Usage Data in an anonymised form to assess how features that are provided are used and make service improvements and for other business purposes. In some circumstances we also may have access to and use anonymised data from which we cannot identify any individuals.

3. How is your personal data 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 / applications etc, by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you interact with us as set out above.
• Automated technologies or interactions. As you interact with the Website or our applications, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Notice for further information.
• Third parties. We will receive personal data about you from various third parties as set out below:
• Technical Data is collected from the following parties:
  • analytics providers;
  • advertising networks; and
  • search information providers.
• Candidate Data is collected from recruitment agencies, background check providers, credit reference agencies, your named referees.
• Contact Data is collected from providers of technical services.
• Identity and Contact Data is collected from publicly available sources such as Companies House and social media platforms such as LinkedIn.

4. 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:

• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests. 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.

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

We may ask you to indicate your preferences for receiving direct marketing communications from us via email (for example, on the Website or when you initially sign up to participate in a Research Project with us).

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 (we are either sending you direct marketing communications because you have asked us to send you such communications or we are otherwise legally allowed to send you such communications).

Third-party marketing

We will not share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask 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 us.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative purposes for example relating to updates to our privacy notice.

5. Disclosures of your personal data

We may also share your personal data with the following third parties in accordance with this privacy notice, including:

• Vendors and service providers who support our respective operations, such as providing research services, IT and system administration services, hosting services for any of our applications, service support, email delivery and administration, and data storage and analysis.
• Our professional advisors, including lawyers, auditors and insurers who provide legal, accounting, insurance and other services.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets (or with whom we may discuss any such activities) or who may wish to invest in our business. 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 notice.
• Shareholders and investors who we provide with information as part of our reporting activities.
• Government and other law enforcement agencies and regulatory bodies (including HMRC) to comply with applicable laws and regulatory requirements.

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.

6. International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf, as well as other third parties who we may share your personal data with. This may involve transferring personal data outside the UK (for example, to Ireland) to countries which have laws that do not provide the same level of data protection as the UK law.

When we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

• We will only transfer your personal data to countries that have been deemed by the UK government to provide an adequate level of protection for personal data; or
• We may use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK. To obtain a copy of these contractual safeguards, please contact us using our contact details below (Paragraph 10).

7. 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.

8. 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.

In some circumstances we will 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.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal information.

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 data 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.
• 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. 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. If we intend to rely on legally permitted reasons not to comply with your request, we will explain this to you.

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 a number of requests. In this case, we will notify you and keep you updated.

10. COOKIES

For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Notice.

11. Contact details

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

• Email address: admin@marleyhealth.com
• Postal address: 125 Wood Street, London, United Kingdom, EC2V 7AW

12. Complaints

You have the right to make a complaint 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.

13. Changes to the privacy NOTICE and your duty to inform us of changes

We keep this notice under regular review.

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.

14. Third-party links

The Website and our applications 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 the Website or our applications, we encourage you to read the privacy policy of every website you visit.

Last updated: January 2026