Privacy Policy
June 2026
Privacy Policy - Platform User
Champion Health Ltd
Last updated: June 2026
Platform Introduction
Champion Health is committed to protecting your personal data and respecting your privacy.
Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in this policy and it is important that you read that information.
This policy (together with our end-user license agreement as set out at www.championhealth.co.uk/eula (the EULA) or as presented to you when you first use or install our Platform (as defined in the EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to:
- Your use of all versions of our Platform, whether available whether made available to you as an app on your phone (Mobile Platform) or online through our website (Web Platform), once you have downloaded or streamed a copy of the Platform onto your personal computer, mobile telephone or handheld or other suitable electronic device (Device); and
- Any other interactions with us, by phone or computer or otherwise, this policy will govern the processing of your personal data that we carry out.
Our Platform is not intended for use by, or for the purpose of the collection of any personal data relating to, children (under the age of 16 years) and we do not knowingly collect data relating to children. Authorised Users (Employees) may assign and revoke up to 3 (three) access licenses to friends or family members (over the age of 16 years).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Who We Are
Champion Health Ltd is a company registered in England and Wales with company registration number 11456257 of with registered address at Champion Health Ltd, 4th Floor 140 Aldersgate Street, London, United Kingdom, EC1A 4HY. We are the data controller who is responsible for your personal data (collectively referred to as "we", "us" or "our" in this policy).
We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.
Our DPO's contact details are:
Email address: [email protected]
Postal address: Champion Health Ltd, 4th Floor 140 Aldersgate Street, London, United Kingdom, EC1A 4HY
Consent
Before installation or access to the Platform, you will be asked to indicate your consent to our collection and processing of your personal data (where 'consent' has been identified as the appropriate lawful basis as described in this policy).
How you can withdraw consent
Once you provide consent for us to collect and process your personal data for specified processing activities (see online registration form) you may change your mind and withdraw consent at any time by visiting our Website Support Page or by emailing us ([email protected]) but that will not affect the lawfulness of any collection and processing carried out before you withdraw your consent. We may still need to retain certain information, including some of your health information, but only where this is strictly required for insurance purposes or other legal compliance. We will delete any information that we do not strictly need to comply with our own legal obligations as we are required to by data protection laws. We shall not be able to remove any data that you provided that we have already fully anonymised as part of an aggregated data set (which we describe below) that does not reveal any individual's identity.
The Data We Collect About You
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data
- Contact Data
- Health Data (Special Category)
- Device Data
- Content Data
- Profile Data
- Usage Data
- App Data
- Marketing and Communications Data
We will be collecting data related to information about your health, which is defined as being 'Special Category' personal data by data protection laws.
We do not collect any information about criminal convictions and offences. Where we collect Special Categories of Personal Data about you, we will ask for your explicit consent to process this information. We will only ask for your consent again if the purpose of our processing changes.
We do not collect financial or transaction data from you, the data subject, where your employer or a family member or friend provides you with access to our Services.
In some instances, some of your details may be shared with a group of your colleagues if you choose to participate in certain features/programmes offered within the Platform. For example, if you take part in the Champion Health "Steps Challenge" or any other challenge/feature that tracks and/or shares any of your details, you are consenting to your details being tracked in your version of the platform and for your details being shared with your group of colleagues who are also consenting to be part of that feature/program at any point. If you no longer wish for your details to be shared, you may adjust your settings within your application by navigating to your Profile section which is accessed via the footer navigation. Once you adjust your settings, your consent will be deemed to have been withdrawn and your details will no longer be shared with your colleagues.
Description of Categories of Personal Data
Identity Data: first name, last name, username or similar identifier, age, gender.
Contact Data: email address.
Health Data: includes information about your health and wellbeing. This includes: lifestyle health-related behaviours (nutritional/hydration intake, alcohol consumption, smoking, physical activity, sleep), physical health (musculoskeletal conditions), mental health (stress, anxiety, depression).
Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
Content Data: includes log-in information stored on your Device and any digital content that you upload into the Champion Health Platform (e.g. your profile photo).
Profile Data: includes your username and password, your interests, preferences, feedback and survey responses.
Usage Data: includes details of your use of any of our Platform or your visits to any of our Sites including, but not limited to, traffic data and other communication data, and the resources that you access.
Marketing and Communications Data: includes your preferences in receiving marketing communications from us.
App Data: includes whether you are accessing the Platform through a mobile application.
Aggregated Data and Anonymisation
We may collect, use and share aggregated data such as statistical or demographic data for the purpose of providing your employer with an anonymised summary of the workforce wellbeing. Aggregated data could be derived from your personal data (including your Health 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 Usage Data to calculate the percentage of users accessing a Platform feature. 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.
We may also use anonymised data (including your Health Data) for research and scientific purposes in order to either try and improve the way we deliver our own services.
We will either rely on legitimate interests or explicit consent as a lawful basis for the anonymisation of your personal data. If you really do not want us or anyone else to use your data in this way, even though no one will be able to tell that you are the source of that data, or if you have provided explicit consent and then wish to withdraw your consent, then please contact us to let us know. Please note however, that because of the way in which we anonymise and aggregate data, we will not be able to tell which data is yours so we may not be able to remove this data from any reports or research that it has been used for prior to the date of you withdrawing your consent or opting out. If you withdraw consent for us to use your health data we will also be unable to provide other Services to you.
How Is Your Personal Data Collected?
We will collect and process the following data about you:
Information you give us. This is information (including Identity, Contact, Health, Financial, and Marketing and Communications Data) you give to us by filling in forms whilst using our Platform, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use our Platform, download, register or use our Platform for the first time, subscribe to any of our Services, search for our Platform or Service, share data via an App's social media functions, enter a competition, promotion or survey and when you report a problem with any of the Platform, our Services, or any of our Sites. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device. Each time you visit one of our Sites or use one of our Platforms we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies.
For detailed information on the cookies we use and the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy below.
Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Device Data from analytics providers such as Google based outside the UK;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe, Inc based in the United States of America, GoCardless and Xero.
- Identity Data, Contact Data, Health Data (Special Category), Financial Data, Transaction Data, Device Data, Content Data, Profile Data, Usage Data, App Data, Marketing and Communications Data from our third-party IT services providers or mobile application marketplaces who manage and run our Platform and the Services under our strict instructions and not for their own purposes.
- Identity Data, Contact Data from your employer to verify your employment status with them.
- Identity Data, Contact Data from an Authorised User to provide you with access to our Platform via the Friends and Family scheme.
- Clinical Health Data (Special Category) from ErgoPro Ltd, where your employer has commissioned workplace ergonomics assessments, for the purpose of aggregate workforce reporting. ErgoPro is engaged as a sub-processor via Champion Health Plus Limited. ErgoPro's own privacy policy governs their direct assessment processing.
Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
How We Use Your Personal Data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing;
- Where we need to perform a contract we are about to enter or have entered with you;
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- Where we need to comply with a legal or regulatory obligation; and
- To protect your vital interests where you are unable to give consent.
When we collect personally identifiable information through our digital platforms and website we will use the information in the way described above and we will make it clear what we intend to do with it.
Purposes For Which We Will Use Your Personal Data
Disclosures of Your Personal Data
When you provide us with your personal data, we may only share your personal data with the third parties for the purposes set out in the table above (Purposes For Which We Will Use Your Personal Data), and for the purposes outlined below:
- External Third Parties as set out in the Glossary.
- 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.
Who we WILL NOT share your Health Data (Special Category) with:
- Your employer or the group or organization to which you belong.
- Third party marketing providers or databases of any kind.
- Anyone outside of our business, unless and until we have made sure that you cannot be identified from the data we create (except as expressly set out in this policy). For more information on how this data is used after it is no longer "personal data" see the section on "Aggregated Data" above.
Friends & Family Access
Authorised Users (Employees) may assign and revoke up to 3 (three) access licenses to friends or family members (over the age of 16 years).
No anonymised and aggregated health data will be reported to businesses or organisations from friends or family user groups.
Marketing
We do not share your personal data with any third party for marketing purposes of any kind.
Nexa Clinical MSK Platform
The following applies only where your employer has given you access to the Nexa clinical musculoskeletal (MSK) health platform as part of their employee wellbeing provision. If your employer does not offer Nexa, this section does not apply to you.
Additional data we collect for Nexa
In addition to the data categories set out above, where you use the Nexa platform we collect:
- Clinical Health Data (Special Category): MSK triage questionnaire responses, functional capacity self-assessment, clinical assessment outcomes, treatment notes, physiotherapy outcome scores, and appointment history.
- Employment Data: job role and department, where provided by your employer, to support occupational health reporting.
- Address: work address for the current deployment. The system is built to accept a home address in preparation for future face-to-face treatment routing when that pathway becomes active.
Lawful basis for Nexa health data
Where you provide health information directly through the Nexa triage questionnaire, we rely on your explicit consent (Article 9(2)(a) UK GDPR).
Where clinical professionals employed or engaged by Champion Health process health data in their capacity as registered healthcare practitioners providing your direct care, they do so under Article 9(2)(h) UK GDPR (occupational medicine and health care provision). This processing is supported by an Appropriate Policy Document (APD) as required by Schedule 1 of the Data Protection Act 2018.
How we use your Nexa data
Report sharing
Your triage output and clinical assessment report is provided to you. A human clinician reviews all assessment outputs before any recommendation is made. No automated decision-making is applied.
With your explicit consent, a summary report may also be shared with your employer's occupational health or HR team for the purpose of supporting your return to work or ongoing workplace health management. You will be asked for this consent separately during the Nexa registration process. You may withdraw this consent at any time by contacting [email protected].
Retention - Nexa clinical records
Clinical records (including triage assessment data and treatment notes) are retained for a minimum of 8 years from the date of last clinical contact, in accordance with NHS and clinical governance requirements. This retention period applies regardless of whether you close your Champion Health account.
Where Your Personal Data Is Stored and Processed
Primary storage and processing location. All personal data we collect through the Champion Health platform - including your account information, health-assessment responses, and any other personal or special-category health data - is stored and processed within the United Kingdom, in an Amazon Web Services (AWS) data centre located in London. The data is held inside an isolated AWS Virtual Private Cloud (VPC), encrypted at rest using AES-256 and in transit using TLS 1.2 or higher, and access is restricted by IP allowlisting, multi-factor authentication, and role-based access controls.
Database location. Your health-assessment responses are stored in a managed MongoDB Atlas database operating entirely within our AWS UK environment. User-account data and health-assessment responses are kept in separate database collections and linked only via internal user-ID references, supporting data minimisation and segregation.
Backups. Backups of UK-region data are stored within the same AWS UK region for resilience and to keep your data within UK jurisdiction.
Sub-processors. In limited cases, personal data may be processed outside the UK and the European Economic Area (EEA). This is usually by carefully selected sub-processors that support the platform - for example, providers of email delivery, product analytics, payment processing, or customer-support tooling. A current list of our sub-processors and the country in which each one processes data is available on request from [email protected].
Group certification. Champion Health's information security and PII-protection controls - including controls over the geographical location of PII processing - are certified to ISO/IEC 27001:2022 and ISO/IEC 27018:2019 as part of the Physitrack Group ISMS.
Changes to processing locations. If we change the geographical location of PII processing in a way that materially affects you, we will update this Privacy Policy and, where required, notify you directly.
International Transfers
Where personal data is transferred outside the UK or the EEA to a country that has not been the subject of a UK or European Commission adequacy decision, we rely on appropriate safeguards under Article 46 of the UK GDPR and the EU GDPR. These safeguards include the UK International Data Transfer Agreement (IDTA), the UK Addendum to the EU Standard Contractual Clauses, and the EU Standard Contractual Clauses (SCCs) as applicable. Sub-processors are subject to GDPR-compliant Data Processing Agreements, and we conduct transfer-risk assessments before any new international transfer is initiated. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.
EU Representative
Our representative within the EU with respect to our obligations under European data protection law is Physiotools Oy incorporated and registered in Finland with company number 0491074-9 whose address is Kehrasaari B, 5th Floor, 33200 Tampere, Finland. Email: [email protected]
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.
Personal Data Breach Notification
A personal data breach is a security incident leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data we hold about you. We operate the Physitrack Group Incident Management Procedure, which is independently certified under ISO/IEC 27001:2022 and ISO/IEC 27018:2019.
When a breach is identified or suspected, we will:
1. Detect, contain and assess. The incident is reported without delay to our Information Security Manager and assessed by our Data Protection Officer and Legal team to determine its nature, scope, the categories of data affected, the likely consequences, and the level of risk to affected individuals.
2. Notify the supervisory authority. Where we consider the breach is likely to result in a risk to the rights and freedoms of natural persons, we will notify the UK Information Commissioner's Office (ICO) - and, where the EU GDPR applies, the relevant lead EU supervisory authority - without undue delay and, where feasible, no later than 72 hours after we become aware of the breach, in line with Article 33 of the UK GDPR and the EU GDPR.
3. Notify affected individuals. Where the breach is likely to result in a high risk to your rights and freedoms, we will inform you without undue delay, in clear and plain language, in line with Article 34 of the UK GDPR and the EU GDPR. We will tell you what happened, the likely consequences, the steps we have taken or propose to take to address the breach, and the measures you can take to protect yourself.
4. Notify our customer (your employer, where applicable). Where Champion Health acts as a data processor for a corporate client, we will notify that client (the controller) without undue delay and in any event within 48 hours of becoming aware of the breach.
5. Document, report and improve. Every confirmed breach is logged in our Group Data Breach Register, where appropriate reported to our insurer in line with our cyber-liability policy, and reviewed at management level so that lessons learned feed back into our policies, controls and staff training.
If you believe your personal data may have been compromised, please contact us at [email protected] or our DPO at [email protected]. You also have the right to lodge a complaint with the ICO at ico.org.uk or with your local supervisory authority in the EU/EEA.
Data Retention
Your personal data is retained only for the duration that you have an active account with Champion Health. Your personal data is securely deleted when:
- You contact us to request an account closure
- Your employer discontinues their commercial agreement with Champion Health
- Your account has been inactive for more than twelve (12) months and continues to remain inactive after being notified with 30 days' notice that your account will be deleted.
Your Legal Rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data: access to your personal data, correction of your personal data, erasure of your personal data, restriction of processing your personal data, transfer of your personal data, withdrawal of your consent and; object to processing of your personal data.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at [email protected]
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, or another competent supervisory authority of an EU member state if the Platform is downloaded outside the UK and you are not a UK citizen.
Request access to your personal data (commonly known as a "data 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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.
Changes to the Privacy Policy and Your Duty to Inform Us of Changes
We keep our privacy policy under regular review.
This version was last updated in June 2026. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email when you next start the Platform or log onto one of the Platform Sites. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Platform or the Services.
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 our relationship with you.
Third Party Links
Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact Data and Identity Data. Please check these policies before you submit any personal data to these websites or use these services.
Glossary
1. Lawful Basis
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Protecting your vital interests means processing your data where your vital interests are at stake, such as in an emergency situation, where we would consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data pursuant to this justification.
2. Third Parties
2.(A) External Third Parties
Service providers acting as processors based in the United Kingdom or in other jurisdictions, in each case under appropriate safeguards as set out in the 'International Transfers' section, who provide IT and system administration services including mobile application marketplaces and mobile operating system.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Your Legal Rights
You have the right to:
Request access to your personal data (commonly known as a "data 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
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.