Privacy Notice – Thriving Clinics Limited

Last Updated: 16 June 2026

1. Introduction

Welcome to the Thriving Clinics Limited Privacy Notice. We respect your privacy and are committed to protecting your personal data. This privacy notice informs you about how we look after your personal data when you visit our website, use our central booking and marketing platforms, or interact with our services.

Thriving Clinics operates under a "hub-and-spoke" franchise model. This means that Thriving Clinics Limited acts as the central administrative and technological "Hub," while your primary medical care is delivered by independently owned and operated clinical branches ("Spokes").

2. Controllership: Thriving Clinics vs. Clinical Branches

Because of our hub-and-spoke model, the responsibility for your data is divided:

  • Thriving Clinics Limited (The Central Hub): We are the Data Controller for the data collected via our website, central booking engine, marketing communications, and central payment processing.
  • Your Local Clinical Branch: Your local clinic is a separate Data Controller responsible for your detailed medical, consultation, and clinical treatment records.

Important Note on Health Inferences: While Thriving Clinics Limited (the Hub) does not hold your full clinical medical records, the basic scheduling information we process (e.g., knowing you booked a "weight loss clinic" or a "GP appointment") allows us to infer information about your health. Therefore, we treat this booking data with the highest level of security as Special Category Data under UK data protection law.

3. The Data We Collect About You

Depending on how you interact with our website and services, we may collect, use, store, and transfer the following kinds of personal data:

  • Demographic & Identity Data: Including your first name, last name, date of birth, age, and home address.
  • Contact & Marketing Data: Including your email address, telephone number, and your preferences for receiving marketing communications from us.
  • Financial & Transactional Data: Including billing details, payments to and from you, and other details of services you have purchased from us. (Note: Payments are processed securely via Stripe, and we do not store full credit card numbers).
  • Scheduling Data (Special Category): Basic information indicating the date, time, and specific type of clinical appointment you have booked, which constitutes health-related data by inference.

4. How Is Your Personal Data Collected?

We use different methods to collect data from and about you, including through:

  • Direct interactions: You may give us your Identity, Contact, and Demographic Data by filling out forms on our website or by corresponding with us.
  • Automated technologies: When you make a booking, data is captured through our integrated platforms (e.g., Cliniko and Stripe).
  • Marketing Opt-ins: When you actively consent to receive newsletters or promotional updates via our website.

5. How We Use Your Personal Data & Our Lawful Basis

Under the UK GDPR, we must have a lawful basis to process your data. Where we process health-related scheduling data, we also invoke a specific condition for Special Category Data.

Purpose/ActivityType of DataLawful Basis (Article 6)Special Category Condition (Article 9)
To process your appointment booking and transfer details to your local clinical branch.Demographic, Identity, Contact, SchedulingPerformance of a Contract (to facilitate the service you requested).Article 9(2)(h): Management of health or social care systems and services.
To send marketing communications, newsletters, and promotional updates.Contact, MarketingConsent (Explicit website opt-in. You may withdraw this at any time).Not applicable (No health data used for marketing).
To process financial transactions, invoicing, and maintain business records.Financial, IdentityLegal Obligation (Required for statutory UK tax and HMRC compliance).Not applicable.

6. Disclosures of Your Personal Data

To provide our central administrative services, we share your data with strictly vetted third-party service providers and partners within our infrastructure:

  • Clinical Branches: Your Demographic and Scheduling data is transferred directly to your chosen local clinical branch so they can handle your medical care.
  • Mailchimp: Used as our CRM to manage and execute marketing campaigns.
  • Stripe & Cliniko: Used to securely process financial transactions and manage invoicing/booking.
  • Google Enterprise: Used for secure internal communications, team collaboration, and administrative backup.

7. International Data Transfers

We protect your data by restricting where it is stored or ensuring robust legal safeguards are in place:

  • Google Enterprise: Our configuration strictly restricts data storage to UK-based servers, ensuring your administrative and communication data does not leave the jurisdiction.
  • Mailchimp: Mailchimp processes data in the United States. To safeguard this transfer, we utilize Standard Contractual Clauses (SCCs) alongside the UK International Data Transfer Addendum (IDTA), ensuring your data receives an equivalent level of protection to UK law.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Data TypeRetention PeriodLegal/Standard Rationale
Scheduling & Booking Data6 years from the date of the appointment.Retained for administrative continuity, booking disputes, and operational audits. (Note: Your primary medical records are kept significantly longer by your local clinical branch).
Financial & Transaction Data6 Years from the end of the financial year in which the transaction occurred.Statutory requirement under UK tax law for HMRC compliance.
Marketing PreferencesUntil Consent is Withdrawn (or after 24 months of total inactivity).Kept as long as you wish to hear from us. You can unsubscribe instantly via any email link.

9. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. Access to your personal data is limited to those employees, contractors, and other third parties who have a business need to know.

10. Your Legal Rights

Under UK data protection laws, you have rights in relation to your personal data, including the right to:

  • Request access to your personal data.
  • Request correction or erasure of your personal data.
  • Object to processing or request restriction of processing.
  • Request the transfer of your personal data.
  • Withdraw consent at any time (specifically regarding our marketing communications).

To exercise rights regarding data held by the Central Hub, please contact us below. To exercise rights regarding your clinical medical records, please contact your local Clinical Branch directly.

11. Contact Details

  • Full Name of Legal Entity: Thriving Clinics Limited
  • Data Privacy Contact: info@thrivinggp.co.uk
  • Postal Address: Thriving Clinics Limited, C/O Sandison Easson & Co. Rex Buildings, Alderley Road, Wilmslow, Cheshire, United Kingdom, SK9 1HY
  • ICO Registration Number: ZC014651

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 (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.