Vaginal Microbiome Testing Service - Privacy Policy

Vaginal Microbiome Testing Service
Privacy Policy

Updated: April 1 2025

1. Introduction

This privacy policy (“Privacy Policy”) gives you information about how Pelvic Relief collects and processes personal data in relation to the use of its vaginal microbiome testing service (including registering to use the service as a healthcare provider (“Testing Service”).

We keep our Privacy Policy under regular review. This version was last updated on the date above. 

The Testing Service is not intended for anyone aged under 18 and we do not knowingly collect data relating to anyone aged under 18 in relation to the Testing Service.

2. Who is the controller of your data?

References in this Privacy Policy to “Pelvic Relief”, “us” and “we” mean “Pelvic Relief”, the trading name of Elgenia Health Ltd., a company registered in England and Wales with company registration number 09833237. Our registered address is Upper Brockington, Bredenbury, Bromyard, Herefordshire HR7 4TH. Pelvic Relief ® is a registered trade mark of Elgenia Health Ltd.

Pelvic Relief is the data controller, responsible for your personal data. 

To contact us, see Section 12 below.

3. Who does this Privacy Policy apply to?

This Privacy Policy will apply to you:

- If you are registered as a Healthcare Provider in our ‘For Providers’ programme.

- If you have purchased the Testing Service and/or used our Testing Service. 

This Privacy Policy does not cover the use of personal data in the context of the use of the Pelvic Relief website in general, which is governed by our general Privacy Policy.

4. What data do we collect and how do we collect it?

Personal data

Personal data is 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, surname, title and  date of birth. We collect this through interactions with you (eg registering with us as a Healthcare Provider and/or placing an order for the Testing Service with us and/or completing a Test).

- Contact Data – includes address, email address, contact telephone number and (for Healthcare Providers) profession and professional documentation. We collect this through interactions with you (eg registering with us as a Healthcare Provider and/or placing an order for the Testing Service with us).

- Financial Data - includes bank account and payment card details. We collect this through interactions with you (eg placing an order for the Testing Service with us).

- Account data – includes details about payments made to/from you and history of products and services purchased. We collect this through orders placed by you.

- Self-reported health data – For patients, the information provided within the questionnaire used for the Testing Service (eg your date of birth, the results of your vaginal pH test, your reasons for doing the test, your ethnicity, your current symptoms, the severity of your current symptoms, whether you have regular periods, if you are pregnant, current medication use, recent antibiotic use, current HRT use, current contraceptive use, and the overall impact on your quality of life).  Please note that we will share this information with your Healthcare Provider in the report generated through the Testing Service.

- Test data – For patients, the results of the analysis of the vaginal swab. Analysis of vaginal swab samples by the laboratory includes the extraction and sequencing of DNA found in the samples. In a healthy person, almost all of this will be DNA related to the patient’s microbiome - we use it to identify populations of bacteria in your vaginal microbiome. There may be some fragments of the patient’s own DNA included in this sample. These will be sequenced along with all other DNA fragments. We may not be able to identify that some fragments are human DNA, nor do we try to use information about the patient’s own DNA. Please note that we will share this information with your Healthcare Provider in the report generated through the Testing Service.

- Customer support - Details of customer service emails, any information about queries and complaints you provide to us, customer support query records from our customer service email addresses.

Anonymised data

We may also collect, use and share aggregated data taken from the Testing Service results which is not personal data as it does not directly (or indirectly) reveal your identity. Where we de-identify personal data in this way, we commit to maintain and use the anonymised information in anonymous form and not to attempt to re-identify it.

We may use such anonymous data for our lawful business purposes, including to analyse, build and improve our products and services and other future products and services and to promote our business, provided that the data remains anonymous. We may also share the anonymous data with third parties.

5. How do we use your personal data 

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. 

In relation to the processing under this Privacy Policy, we rely on one or more of the following legal bases:

- Performance of a contract with you: Where we need to process the personal data 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. 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).

- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose.

- 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.

Purposes for which we may use your personal data 

We have set out below 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.

6. 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.

- Third Party sub-contractors. Currently our only sub-contractor is Bio-Me AS (“Bio-Me”), a Norwegian company with office and laboratory at Gaudstadalléen 21, N-0349 Olso, Norway, who will carry out the laboratory analysis of the vaginal swabs. If for any reason Bio-Me are replaced or we appoint any other third parties, we will let you know in advance. 

- 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.

7. If you fail to provide personal data 

Where we need to collect personal data by law, or to perform the Testing Service, and you fail to provide that data when requested, we may not be able to perform the Testing Service.

8. How do we keep your data secure?

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, contractors and other third parties who have a business need to know. They will only process your personal data on our instruction, 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.

9. How long do we keep your 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 have to keep basic information about our customers (including Contact, Identity, Financial and Account Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Section 11 below for further information.

Where we anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, it is no longer personal data and we may use this information indefinitely without further notice to you.

10. How do we manage international transfers?

Our processing of personal data is governed by the United Kingdom version of the GDPR (“UK GDPR”) and the Data Protection Act 2018. Whenever we transfer personal data out of the UK, we ensure a similar degree of protection is afforded to the personal data by ensuring at least one of the safeguards permitted under the UK GDPR is used.

These may include:

- Transfer to countries or organisations that have officially been deemed to provide an adequate level of protection for personal data by the ICO. 

- Transfer to companies which are certified under the UK’s data bridge for UK/US transfers.

- Using a specific contract approved by the EU/ICO.

11. What are your legal rights?

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

Note that in limited situations, we may not be able to comply with your request for specific legal reasons. If that is the case, we will still respond to notify you of such a decision. 

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. 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. 

- 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.

- 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 Section 12 below).  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.

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.

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.

12. Contact details

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

- Email address: test@pelvicrelief.co.uk

- Postal address: Pelvic Relief, Upper Brockington, Bredenbury, Bromyard, Herefordshire HR7 4TH.

13. Complaints

In addition to these rights, 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.