Privacy Policy
thrivvy Privacy Policy
Last updated: 31 August 2026
This Privacy Policy explains how thrivvy collects, uses and protects personal information when you visit our website, use the thrivvy Beta or Thrivvy Wellbeing Index, contact us, submit a form, book a discovery call, sign up to receive updates, or otherwise interact with us.
It also explains how we use health and wellbeing information provided through the Thrivvy Wellbeing Index and how we use cookies, analytics and advertising technologies.
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:
Thrivvy Ltd
Trading as: thrivvy
Company number: 16203163
Registered office: Unit 4 Webster Court, Carina Park, Westbrook, Warrington, England, WA5 8WD
Website: thrivvy.com
Email: info@thrivvy.com
2. What this policy covers
This policy covers personal information we collect from:
- visitors to the thrivvy website and campaign landing pages;
- participants in the thrivvy Beta and Thrivvy Wellbeing Index;
- people who receive personalised wellbeing insights or test product matches;
- people who sign up for thrivvy news, updates or marketing;
- people who submit enquiries, contact forms or discovery-call requests;
- wellness brands, suppliers, commercial partners and prospective partners; and
- people who participate in research, surveys, product testing or feedback activities.
Different parts of this policy may apply depending on how you interact with thrivvy.
3. Personal information we collect
The information we collect depends on how you use thrivvy.
Thrivvy Wellbeing Index and Beta information
When you participate in the Thrivvy Wellbeing Index or Beta, we may collect information including:
- your name;
- your email address;
- your age range;
- your gender, including where you choose “prefer not to say”;
- information about your wellbeing goals or motivations;
- information about exercise, training or activity;
- information about wellness products or product types you use;
- questionnaire responses relating to areas such as general wellbeing, mood, calm and relaxation, physical activity, energy, body image, eating habits and sleep;
- your Thrivvy Wellbeing Index score;
- personalised wellbeing insights;
- wellbeing priorities or inferences generated from your responses;
- test product matches and recommendations;
- previous results where you complete the Index more than once;
- records associated with your participation in the Beta; and
- records of the consent you provide or withdraw.
For the New Forest Marathon version of the Thrivvy Wellbeing Index, we also ask questions about race motivation, recent training and products or product types used during training.
Some questionnaire responses, scores and information inferred from them may constitute health information or other special-category personal data under UK data protection law.
We treat this information with additional care.
Information required to provide results:
An email address is required to access your Thrivvy Wellbeing Index results.
Providing your email address for this purpose does not mean that you have agreed to receive marketing.
Marketing consent is requested separately and is optional.
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:
- your name;
- your work email address;
- your phone number, if requested or provided;
- your company name;
- your job title, if provided;
- the contents of your message or enquiry;
- information about your organisation, products or partnership interests;
- your communication preferences; and
- records of our correspondence with you.
Consumer marketing information
If you choose to receive thrivvy news, product updates or marketing, we may collect:
- your name;
- your email address;
- your communication preferences;
- the date and source of your consent;
- subscription status; and
- unsubscribe or suppression records.
Website and technical information
When you visit our website or use the Beta, technical information may also be processed, including:
- IP address;
- browser type and version;
- device type;
- operating system;
- date and time of access;
- website or application usage information;
- referral or campaign information;
- basic server logs; and
- security and diagnostic information.
Where required, analytics, advertising or product analytics technologies are only used after the appropriate consent has been obtained.
4. How we use Thrivvy Wellbeing Index and Beta information
We may use Beta and Wellbeing Index information to:
- calculate your Thrivvy Wellbeing Index;
- provide your results;
- generate personalised wellbeing insights;
- identify possible wellbeing priorities;
- generate or prioritise experimental product matches;
- personalise your Beta experience;
- provide and administer Beta access;
- compare results over time where you complete the Index more than once;
- test and improve the questionnaire;
- test and improve our scoring methodology;
- improve our product-matching logic;
- understand how people use thrivvy;
- investigate bugs, errors, security incidents or support requests;
- conduct internal research and statistical analysis;
- understand interest in different wellbeing areas, products and features;
- develop new features, services and products;
- evaluate the performance and usefulness of the Beta; and
- create anonymised and aggregated research and insights.
For example, questionnaire responses together with information such as age range or gender may be used to decide which wellbeing areas or test products are more relevant to show you.
We do not use your individual wellbeing answers, score or health-related inferences to determine prices, restrict your access to services, determine whether you are eligible for the Beta or decide whether a commercial partner should contact you.
5. Health and wellbeing information and explicit consent
Some information collected through the Thrivvy Wellbeing Index may reveal or allow us to infer information about your health or wellbeing.
Where this amounts to special-category health information, we rely on:
- consent under Article 6(1)(a) of the UK GDPR as our lawful basis for processing your personal information; and
- explicit consent under Article 9(2)(a) of the UK GDPR as the condition allowing us to process special-category information.
Before starting the questionnaire, we ask you to actively confirm that you consent to thrivvy collecting and using your health and wellbeing information for the purposes explained to you and in this Privacy Policy.
This consent is separate from:
- your agreement to the Beta Terms of Use; and
- any optional consent to receive marketing.
You do not have to provide this consent. However, because the relevant information is required to calculate your Thrivvy Wellbeing Index and provide personalised Beta results, we cannot provide those features without it.
You may withdraw your consent at any time.
6. How personalised insights and product matching work
thrivvy uses automated processing and profiling to personalise parts of the Beta.
The current Thrivvy Wellbeing Index uses predefined rules to consider information such as:
- your questionnaire responses;
- your resulting wellbeing score;
- areas in which your responses indicate a possible wellbeing priority;
- your age range or gender where relevant to the matching rules; and
- relevant information about products held within thrivvy's product system.
These rules may be used to generate personalised insights or to select, rank or prioritise test product matches.
For example, if your responses indicate that sleep is an area where you would like greater support, the Beta may prioritise products considered relevant to that area.
Product matches are experimental and are intended to support general wellness product discovery.
No thrivvy team member reviews every participant's responses or matches before they are displayed.
This profiling does not make decisions about you that have legal or similarly significant effects.
Further information about the experimental nature and limitations of Beta results and product matching is contained in our Beta Terms of Use.
7. Research, product development and aggregated insights
We may use questionnaire responses, scores, product interactions and Beta feedback to understand how thrivvy performs and how it can be improved.
Where practicable, information used for internal research may be pseudonymised so that it is associated with a user number or another identifier rather than directly with your name.
Pseudonymised information remains personal information where we are capable of reconnecting it to you, and we continue to protect it accordingly.
We may use pseudonymised information internally to:
- test and refine scoring;
- improve product matching;
- identify trends;
- evaluate wellbeing categories;
- develop new products or features;
- conduct statistical analysis; and
- support future commercial product development.
We may also create genuinely anonymised and aggregated information that no longer identifies an individual.
We may use or share such anonymised findings in:
- thrivvy website content;
- reports;
- presentations;
- investor or commercial materials;
- event findings;
- partner presentations;
- public-relations or media activity;
- academic or independent research; and
- product and service development.
We may analyse anonymised findings by factors such as age range, gender, broad location, event, wellbeing area or questionnaire response patterns where this can be done without identifying individuals.
We use aggregation, suppression or other disclosure controls where appropriate to reduce identification risk, particularly for small or distinctive groups.
Partners such as New Forest Marathon will receive anonymous group findings only, not participant-level questionnaire responses or wellbeing scores.
Genuinely anonymised information may continue to be used after the personal information from which it was created has been deleted because it can no longer be linked back to an identifiable person.
We will seek separate permission before using your name, image, identifiable quotation, testimonial, review or individual story for promotional purposes.
8. Withdrawal of consent and deletion
You may withdraw your consent to the processing of your health and wellbeing information at any time.
You can currently do this:
- through the “delete my data” option available from your survey results; or
- by emailing info@thrivvy.com.
Where you withdraw this consent, we will:
- stop future processing that depends on that consent;
- stop or disable personalised Beta functionality that requires the information;
- delete or anonymise questionnaire responses, scores and related wellbeing inferences where appropriate; and
- retain only limited information where reasonably necessary to record that consent was withdrawn or to comply with our legal obligations.
Withdrawal does not affect processing that was lawful before consent was withdrawn.
Because health and wellbeing information is necessary to provide personalised Wellbeing Index functionality, withdrawing consent may mean that some or all personalised Beta functionality is no longer available to you.
Whether other non-wellbeing account or registration information remains after withdrawal will depend on the information involved, the request you make and any applicable legal or operational requirements.
Where appropriate, you may complete the Thrivvy Wellbeing Index again in future rather than altering an earlier questionnaire response.
9. AI and technology providers used in the Beta
We use technology providers to help us operate and develop thrivvy.
For the current New Forest Marathon Beta, Anthropic may process certain wellbeing questionnaire responses on our behalf in connection with operating and providing Beta functionality.
The information provided to Anthropic for this purpose does not include your name, email address, age range, gender or other demographic information.
Questionnaire information provided to a technology provider remains personal information where it can still relate to an identifiable or pseudonymous participant, and we require service providers processing personal information on our behalf to protect it appropriately.
We do not permit wellness brands, event partners or other commercial partners to receive identifiable questionnaire responses, scores or personalised product matches.
We are continuing to review and document the detailed technical configuration of our Beta service providers and will update this Privacy Policy where necessary if our providers or processing arrangements materially change.
10. Marketing
Where you actively choose to receive thrivvy news, product updates or marketing communications, we rely on your consent.
Marketing consent is optional.
Choosing not to receive marketing does not prevent you from receiving your Thrivvy Wellbeing Index results or participating in the Beta.
For participants who give marketing consent, we may send their first name, email address and relevant marketing preference information to HubSpot, which we use to manage marketing contacts and communications.
We do not send individual Thrivvy Wellbeing Index questionnaire responses, wellbeing scores, personalised insights or product matches to HubSpot for this purpose.
You can withdraw marketing consent at any time by:
- clicking the unsubscribe link in a marketing email; or
- contacting us at info@thrivvy.com.
We may retain a limited suppression record so that we know not to send further marketing to an email address that has opted out.
11. Other ways we use personal information
We may also use personal information to:
- respond to enquiries;
- arrange and manage discovery calls;
- communicate with prospective partners and wellness brands;
- assess potential commercial relationships;
- manage our CRM records and business relationships;
- send relevant B2B communications where permitted;
- maintain and secure our website and services;
- investigate misuse or security incidents;
- maintain appropriate business records;
- comply with legal, regulatory, tax and accounting obligations; and
- establish, exercise or defend legal rights.
We do not sell your personal information.
12. Other lawful bases
Different lawful bases apply to different thrivvy activities.
B2B enquiries and commercial relationships
We generally rely on our legitimate interests to respond to B2B enquiries, arrange calls, manage prospective commercial relationships and communicate with relevant business contacts.
Our legitimate interests include operating and developing thrivvy, managing commercial relationships and responding to organisations interested in working with us.
You can object to processing based on legitimate interests.
Consumer marketing
We rely on consent where you choose to receive consumer marketing.
Website security and operation
We may rely on legitimate interests where necessary to operate, secure, maintain and protect our website and services.
Legal obligations
We may process information where necessary to comply with legal, regulatory, tax or accounting obligations.
13. HubSpot and CRM
We use HubSpot to manage CRM records, website forms and marketing communications.
Depending on how you interact with thrivvy, HubSpot may process information such as:
- name;
- email address;
- company information;
- enquiry details;
- communication records;
- marketing preferences;
- subscription status; and
- consent or unsubscribe records.
For the NFM Wellbeing Index, questionnaire answers, scores, personalised insights and product matches are not sent to HubSpot for marketing purposes.
14. Cookies, analytics and advertising technologies
We use cookies and similar technologies to operate our website and understand how it is used.
Some technologies are strictly necessary for the service to function. Others are optional and are controlled through our cookie-consent settings.
Depending on the technologies currently active, we use or may use:
- Google Analytics for website analytics;
- Meta advertising technologies;
- product analytics technologies such as PostHog;
- HubSpot website and analytics technologies; and
- affiliate or conversion-tracking technologies.
These technologies may be used for purposes including:
- understanding website usage;
- measuring advertising performance;
- attributing registrations or conversions;
- campaign optimisation;
- retargeting;
- frequency control;
- creating advertising audiences; and
- creating similar or lookalike audiences.
Where required, analytics, marketing and product-analytics technologies will not operate unless you have enabled the relevant consent category.
You can:
- accept optional technologies;
- reject them;
- choose individual categories; and
- change your preferences later.
Our Cookie Policy and cookie-preference centre provide further information about the technologies currently in use.
We may use advertising measurement or attribution on public thrivvy pages and campaign landing pages.
We do not intend advertising platforms to receive individual Wellbeing Index questionnaire responses, scores, personalised wellbeing insights, matched products or other information revealing your individual health or wellbeing profile.
Advertising tracking is not intended to follow users through personalised questionnaire, results or other sensitive Beta areas.
We may in future use services such as advanced matching, customer audiences or server-side conversion measurement. Where we do, we will assess the information involved, apply appropriate consent controls and update our privacy or cookie information where necessary.
15. Who receives personal information
We may share personal information with trusted organisations that help us provide and operate thrivvy.
These may include:
- website hosting and infrastructure providers;
- database and cloud-service providers;
- authentication providers;
- providers supporting questionnaire or Beta functionality;
- technology and AI service providers, including Anthropic where applicable;
- analytics and product-analytics providers;
- CRM and email providers, including HubSpot;
- error-monitoring and security providers;
- customer-support providers;
- backup and storage providers;
- developers and technical contractors who require authorised access;
- professional advisers such as lawyers and accountants; and
- regulators, courts or authorities where disclosure is legally required.
Service providers processing personal information on our behalf are expected to use it only for authorised purposes and protect it appropriately.
Wellness brands, New Forest Marathon and other commercial or event partners will not receive identifiable individual questionnaire responses, Wellbeing Index scores or personalised product matches.
They may receive genuinely anonymised and aggregated findings.
16. Hosting and international transfers
thrivvy uses third-party hosting, infrastructure and technology services.
Parts of our website infrastructure are currently hosted using Amazon Web Services (AWS), including infrastructure in the European/Ireland region.
Some of our service providers may process or make personal information accessible outside the United Kingdom.
Where a restricted international transfer takes place, we take steps designed to ensure that the information receives an appropriate level of protection in accordance with UK data protection law.
Depending on the provider and destination, these safeguards may include:
- UK adequacy regulations;
- the UK International Data Transfer Agreement;
- the UK Addendum to approved Standard Contractual Clauses; or
- another lawful transfer mechanism.
You can contact us for further information about safeguards applying to a particular transfer.
17. How long we keep personal information
We keep identifiable personal information only for as long as reasonably necessary for the purposes for which it was collected, taking into account:
- whether you remain an active Beta participant;
- whether the information is required to provide your results or personalised features;
- the nature and sensitivity of the information;
- whether it remains useful for legitimate research, testing or product-development purposes;
- whether it has been pseudonymised or anonymised;
- security and technical requirements;
- legal, regulatory or contractual requirements; and
- the need to establish or defend legal rights.
As a current working retention approach:
- active Beta information may be retained while you participate in the Beta;
- Beta information associated with inactive or dormant participation will generally not be retained in identifiable form for more than 24 months after your last activity, unless there is a specific reason requiring longer retention;
- marketing contact information may be retained while you remain subscribed;
- suppression information may be retained for as long as reasonably necessary to honour an opt-out;
- consent and withdrawal records may be retained where reasonably necessary to demonstrate compliance;
- technical and security logs are generally retained for shorter operational periods; and
- information contained in backups may remain until the applicable backup is securely overwritten or deleted.
Where information is no longer needed in identifiable form, we may delete it or convert it into genuinely anonymised information.
Genuinely anonymised information is no longer personal information and may be retained and used for research, statistical analysis and product development.
We are reviewing our detailed technical retention schedule as the Beta develops and will update this policy if our retention practices materially change.
18. Your rights
Depending on the circumstances, UK data protection law may give you rights to:
- access personal information we hold about you;
- ask us to correct inaccurate information;
- ask us to delete your information;
- ask us to restrict how we use your information;
- object to processing based on legitimate interests;
- object to direct marketing at any time;
- receive certain information in a portable format;
- withdraw consent where processing relies on consent; and
- raise concerns about how your information is being used.
Some rights depend on the circumstances and lawful basis involved and are not absolute in every case.
To exercise your rights, contact:
You also have the right to complain to the UK Information Commissioner's Office (ICO) if you are unhappy with how we handle your information.
19. Security
We use technical and organisational measures designed to protect personal information against:
- unauthorised access;
- accidental loss;
- misuse;
- alteration; and
- unauthorised disclosure.
Access to personal information is restricted where appropriate to people who require it for authorised business or technical purposes.
No internet-based system can be guaranteed to be completely secure, but we take reasonable steps to protect the information we hold.
20. Participants under 18
The Thrivvy Wellbeing Index and current Beta are intended for people aged 18 or over.
If you indicate that you are under 18, you will not be able to continue with the Wellbeing Index questionnaire.
We do not knowingly use the current Beta to collect health and wellbeing questionnaire information from children.
21. Feedback
If you provide feedback about the Beta, we may use that feedback to:
- evaluate thrivvy;
- improve features and functionality;
- conduct research and analysis; and
- develop future products and services.
We may use feedback in anonymised or aggregated form.
We will obtain separate permission before publicly attributing a testimonial, identifiable quotation, image, review or personal story to you.
Further provisions concerning Beta feedback are contained in our Beta Terms of Use.
22. Changes to this policy
We may update this Privacy Policy as thrivvy develops, our technology providers change, new features are introduced or our legal or regulatory obligations change.
We will update the date at the top when we make changes.
Where a change materially affects how we use personal information, we will take appropriate steps to bring the change to the attention of affected users and seek new consent where required.
23. Contact us
For questions about this Privacy Policy, withdrawal of consent, deletion requests or other data-protection matters, contact:
Thrivvy Ltd
Trading as: thrivvy
Company number: 16203163
Registered office: Unit 4 Webster Court, Carina Park, Westbrook, Warrington, England, WA5 8WD
Email: info@thrivvy.com
Website: thrivvy.com