Privacy Policy

1. Introduction

‏‎Welcome to our Privacy Policy.

Roczen Ltd. (Company number: 13251035), registered at One Fleet Place, London, EC4M 7WS, is a wholly owned subsidiary of Reset Health Limited

Roczen is a trading name of Reset Health Limited, a private limited company (Company No. 12111885) incorporated in England. Our principal place of business is at 7-8 Stratford Place, London W1C 1AY. In this Privacy Policy, we refer to ourselves as "Roczen", "us", "our" or "we".

Roczen is the data controller in relation to your personal data.

We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you how and why we collect your personal data, how we look after your personal data, and about your privacy rights and how the law protects you.

This Privacy Policy explains how we collect and process your personal data when you:

visit our website or use Roczen mobile apps;
contact us directly;
use or subscribe to any of our services or products (including attending any pre-treatment or pre-enrolment screenings); and
sign-up to receive updates and newsletters from us.

This website, and the services we offer, are not intended for children. We do not knowingly collect data about children. If you become aware that we may have been given data about a child, please contact us as soon as possible.

It is important that you read this Privacy Policy together with any other privacy policy or privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

2. The data we collect about you

‏‎‎Personal data, or personal information, means any information about an individual from which that person can be identified. 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 which we have grouped together as follows:

Identity Data - Name and contact details, date of birth, age, gender;
Bank and payment/transaction details details

Health Data: Body measurements (e.g. weight, height, waist circumference), BMI, blood pressure, disabilities, current illnesses/conditions (e.g. Type 2 Diabetes, high blood pressure, etc), current medications/dosages), medical information held by your GP/doctor or the NHS in your medical file, dietary and nutritional information, race and ethnicity, psychological wellbeing (including information about psychiatric disorders and conditions, such as, depression, bipolar disease and eating disorders), physical wellbeing (e.g. lifestyle, exercise habits, quality of life, personal preferences), other health and related data provided by you in group settings;
GP contact details
Live video call footage (when you participate in a screening, appointment or consultation with one of our healthcare professionals through video call) (this is only viewed by the relevant Roczen professional during a screening, appointment or consultation in which you are participating, solely for the purpose of conducting that call; we do not record this footage);
Technical Data - IP Address, login data, browser details, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technologies on the devices you use to access this website;
Profile Data - Username and password, order details, your interests, preferences, feedback and survey responses;
Usage Data - Website usage details, mobile apps usage details, how you use our products and services;
- Note that this usage data also includes your interactions and feature usage, in-app guidance usage (such as tooltips and walkthroughs), user behaviour and custom metadata, in-app feedback via surveys and polls, and analytics around how new features are working for our users.
Marketing and Communications Data - Your preferences in receiving marketing from us and our third party partners, and your communication preferences.
Shared information: other personal data shared by you to us (e.g. within a voluntary peer group setting, your name may be displayed to the group)

‍We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Health Data with the Health Data of other customers of Roczen in order to better understand Type II Diabetes Mellitus, Metabolic Syndrome and obesity, and how to treat these conditions. This aggregated data may be used in medical publications and research showing the effectiveness of Roczen treatments in different groups and demographics of people. 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.

You have the option to opt out of platform-based tracking. To do so, please email support.uk@roczen.com.

‏‏If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

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

‏‎‎a) Direct interactions:

You may give us your Identity Data, Bank and payment/transaction details, Health Data, GP Details, Video Data and Marketing and Communication Data by using our mobile apps, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

apply for or purchase our products or services;
download and use Roczen’s mobile apps;
create an account on our website;
complete any forms or questionnaires;
attend or participate in a screening, consultation or appointment (in person or via video call);
subscribe to our publications or marketing; or
give us feedback or contact us.

‏‏‎ ‎b) Third parties:

We may obtain your Identity Data, Health Data, Usage Data, and GP Details from third parties that have referred you to us or who disclose your information to us, as set out below:

When you are referred to us by your GP/doctor, or other healthcare professional;
EMIS Health, who provide us with a clinical management software that allows us to access your summary care records (where you consent to this). EMIS obtains your summary care records through NHS Spine;
Where you provide consent for us to access your Health Data and other information directly from your GP/doctor or other healthcare professional;
Where you are referred to us by one of our corporate partners (e.g. where you are an employee / staff member of the relevant corporate partner, and you have asked that corporate partner to refer you to us);

c) Automated technologies and interactions:

As you interact with our website and apps, we will automatically collect Technical Data and Usage Data about your devices, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

Roczen may supplement the information that you provide to us, or which we are given, with information that we receive or obtain from other sources, such as from our professional advisors, partners, and agents of Roczen, third parties with whom we interact, and publicly available sources.

‏‏‎ 4. Purposes for which we use your personal data

‏‏‎ ‎We have set out below a description of all the ways we plan to use your personal data and which legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need further details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out, for the purposes below:

a) To provide you with our products and service

We will process your personal data where you have purchased, or are enquiring about purchasing, our products and services. This is so that we can provide you with the requested product or service, or with the information you have requested about such product or service.

Our services focus mainly on providing metabolic membership programmes designed for people living with obesity, Type 2 Diabetes, and other metabolic syndrome complications. In order to provide these services we will process personal data both (i) during the assessment, triage and diagnostics stages, and thereafter (ii) during the treatment and monitoring stages.

In practice, personal data processing will occur when you use our mobile apps (as explained below), when you provide us with information about yourself as part of pre-treatment assessment and diagnostics, when you allow us to obtain your medical information from your GP or health professional, when you attend screenings, consultations and appointments with one of our professionals, when you provide us feedback via a peer group, and when you are completing a treatment plan or programme.

We will also process your data for the purposes of (i) managing any payments, fees and charges, and (ii) collecting and recovering monies owed to us.

‍‍This applies to Identity, Financial, Health, GP details, Video, and Usage data.

The lawful basis for processing this data is:

Performance of our contract with you.
Explicit consent (where you provide us with explicit consent to process your Health Data or access your medical records).
Necessary for our legitimate interests (to recover debts due to us).

b) Roczen Mobile Apps

We process information about you when you use our mobile apps. Our apps can be downloaded from the Apple App Store and Google Play store.

Our apps require you to provide information about your health (including your psychological and physical wellbeing). This information is used to assess your suitability for our products and services, to diagnose and inform your treatment, and to monitor progress throughout any treatment programme that you subscribe to.

This is for Identity, Financial, Health, Technical, Profile, Usage, and Marketing / Communications Data. The lawful basis for this processing is:

Performance of our contract with you.
Explicit Consent (where you provide us with explicit consent to process your Health Data);
Consent (where you use our Apps to opt-in to receive updates and promotional materials from us).‍
Collection and processing of usage data to monitor and improve the features of our platform, ensuring that we provide the best possible care and user experience for patients.
Tracking interactions with the platform to assess its performance and identify areas for improvement, which helps us optimise our services
Enhancing the quality of patient care, we analyse how users interact with different features on the platform, allowing us to make data-driven improvements to our platform

c) Relationship management

To manage our relationship with you which may include:

communicating with you;
notifying you about changes to our terms and conditions or Privacy Policy; and
asking you to leave a review or take a survey.

‍This applies to Identity, Usage Data, Profile, and Marketing / Communications data. The lawful basis for this processing is:‍

Performance of our contract with you.
To comply with a legal obligation.
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).

d) Administration

To administer and protect our business, this website and our apps (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

‍‍This is for Identity, Financial, Technical, Profile, Usage, and Marketing / Communications data. The lawful basis for this processing is:‍

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);
To comply with a legal obligation.

e) Online and social media advertising

Roczen uses third-parties to provide online or electronic ads on our behalf. These third parties use data about your visits to our websites and apps to send you customised ads that may be of interest to you. This information is collected using cookies and other similar technologies by Roczen and our third-party advertising partners in accordance with our Cookie Policy.

‍‍This is for Identity, Profile, Usage, and Marketing / Communications data. The lawful basis for this processing is:‍

Consent to the use of these cookies on our website and apps.

‏‎ ‎f) Improving our website, apps and products/services

To use data analytics to improve our website, apps, products and services, marketing, customer relationships and experiences.

‍This is for Technical and Usage data.‍ The lawful basis for this processing is:

Legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).‍

g) Keeping you informed

To make suggestions and recommendations to you about products and services that may be of interest to you.

Please see below for further details on marketing.

This is for Identity, Technical, Usage, Profile, and Marketing / Communications data. The lawful basis for this processing is:

Consent (where you have opted-in to receive updates and promotional materials form us, for example, on our website).
Necessary for our legitimate interests (to develop our products/services and grow our business).‍

We may use your Identity Data, Technical Data, Usage Data, Profile Data and Marketing and Communication Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which updates, products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us if you have requested information from us, or subscribed to or purchased products or services from us and you have not opted-out of receiving that marketing. Alternatively, you may receive marketing communications where you have specifically opted-in to receive these (for example, by signing up for updates or newsletters on our website, or by signing up whilst using our apps).

You can ask us to stop sending you marketing at any time by clicking "unsubscribe" on any email marketing sent to you, by changing your preferences in our apps, or alternatively by contacting our Data Protection Officer on the details below.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.