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Privacy Policy

Effective date: 03.03.2026
Last updated: 03.03.2026
 

1) Who we are

Product Earth Health is a trading brand operated by Clarity Pharma Limited (Company No. 03657934), a company incorporated in England and Wales with its registered office at:
 

Unit 3 Mead Way, Great Hallingbury, Bishop’s Stortford, CM22 7FD, United Kingdom.
 

We operate in partnership with Leva Clinic Ltd, the CQC-registered provider of regulated clinical services.
 

We are committed to processing personal data lawfully, fairly and transparently and in accordance with UK GDPR and the Data Protection Act 2018.
 

ICO registration: 
Support and privacy contact: support@productearthhealth.com
 

2) What this policy covers

This Privacy Policy explains how we collect, use, store and share your personal data when you use our website, register interest, use our digital services (including the patient app/portal), book consultations, receive clinical services, or receive pharmacy fulfilment.

This policy should be read alongside any privacy notices shown to you at the point you provide data (for example, during onboarding, booking, or within the app).
 

3) Data protection roles (who controls what)

Because our service involves multiple regulated entities, your data may be handled by more than one organisation:

  • Clarity Pharma Limited is a Data Controller for data collected via the Product Earth Health website and for pharmacy-related operations where applicable.

  • Leva Clinic Ltd is a Data Controller for data processed to deliver regulated clinical services, including clinical consultations and creation/maintenance of clinical records.

  • Some suppliers (technology providers) act as Data Processors and process data only under instructions and contractual safeguards.

If you want help understanding which organisation is responsible for a specific part of your data, contact us at support@productearthhealth.com.
 

4) What personal data we collect

Depending on how you use the service, we may collect:

Identity & contact details: name, date of birth, email, phone, address.
Account & technical data: login events, device type, IP address, browser/app details, usage and diagnostic logs.
Health and clinical data (special category): medical history, symptoms, GP/medical records you upload or request, consultation notes, clinical decisions, prescription details, outcomes and follow-ups.
Payments & transactions: consultation payment confirmations, medication payment confirmations, refunds, cancellations, invoices/receipts (we do not store full card details).
Communications: messages to support, emails, call notes, complaint handling.

Health data is treated as special category data and is handled with higher safeguards.
 

5) How we collect personal data

We collect data when you:

  • submit forms on our website (e.g., eligibility/waitlist/contact),

  • create an account and use the patient app/portal,

  • upload documents or complete questionnaires,

  • book and attend consultations,

  • pay for consultations or medication,

  • contact support or provide feedback,

  • are referred by a clinician or provide information from your GP (where you request/authorise it).

We only collect data that is necessary for delivering healthcare services, operations, and regulatory compliance.
 

6) How we use your data (what we do with it)

We use personal data to:

  • provide access to the website, app/portal and services,

  • assess suitability for consultation and support safe onboarding,

  • deliver clinical consultations and maintain clinical records,

  • issue prescriptions where clinically appropriate and allowed under UK law,

  • support dispensing and fulfilment by the pharmacy,

  • process payments, refunds, cancellations and service communications,

  • provide customer support and manage complaints,

  • prevent fraud and protect platform security,

  • improve services through aggregated analytics (where possible, using anonymised or pseudonymised data).

We do not sell your personal data.
 

7) Lawful basis for processing

We rely on different lawful bases depending on context:

  • Contract: to provide services you request (e.g., account setup, booking, communications, fulfilment).

  • Legal obligation: to comply with healthcare, pharmacy, tax, and regulatory duties.

  • Legitimate interests: to operate, secure, and improve services (balanced against your rights).

  • Consent: where required (for example, non-essential cookies and certain marketing).

  • Special category health data: processed under UK GDPR conditions for healthcare provision and management, with confidentiality safeguards.

Where we rely on consent, you can withdraw it at any time (this will not affect lawful processing already carried out).

8) Prescription-only medicines and regulated care

We provide consultations for patients who may be eligible for treatment with prescription-only medicines, including medicinal cannabis, in accordance with UK law. Clinical decisions are made by qualified clinicians and are subject to eligibility and clinical appropriateness.

If you are prescribed medication, dispensing and fulfilment is handled by the dispensing pharmacy in accordance with applicable medicines and pharmacy regulations.
 

9) Sharing your data

We may share data only when necessary, including with:

  • Leva Clinic Ltd (regulated clinical provider),

  • clinicians involved in your care,

  • Clarity Pharma Limited (dispensing pharmacy / fulfilment),

  • technology suppliers supporting scheduling, video consultation, hosting, analytics, and customer support,

  • payment providers for processing transactions,

  • regulators or authorities where required by law or to protect safety.

All service providers must meet appropriate security and confidentiality requirements and are bound by contracts where required.
 

10) Marketing

We may send service communications that are necessary (e.g., appointment confirmations, onboarding reminders, safety notices). Marketing communications (e.g., newsletters, promotions) will be sent only where permitted by law and, where required, with your consent. You can opt out at any time using the unsubscribe link or by contacting us.
 

11) Cookies (included in this Privacy Policy)

Our website uses cookies and similar technologies to ensure the site works properly, to improve performance, and to understand how visitors use the site.

Cookie types we may use:

  • Strictly necessary cookies: required for core functionality and security.

  • Analytics cookies: help us understand traffic and improve content (e.g., how many visitors, which pages are used).

  • Functional cookies: remember preferences (where enabled).

We do not use cookies to target advertising relating to prescription medicines.

Managing cookies: You can control cookies through your browser settings and (where available) our cookie banner/preferences tool. If you block some cookies, parts of the website may not work as intended.

(If you want, I can produce a simple cookie table once you tell me which tools you actually run on Wix — e.g., GA4, Meta Pixel, etc.)
 

12) Data security

We use appropriate technical and organisational measures designed to protect personal data, including access controls and secure systems. Access to health data is restricted to authorised personnel only. No online system is 100% secure, but we take security seriously and investigate suspected incidents.
 

13) Data retention

We keep personal data only for as long as needed for the purposes described above, including legal and regulatory obligations. Clinical records are retained in line with healthcare record retention requirements. Transaction records may be retained for tax and accounting purposes.
 

14) International transfers

If we or our service providers transfer personal data outside the UK, we ensure appropriate safeguards are in place (such as UK-approved contractual clauses or other lawful mechanisms).
 

15) Your rights

You may have rights under UK GDPR including:

  • access to your data,

  • correction of inaccurate data,

  • deletion (where applicable),

  • restriction or objection to processing,

  • data portability (in certain cases),

  • withdrawing consent where processing is based on consent.

To exercise your rights, contact [privacy@productearthhealth.com]. We may need to verify your identity before responding.

You also have the right to complain to the Information Commissioner’s Office (ICO). We would appreciate the opportunity to address concerns first.
 

16) Changes to this policy

We may update this policy from time to time. The latest version will always be posted on our website with an updated “Last updated” date.
 

17) Contact

For privacy questions or requests: support@productearthhealth.com

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