External Privacy Notice
Newmode Health Limited (trading as “Arc”)
Last Updated: 05/10/2026Who we are and what we do
Who we are
Newmode Health Ltd (“Newmode Health”, “Arc”, “us”, “we”, “our”) is a limited company registered in England and Wales under registration number 17050479. Our registered office is 9th Floor 107 Cheapside, London, United Kingdom, EC2V 6DN.
We are registered with the UK supervisory authority, Information Commissioner’s Office (“ICO”) in relation to our processing of Personal Data under registration reference ZC105671.
What we do
We provide a private preventative healthcare service to subscribed customers. We are committed to protecting the privacy and security of the Personal Data we process about you.
Unless we notify you otherwise, we are the controller of the Personal Data we process about you. This means that we decide what Personal Data to collect and how to process it.
Purpose of this privacy notice
The purpose of this privacy notice is to explain what Personal Data we collect about you and how we process it. This privacy notice also explains your rights, so please read it carefully. If you have any questions or wish to make a complaint, you can contact us using the information provided below under the ‘How to contact us’ section.
Who this privacy notice applies to
This privacy notice applies to you if:
- You visit our website
- You purchase goods or services from us
- You enquire about our products and/or services
- You use our App
- You sign up to receive newsletters and/or other promotional communications from us
What Personal Data is
‘Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier.
‘Special Category Personal Data’ is more sensitive Personal Data and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying someone, data concerning physical, or mental health or data concerning someone’s sex life or sexual orientation.
Personal Data we collect & How
The type of Personal Data we collect about you will depend on our relationship with you. For a more detailed overview of what personal data we process and way, see the table at section 6. Typically, the personal data we collect from you when you use our services will include (but may not be limited to) the below:
- Full name
- Contact details (email, home address, phone number)
- Age/DoB
- Gender
- Identity documents (passport/driving license)
- Payment information
- Medical details and genetic information (medications, conditions, allergies, biomarkers and blood test results)
- Health / lifestyle details (steps, sleep, calories, heart rate, diet, exercise habits and supplement use)
- Diversity information such as race and ethnicity
- Any correspondence you choose to provide to us
- App usage information, device details and some location data
- Photographs
- Call recordings (should you call our customer services)
We collect Personal Data directly from you via our App, or by phone and email.
Purposes, lawful bases and retention periods
We will only use your Personal Data when the law allows. Most commonly, we will use your Personal Data in the following circumstances:
| Categories of individuals | Categories of Personal Data | Purpose of Processing | Lawful Basis |
|---|---|---|---|
| Prospective Customers | Name, address, email address | To enquire about our services, or sign up to our marketing communications | Contract & Consent |
| Customers | Identity Documents | To verify who you are in order to be able to provide medication | Legal Obligation |
| Customers | Name, contact details, test requirements | To facilitate your blood test with our third-party test provider | Legitimate Interests |
| Customers | Date of birth/age, gender, medical and health information, blood test results, race/ethnicity details, medical notes and photographs | To provide you with our healthcare service | Provision of Healthcare |
| Customers | App usage information, device identifiers, Cookies information | To understand how our app is performing, conduct analytics and identify any issues | Legitimate Interests |
| Customers/Perspective Customers | Call recordings | Training and monitoring purposes | Legitimate Interests |
Where Personal Data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information.
Sharing your Personal Data
We may share your Personal Data with our carefully selected third parties, including:
- Your GP, emergency services, or the NHS, when it is necessary to escalate a medical issue and we are unable to contact you directly.
- Other healthcare providers, such as our lab testing partners or pharmacies, only with your explicit permission when referring you for other medical services.
- Data processors that we use for securely storing your personal data so that we can provide our service, primarily Google Cloud Platform.
International Transfers
Your Personal Data may be processed outside of the UK. This is because the organisations we use to provide our service to you are based outside the UK.
We have taken appropriate steps to ensure that when your Personal Data is processed in a country outside the UK, it does not have a materially lower level of protection than that guaranteed in the UK. We do this by ensuring that:
- Your Personal Data is only processed in a country which the Secretary of State has confirmed has an adequate level of protection (an adequacy regulation), or
- We enter into an International Data Transfer Agreement (“IDTA”) with the receiving organisation and adopt supplementary measures, where necessary or
- When transferring your Personal Data to America, we may rely on the UK-US Data Bridge, where appropriate.
Marketing Communications
From time to time, with your consent we may use your information to contact you with details about our products and services, which we feel may be of interest to you. You have the right at any time to stop us from contacting you for marketing purposes. You can do so by following the ‘unsubscribe’ link on any emails received or contacting us at dataprotection@myarc.com.
Automated Decision-making
Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement), or profiling (automated processing of personal data to evaluate certain conditions about an individual).
We do offer an in-system chat function for enquiries and support, which uses Artificial Intelligence (AI) to operate. This has been risk assessed with appropriate safeguards in place to ensure personal data is protected. This functionality (in-system chat) is optional to use.
Your rights
You have certain rights in relation to the processing of your Personal Data, including to:
- Right to be informed — You have the right to know what personal data we collect about you, how we use it, for what purpose and in accordance with which lawful basis, who we share it with and how long we keep it. We use our privacy notice to explain this.
- Right of access (commonly known as a “Subject Access Request”) — You have the right to receive a copy of the Personal Data we hold about you.
- Right to rectification — You have the right to have any incomplete or inaccurate information we hold about you corrected.
- Right to erasure (commonly known as the right to be forgotten) — You have the right to ask us to delete your Personal Data.
- Right to object to processing — You have the right to object to us processing your Personal Data. If you object to us using your Personal Data for marketing purposes, we will stop sending you marketing material.
- Right to restrict processing — You have the right to restrict our use of your Personal Data.
- Right to portability — You have the right to ask us to transfer your Personal Data to another party.
- Automated decision-making — You have the right not to be subject to a decision based solely on automated processing which will significantly affect you. We do not use automated decision-making.
- Right to withdraw consent — If you have provided your consent for us to process your Personal Data for a specific purpose, you have the right to withdraw your consent at any time. If you do withdraw your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we are permitted by law to do so.
How to exercise your rights
You will not usually need to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
If you wish to exercise your rights, you may contact us using the details set out below within the section called ‘How to contact us’. We may need to request specific information from you to confirm your identity before we can process your request. Once in receipt of this, we will process your request without undue delay and within one month. In some cases, such as with complex requests, it may take us longer than this and, if so, we will keep you updated.
Complaints
You have the right to complain if you consider that we have not complied with the data protection law when handling your Personal Data. We will acknowledge receipt of your complaint within 30 days, investigate the matter without undue delay, and keep you informed of the progress and outcome. If you wish to complain please use the contact details given below under “How to contact us and our Data Protection Officer”. We will do our best to resolve the matter to your satisfaction.
If you are not satisfied with the outcome of your complaint, you can complain with the relevant supervisory authority. The supervisory authority in the UK is the Information Commission who can be contacted online:
Or by telephone on 0303 123 1113
Children’s Privacy
We do not offer our products and services to children. If you learn that a child has provided us with their Personal Data, you may contact us, as described below, and we will securely and permanently delete it, in accordance with applicable law.
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.
If we become aware of any loss, misuse, alteration of personal data we will work closely with our IT team, DPO and other parties as necessary to investigate the incident. We have put in place the relevant procedure and policies to investigate, mitigate and report (when needed to relevant parties) such instances.
Retention of Personal Data
We will retain personal data for as long as necessary in line with various requirements, such as for example, best practice recommendations (e.g., ICO recommendations), relevant guidelines (e.g. CQC guidance) or for as long as mandated under specific legislation (e.g. HMRC requirements). We will also determine appropriate retention periods based on our legitimate interests where identified. When data is needed to be deleted, we will either delete manually or anonymise it if deletion is not possible.
How to Contact Us
If you wish to contact us in relation to this privacy notice or if you wish to exercise any of your rights outlined above, please contact us as follows:
We have also appointed Evalian Ltd as our Data protection Officer (“DPO”), details as per below:
Evalian Ltd
Leylands Business Park,
West Lodge,
Colden Common,
Winchester
SO21 1TH
Changes to this privacy notice
We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify you of the changes where required by applicable law to do so.
Last modified 05/10/2026.