Privacy policy

• When you create an account. If you create an account with Stella or Stella Plus, we will collect information including your name, password and email address if you choose to provide it. We collect these details to fulfil our contractual obligations to you.
• When you pay for a subscription. If you pay for a subscription, we will collect information including your name and payment details. We collect these details to fulfil our contractual obligations to you.
• When you complete a menopause assessment. If you complete a menopause assessment through Stella, we will collect your name, date of birth and health related information such as your stress levels, activity levels and menopause symptoms. We collect this information to fulfil our contractual obligations to you and where we process your health information based on your explicit consent so that we can provide you with a tailored menopause plan and support. You can withdraw your consent at any time by contacting us at privacy@vira.health.
• When you complete a menopause consultation. If you complete a menopause consultation through Stella Plus, we will collect information including your name, date of birth, medical history, current menopause symptoms, family history, lifestyle, your recommended treatment details and photo ID. We collect these details to fulfil our contractual obligations to you and for the provision of health care services from a health professional.
• Doctor’s appointments. If you book an appointment through Stella Plus to speak with a doctor, we collect information including your name, contact details, payment details, appointment details and prescription details if applicable. Our doctors also make detailed notes of your consultation which we keep on file to ensure we are compliant with healthcare regulations. We collect these details to fulfil our contractual obligations to you and for the provision of health care services from a health professional.
• Prescriptions. If you purchase a menopause prescription through Stella Plus, we collect information including your prescription details, name, contact details, delivery details and payment details. We collect these details to fulfil our contractual obligations to you and for the provision of health care services from a health professional.
• When you provide a testimonial. If you provide us with a testimonial or story we may publish this or otherwise use it for our internal business purposes. We will anonymise any public testimonials and we process this information as it is in our legitimate interests to promote our business and improve our services. If we publish your story or testimonial in a way that identifies you we will only do so with your consent and if it contains your health information with your explicit consent. If you would ever like us to remove your testimonial or story from our website, please contact us at privacy@vira.health and we’ll of course remove this.
• When we anonymise your personal data. In some circumstances we and our sub-contractors may carefully anonymise your personal data so that it can no longer be associated with you, and we and they may use this anonymised information indefinitely without notifying you. We use this anonymised data to (i) complete research in the public interest, such as to analyse trends in menopause symptoms and treatments to develop our products and services and support other similar programmes around the world, including using the data in blogs and academic articles and (ii) to meet our reporting requirements.
• When you attend one of our events or any third party events. When you attend one of our events (whether in person or online e.g. via Zoom), we will usually collect your name and email address. We collect this information because it’s in our legitimate interests to know who’s attending our events. Where you provide us with your personal data at a third party event where we are also in attendance, we will process this under our legitimate interest to promote our business and follow up on your expression of interest in our group.
• When you apply for a job with us. When you enter into the recruitment process with us we may collect your name, contact details, recruitment information (e.g. right to work documentation and references), qualifications, accreditations, and any additional information we may receive from our recruitment partners. We will use your personal data to assess your suitability for our available roles before taking steps at your request to enter into a contract with you. Where we process your right to work documentation, we will do so to comply with our legal obligations.
• When you contact us. When you contact us either by phone or email with general queries, we will usually collect your name, contact details and information relating to your query, because it is in our legitimate interest to make sure we can properly respond to your query.
• Newsletters. When we send you our newsletters because you have opted-in to receive them, we rely on your consent to contact you. If you have not opted-in and we contact you by email, we do this because of our legitimate interest to promote our business. You can unsubscribe from our updates at any time by clicking the unsubscribe link at the bottom of any of our emails or by emailing privacy@vira.health.
• On social media. When you connect with us on social media including on Twitter, Instagram and LinkedIn we will collect and look after your handle, name and email address under our legitimate interest to respond to your comments and queries promptly.
• Technical information when you use our website or app. When you consent, we collect information about how you use our website. We use this information to improve our website and to better understand how people use it. More detail on the information we collect and how we do this is set out in our cookie policy below.
• To continue to provide our services to you in the event our business is sold. In order to ensure we can continue to provide our services to you by a prospective buyer, we may process your personal data where we have a legitimate interest to do so. If you object to our use of your personal data in this way, the buyer of our business may not be able to provide services to you.
• We continually review the personal data we collect to ensure we adhere to the principle of data minimisation by only collecting and retaining what is necessary for the provision and improvement of our services. We will inform you and, where required by law, seek your consent before making any changes to the purpose for which we collect and use your personal data.

• Business partners, researchers, suppliers and subcontractors for the performance of the contract we enter into with them and for the advancement of high quality menopause care.
• Analytics and search engine providers to assist us with the improvement and optimisation of our site.
• Promotional events, we do not sell data for marketing purposes. We may share your data with an event organiser. We will always tell you before (usually on the event registration form) and you will be given the chance to opt-out before we do this.
• Regulators/ Authorities/ Enforcement Agencies if we are under a duty to disclose or share your personal data in order to meet any legal requirement, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our clients or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
• Prospective buyers of our business under our legitimate interest to ensure our business can be continued by the buyer.

If you use Stella Plus, we will also share your personal data with our pharmacy partner, Chemist4U (UK Company Registration Number: 07262043 (Innox Trading Limited) and GPhC number 9011784 – please see https://www.pharmacyregulation.org/registers/pharmacy/name/chemist4u) and our doctors.

If you place an order from us for a menopause prescription, we will share your information with a clinical business partner to review the consultation and, if they agree, issue a prescription. This prescription will then be shared with our registered pharmacy provider Chemist4U. Chemist4U will issue your prescription and send it to your nominated delivery address.

You can contact Chemist4U directly by phone on 01695 474433 or by email at support@chemist-4-u.com. Chemist4U’s superintendent pharmacist is James O’Loan, MRPharmS (GPhC number 2084549).

If, after your menopause consultation, you book an appointment through us to speak with a doctor we will share your personal data with the doctor for the purpose of the appointment. If the doctor issues you with a prescription, the details will be sent to us for processing.

All information you provide to us is end-to-end encrypted between your device and our cloud servers based in the UK and EU (Ireland). We also work with sub-processors who may store data outside of the UK and EU (e.g. the United States).

Whenever we transfer your personal data to our sub-processors outside of the UK and the EU, which would only be for the purposes of storing it safely with our hosting provider sub-processor, we ensure it receives additional protection as required by law. To keep this privacy policy as short and easy to understand as possible, we haven’t set out the specific circumstances when each of these protection measures are used. You can contact us at privacy@vira.health for more detail on this.

We will only retain your personal data for as long as we need it to fulfil the purposes we collected it for and we will periodically review the personal data in our reviews to ensure we are only holding what is necessary. We may be required to keep your data for longer in order to be able to comply with our legal, accounting or regulatory requirements. If you are a patient using Vira’s products through the UK National Health Service the documents used to confirm your identity will only be held for 12 months after you sign-up. Please note where we are relying on your consent to hold your personal data, you can withdraw this consent at any time and we can remove your data. Personal data that is no longer required is removed using technology designed to prevent the recovery of the personal data and, if in paper, form shredded, burned, pulped, pulverized, or incinerated.

Vira Health seeks to be compliant with the GDPR (General Data Protection Regulation, including the UK GDPR). You have various rights under the GDPR, including the right to:

• access your personal data (also known as a “subject access request”);
• correct incomplete or inaccurate information we hold about you;
• ask us to erase the personal data we hold about you;
• ask us to restrict our handling of your personal data;
• ask us to transfer your personal data to a third party;
• object to how we are using your personal data; and
• withdraw your consent to us handling your personal data.

Please keep in mind that data protection law is complicated, and these rights will not always be available to you all of the time.

You also have the right to lodge a complaint with us or the Information Commissioner’s Office, the supervisory authority for data protection issues in England and Wales. If you are based outside of England and Wales, you can find your relevant supervisory authority here.

If you have any questions about when these rights will apply to you, please do get in touch with us at privacy@vira.health. We will endeavour to respond within 1 month of receipt.

We do not knowingly collect personal data from individuals under 18 years of age and neither Stella nor Stella Plus are targeted at this demographic. If you become aware that a child has provided us with personal data without parental consent, please contact us at privacy@vira.health. If we become aware that an individual under 18 has provided us with personal data without parental consent, we will take steps to remove the data and cancel that individual’s account.

Your feedback and suggestions on this policy are welcome. We’ve worked hard to create a policy that’s easy to read and clear. But if you feel that we have overlooked an important perspective or used language which you think we could improve, please let us know by email at privacy@vira.health.

If you’d prefer, you can always get in touch with us by post to our registered office at 22 Highbury Grove, Unit 401, London, United Kingdom, N5 2EF.

Please note, if you follow a link to a third party website or application from Vira, these third parties may have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

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