Privacy Policy

Last updated: 01.06.26

This Privacy Policy explains how thrivvy collects, uses and protects personal information when you visit our website, contact us, submit a form, book a discovery call, or sign up to receive updates from us.

This Privacy Policy reflects thrivvy's current website and data processing activities. At this stage, we use the website to support brand and partner enquiries, discovery-call requests, and consumer launch updates.

We do not currently collect wellness quiz responses, health information, personalised recommendation data, consumer account data, or product-matching information.

We will review and update this Privacy Policy as thrivvy's website, CRM, analytics, quiz, email marketing, partner activity and consumer features develop.

1. Who we are

thrivvy is a wellness discovery and product-matching platform designed to help people make more confident wellness decisions and help wellness brands reach relevant audiences.

For the purposes of UK data protection law, the data controller is:

2. What this policy covers

This policy covers personal information we collect from:

At this initial launch stage, the website collects limited personal information through HubSpot forms.

As thrivvy develops, this policy will be expanded before we introduce features such as consumer accounts, wellness quizzes, product matching, affiliate tracking, analytics, advertising cookies, or partner data-sharing arrangements.

3. Personal information we collect

The personal information we collect depends on how you interact with us.

B2B enquiry and discovery-call information

If you submit a B2B form, request a discovery call or contact us about working with thrivvy, we may collect:

We use this information to respond to your enquiry, arrange and manage a discovery call, assess whether there may be a suitable commercial relationship, send relevant follow-up information about thrivvy in a business context, and maintain appropriate CRM records.

Consumer launch update information

If you sign up to receive updates about thrivvy's launch or development, we may collect:

We use this information to send you updates about thrivvy, including launch news and relevant information about the service as it develops.

Website usage and technical information

When you visit our website, some limited technical information may be processed automatically to help deliver the website securely and correctly. This may include:

At this initial launch stage, we do not use analytics, advertising, retargeting or behavioural tracking cookies on the thrivvy website.

If we introduce analytics, advertising pixels, retargeting, HubSpot tracking code, affiliate tracking or similar technologies in future, we will update this policy and introduce an appropriate cookie consent mechanism before using non-essential cookies.

The ICO explains that non-essential cookies generally require consent, while cookies that are strictly necessary to provide a service requested by the user may be exempt.

Information we do not currently collect

At this stage, we do not collect:

Before collecting this type of information, we will review whether any special category data is involved and update our privacy wording, consent flows, retention rules and security measures as needed.

4. How we use personal information

We use personal information to:

We will not sell your personal information.

5. Our lawful bases for using personal information

We only use personal information where we have a lawful basis to do so under UK data protection law.

B2B enquiries and discovery calls

When you submit a B2B enquiry or request a discovery call, we usually rely on legitimate interests to process your information so that we can respond, arrange the call, follow up on your enquiry and manage a potential commercial relationship.

Our legitimate interests include responding to business enquiries, developing commercial partnerships, managing our CRM, and communicating with relevant business contacts about thrivvy where this is relevant to their role, organisation, enquiry or likely business interests.

We only use B2B contact information in ways that we consider proportionate and relevant. You can object to processing based on legitimate interests at any time by contacting us.

Where we send B2B communications by email, we will do so in line with applicable electronic marketing rules. We may contact corporate business contacts about relevant partnership opportunities without prior consent where permitted, but we will always provide a clear way to opt out. If we contact sole traders or other individual subscribers, different rules may apply and we will only do so where we have the appropriate permission or lawful basis.

Consumer launch updates

Where you sign up to receive consumer updates from thrivvy, we rely on consent.

We will not send consumer marketing emails unless we have the appropriate permission to do so.

You can withdraw your consent at any time by clicking the unsubscribe link in our emails or contacting us directly.

Website security and operation

We may use technical information where necessary for our legitimate interests in operating, securing and maintaining the website.

Legal obligations

We may process personal information where necessary to comply with legal, tax, accounting or regulatory obligations.

6. B2B privacy section

This section applies to wellness brands, suppliers, agencies, commercial partners and prospective partners.

If you complete a form, book a call or otherwise contact thrivvy in a business capacity, we will use your information to:

We use HubSpot to collect website form submissions and manage contact records.

You can unsubscribe from B2B marketing communications at any time using the unsubscribe link in the email or by contacting us.

7. Consumer privacy section

This section applies to visitors who sign up to receive consumer updates about thrivvy.

At this initial launch stage, the consumer-facing page is an information splash page. If you choose to sign up for updates, we will use your name and email address to send you information about thrivvy's launch and development.

We do not currently use the consumer page to collect wellness quiz responses, health information, lifestyle information, product preferences, personalised matching information, or account data.

Before thrivvy launches consumer-facing quizzes, personalised matching, recommendation tools or account functionality, we will update this Privacy Policy to clearly explain:

thrivvy will not share identifiable consumer quiz responses with commercial partners unless this has been clearly explained and an appropriate lawful basis is in place.

8. HubSpot forms and CRM

We use HubSpot to collect website form submissions and manage contact records.

When you submit a HubSpot form on our website or through a HubSpot-hosted form page, the information you provide may be processed by HubSpot on our behalf.

We use HubSpot to:

HubSpot publishes information about its data processing terms and sub-processors. HubSpot states that its sub-processor page forms part of its Data Processing Agreement and customer agreement.

9. Website hosting

The thrivvy landing pages are hosted using Amazon Web Services, commonly known as AWS.

Our primary website hosting region for the landing pages is AWS eu-west-1, which is located in Europe/Ireland. Static images and related delivery services may be served through AWS or CDN infrastructure in other regions, including the United States.

AWS may process limited technical data needed to host, secure and deliver the website, such as server request information and security-related logs. AWS provides a Data Processing Addendum for customers using AWS services to process personal data.

Where any personal information is processed outside the UK, we take steps designed to ensure that it remains protected in accordance with applicable data protection law.

10. Cookies and tracking

At this initial launch stage, we do not use analytics, advertising, retargeting or behavioural tracking cookies on the thrivvy website.

Our website may use strictly necessary technical cookies or similar technologies where required for the website to function securely and correctly.

Where required, we will ask for consent before setting non-essential cookies.

If we introduce analytics, advertising pixels, retargeting, HubSpot tracking code, affiliate tracking or similar technologies in future, we will update this policy and introduce an appropriate cookie consent mechanism before those non-essential cookies are used.

11. Sharing personal information

We may share personal information with trusted service providers who help us operate our website, CRM, forms, email communications, hosting, security and business operations.

These may include:

We only share information where necessary and expect our providers to protect personal information appropriately.

We may also share information if required by law, regulation, court order or to protect our legal rights.

12. International transfers

Some of our service providers may process personal information outside the UK.

Where this happens, we take steps designed to ensure that personal information remains protected in accordance with applicable data protection law. This may include using adequacy regulations, Standard Contractual Clauses, the UK International Data Transfer Addendum, or other appropriate safeguards where required.

13. How long we keep personal information

We keep personal information only for as long as necessary for the purposes described in this policy.

As a starting point:

We will create a more detailed retention schedule as the business develops.

14. Your rights

Under UK data protection law, you may have rights to:

To exercise your rights, contact us at:

Email: info@thrivvy.com

You also have the right to complain to the UK Information Commissioner's Office if you are unhappy with how we handle your personal information.

15. Marketing preferences

You can unsubscribe from marketing emails at any time by clicking the unsubscribe link in our emails or contacting us directly.

If you object to direct marketing, we will stop using your personal information for that purpose.

We may keep a suppression record to make sure we do not contact you again for marketing purposes.

16. Security

We use appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse or disclosure.

No website or online service can be completely secure, but we take reasonable steps to protect the information we hold.

17. Children

thrivvy is not intended for children and we do not knowingly collect personal information from children.

If this changes in future, this Privacy Policy and the website's data collection practices will be reviewed before launch.

18. Changes to this policy

We may update this Privacy Policy from time to time as thrivvy develops or our legal, technical or commercial arrangements change.

In particular, we will update this policy before introducing features such as wellness quizzes, personalised recommendations, consumer accounts, analytics, advertising cookies, affiliate tracking, or partner data-sharing arrangements.

The latest version will be published on our website with the updated date shown at the top.

19. Contact us

For questions about this Privacy Policy or how we use personal information, contact:

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